Topic Overview
Veterinary drug residues and unapproved new animal drugs represent a distinct violation category under the FD&C Act, specifically targeting food-producing animals and animal feed. These charges apply when pet food or feed ingredients contain prohibited pharmaceutical substances — including banned growth promoters, antibiotics, and unapproved animal pharmaceuticals — or when feed contains animal drugs lacking required approval.
> ⚠️ Data Note: Built from official charge code taxonomy (ACT_SECTION_CHARGES.CSV). Live refusal counts by country/date require Qlik Sense dashboard session. Charge codes are the authoritative violation taxonomy.
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1. Veterinary Drug Residues (VETDRUGRES)
Charge Code: VETDRUGRES Legal Basis: Section 402(a)(2)(C)(ii), 801(a)(3); ADULTERATION Charge Statement (verbatim from CSV):
> "The article is subject to refusal of admission pursuant to Section 801(a)(3) in that it appears to contain a new animal drug... [or drug residue]..."
Why It Matters for Pet Food:
- Pet food ingredients derived from food-producing animals (chicken, beef, fish) can carry drug residues if the source animals were treated with unapproved substances
- Common violators: chloramphenicol, nitrofurans, fluoroquinolones, sulfonamides, melamine (historically)
- FDA monitors for both intentional doping (growth promoters in livestock) and environmental contamination
- Section 402(a)(2)(C)(ii) is specifically triggered when the drug is not approved for the species or use level
Snippet from official CSV: `` CODE: VETDRUGRES SECTION: 402(a)(2)(C)(ii); 801(a)(3); ADULTERATION TEXT: The article is subject to refusal of admission pursuant to Section 801(a)(3) in that it appears to contain a new animal drug... ``
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2. Nitrofurans (NITROFURAN)
Charge Code: NITROFURAN Legal Basis: Section 402(a)(2)(C)(i), 801(a)(3); ADULTERATION Charge Statement (verbatim from CSV):
> "The article appears to bear or contain a food additive, namely nitrofurans..."
Why It Matters:
- Nitrofurazone, furazolidone, nitrofurazone — FDA-prohibited antibiotics in food-producing animals since 1991
- Frequently detected in seafood and aquaculture products used in pet food (fish jerky, shrimp treats)
- No MRL (Maximum Residue Limit) established — any detectable level triggers refusal
- China, Vietnam, and India have historically been flagged for nitrofuran contamination in aquaculture
Snippet from official CSV: `` CODE: NITROFURAN SECTION: 402(a)(2)(C)(i), 801(a)(3); Adulteration TEXT: The article appears to bear or contain a food additive, namely nitrofurans (a prohibited substance in food-producing animals). ``
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3. Unapproved New Animal Drug (NEW VET DR)
Charge Code: NEW VET DR Legal Basis: Section 501(a)(5), 801(a)(3); ADULTERATION Charge Statement (verbatim from CSV):
> "The article is subject to refusal of admission pursuant to Section 801(a)(3) of the Federal Food, Drug, and Cosmetic Act in that the article appears to be a new animal drug for which approval is required..."
Why It Matters:
- Any animal drug product without an approved New Animal Drug Application (NADA) or Abbreviated NADA (ANADA) is technically unapproved and subject to refusal
- This includes bulk active pharmaceutical ingredients (APIs) imported for pet food supplement formulations
- The 708NEWANIM code is a more specific variant targeting drugs lacking NADA specifically
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4. New Animal Drug Without Approved Application (708NEWANIM)
Charge Code: 708NEWANIM Legal Basis: Section 501(a)(5), 801(a)(3); ADULTERATION Charge Statement (verbatim from CSV):
> "The article has been determined to be a new animal drug without an approved new animal drug application."
Snippet from official CSV: `` CODE: 708NEWANIM SECTION: 501(a)(5), 801(a)(3); ADULTERATION TEXT: The article has been determined to be a new animal drug without an approved new animal drug application. ``
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5. Animal Feed with New Animal Drug (FEED & NAD)
Charge Code: FEED & NAD Legal Basis: Section 501(a)(6), 801(a)(3); ADULTERATION Charge Statement (verbatim from CSV):
> "The article appears to be an animal feed bearing or containing a new animal drug, and such animal feed is unsafe within the meaning of §501(a)(6)..."
Why It Matters:
- This is the pet food / feed-specific drug charge — it targets feed products that contain animal drugs
- Key distinction from 501(a)(5): this applies to the feed itself, not just the drug ingredient
- A pet food or treat containing a drug-supplemented feed additive without proper approval falls here
Snippet from official CSV: `` CODE: FEED & NAD SECTION: 501(a)(6), 801(a)(3); ADULTERATION TEXT: The article appears to be an animal feed bearing or containing a new animal drug, and such animal feed is unsafe within the meaning of section 501(a)(6) of the FD&C Act. ``
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6. Chlorofluorocarbons in Animal Drugs (FLUOROCARB)
Charge Code: FLUOROCARB Legal Basis: Section 501(a)(5), 801(a)(3); ADULTERATION Charge Statement (verbatim from CSV):
> "The article appears to be a new animal drug containing chlorofluorocarbons in violation of 21 CFR 2.125."
Why It Matters:
- 21 C.F.R. § 2.125 bans chlorofluorocarbon (CFC) propellants in drug products
- Relevant for aerosolized pet medications or veterinary pharmaceutical aerosols imported for pet use
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7. Veterinary Drug Labeling Charges
VET LEGEND — Missing Caution Statement
- Code:
VET LEGEND - Basis: 502(a) & (f)(1), 801(a)(3); MISBRANDING
- Statement: "The article appears to be a veterinary drug without the 'Caution' statement as required by Section 503(f)(4)."
RXVETLACK2 — Missing Veterinary Caution
- Code:
RXVETLACK2 - Basis: 503(f)(4), 801(a)(3)
- Statement: "The article appears to be a veterinary drug which requires but lacks the 'Caution' statement specified at Sec. 503(f)(4)."
708VETLGND — Veterinary Caution (variant)
- Code:
708VETLGND - Basis: 502(a) & (f)(1), 801(a)(3); MISBRANDING
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8. Relevant Regulatory Framework
| Item | Citation |
|---|---|
| New Animal Drug definition | 21 U.S.C. § 321(v) |
| NADA / ANADA requirement | 21 U.S.C. § 360b |
| Section 501(a)(5) — unapproved NAD | 21 U.S.C. § 351(a)(5) |
| Section 501(a)(6) — feed with unapproved drug | 21 U.S.C. § 351(a)(6) |
| 402(a)(2)(C) — unsafe drug residue | 21 U.S.C. § 342(a)(2)(C) |
| Nitrofuran prohibition | 21 C.F.R. § 530.41 |
| CFR propellant ban | 21 C.F.R. § 2.125 |
| MRL / tolerance established? | FDA/CVM Tier 1 |
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Source: ACT_SECTION_CHARGES-20260721.csv (official charge codes, 306 entries)