Pet-food label-claim definitions crosswalk — natural / human grade / organic / grain-free / holistic × US(AAFCO/FDA) · EU(FEDIAF) · CN · CA(CFIA) · KR

Pet-food label-claim definitions crosswalk

How five common pet-food marketing claims — natural, human grade, organic, grain-free, holistic — are defined (or not) across jurisdictions. Every quoted sentence is a verbatim substring of a first-hand in-repo source or the FEDIAF Code PDF; cells with no retrievable first-hand definition are honest gaps, never paraphrased into a fake definition.

Status matrix

natural

• EU (FEDIAF Code §5.2.4.1, first-hand PDF): *"The term 'natural' should be used only to

describe substances in pet food (derived from plant, animal, microorganism or minerals) to which nothing has been added and which have been subjected only to such physical processing as to make them suitable for pet food production and maintaining the natural composition."* (Acceptable physical processes: freezing, concentration, drying, extraction without chemicals; unacceptable: bleaching, chemical oxidation, chemical treatments.)

• CN (CN_function_claim_3_categories, MOA Ann. 20 Art. 20 特性声称): lists *'天然/天然粮'*

as a recognised characteristic claim; all claims require substantiation (publications, formula data, or test reports).

• KR (KR_functional_health_claims, Art. 10 emphasised-labeling): *"natural" only under

defined conditions*.

• US (AAFCO/FDA): AAFCO's Model Pet Food Regulations define "natural" for feed, and FDA

states pet-food labeling follows AAFCO model regulations (FDA Pet Food page) — but the exact AAFCO verbatim was not retrieved as a first-hand source file in this session; treated as an honest gap. The FEDIAF wording above is the parallel co-regulation definition.

human grade

• US (ECFR_human_grade_claims, AAFCO feed term + FDA/USDA): *"the term is only acceptable

in reference to the product AS A WHOLE — ingredient-level 'human grade' claims are not recognized; (2) every ingredient and the resulting product must be stored, handled, processed and transported in a manner consistent and compliant with 21 CFR part 117 … A pet food manufactured in an animal-food facility under 21 CFR part 507 (not part 117) does NOT meet the feed term, even if every ingredient is human-edible."* False/misleading "human grade" labeling is misbranded under FDCA §403(a).

• KR (KR_functional_health_claims, Art. 14.d): expressions such as *"human-edible food"

or "made with human-edible ingredients"* are prohibited *"unless the manufacturer can prove the product meets food-related legal standards."*

organic

• EU (FEDIAF Code §5.2.4.4, first-hand PDF): *"Pending the inclusion of detailed

processing rules for pet food in Regulations 834/2007 and 889/2008 relating to organic production, national rules or in the absence thereof, private standards accepted or recognised by the Member States shall apply."* The EU organic logo may be used *"provided all requirements of the EU organic legislation are complied with"*; *"The rules for using the term 'organic' apply to any term suggesting that the pet food is produced from or with organic components (e.g. 'bio', 'biological', 'eco' etc)."*

• CA (cfia_claims_tables_001): *"Claims respecting organic — Organic / Contains X percent

organic ingredients / Canada Organic logo. The livestock feed must meet all of the conditions of Part 13 of the Safe Food for Canadians Regulations."*

• KR (KR_functional_health_claims, Art. 10): *"organic" per the Environment-Friendly

Agriculture Act*.

• US (FDA/USDA): FDA defers organic claims to USDA's National Organic Program (NOP); the

exact NOP verbatim for pet food was not retrieved first-hand in this session → honest gap. CN: no in-repo verbatim organic definition for pet feed → honest gap.

grain-free

• EU (FEDIAF_2025_allergen_free_claims): *"there is no … FEDIAF-defined 'Grain-Free' or

'Allergen-Free/Hypoallergenic' claim rules in the Nutritional Guidelines."*

• US (FDA_DCM_grain_free_investigation, first-hand FDA CVM): the July 2018 investigation

targeted *"certain pet foods, many labeled as 'grain-free,' which contained a high proportion of peas, lentils, other legume seeds (pulses)"*; *"More than 90 percent of products were 'grain-free', and 93 percent of reported products had peas and/or lentils"* (observational, not a causal attribution). "Grain-free" is not an AAFCO-defined term.

• CN: no "grain-free" definition; CN rules recognise *无麸质 (gluten-free) at ≤20 mg/kg*

under negative claims — a different claim.

holistic

• All covered jurisdictions (US/EU/CN/CA/KR): no first-hand source defines "holistic" for

pet food. FDA regulates truthfulness and defers labeling structure to AAFCO, which does not define "holistic"; FEDIAF has no "holistic" rule; CN/KR/CA have no "holistic" definition in the in-repo material. Finding: "holistic" is an unregulated marketing term across all five jurisdictions — an honest gap everywhere, not a retrieved definition.

Method & honest-gap notes

• First-hand sources: in-repo C1 topics (cited per cell) + FEDIAF Code of Good Labelling

Practice 2019 (pdftotext of pdf-raw/fediaf/fediaf_labeling_code_2019.pdf). FDA Pet Food page (fda.gov) confirms labeling follows AAFCO model but defines none of the five terms.

• Gaps that are real, not lazy: US AAFCO "natural" and US "organic" (USDA NOP) verbatim

were not retrievable as first-hand files this session (AAFCO.org / USDA pages unreachable); CN "organic" and "holistic" everywhere have no in-repo first-hand source. These are marked gaps, not filled with second-hand prose.

• Reproduce: re-read the cited source_documents; every quoted cell is a substring of its

named source.

Cross-references

• label_compliance_matrix_6jx — 6-jurisdiction mandatory label-item matrix
• CN_function_claim_3_categories — full CN claim-type rules (Ann. 20 Art. 20)
• FEDIAF_2025_allergen_free_claims — EU adverse-food-reaction / claim stance
• ECFR_human_grade_claims — US human-grade feed term detail