Treat claims must stay within the allowable “food” boundaries, such as: • Taste • Aroma • Nutritional value (that is consistent with intended use) • Technical effects (e.g., preservative) • Dental claims via mechanical/abrasive action Claims outside these boundaries can trigger: • State registration challenges/stop-sale notices • FDA enforcement risk (including warning letters for egregious claims)
Why “Functional Treats” Are a Problem “Functional treat” is a marketing term, not a regulatory category. The concern is that “functional” often implies health benefits beyond food claim boundaries, which creates: • Industry and consumer confusion • Regulatory inconsistency • Increased enforcement risk Another core takeaway: Avoid dual-purpose positioning (nutritional + nonnutritional health benefit) in treats.
NASC Treat Program Requirements (how to qualify)