Food Additives in Pet Food—Their Roles, Regulation, Labeling, and Future

Additives may also deliver specific functional benefits, such as supporting digestion, promoting healthy skin and coat, or improving joint health. In some cases, particularly in medicated feeds, they even serve therapeutic functions.  
 

However, while additives contribute significantly to the quality and safety of pet foods, they are subject to stringent regulatory oversight and growing public scrutiny regarding their safety, labeling, and long-term use. 

Regulatory Framework 

In the United States, oversight of pet food additives is primarily handled by the US Food and Drug Administration (FDA) through its Center for Veterinary Medicine (CVM). The FDA enforces the Federal Food, Drug, and Cosmetic Act (FD&C Act), which classifies any substance intentionally added to food as a food additive that must either be formally approved or recognized as Generally Recognized as Safe (GRAS) for its intended purpose. The Association of American Feed Control Officials (AAFCO), while not a government agency, plays a key role by publishing ingredient definitions and model regulations that most states adopt into law. This collaboration ensures that ingredients are used safely and consistently nationwide, though occasional overlaps and discrepancies between FDA and AAFCO guidance can create uncertainty for manufacturers. 
 

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To provide further clarity, the FDA issued guidance in 2024 outlining how it enforces regulations related to AAFCO-defined ingredients, signaling that it generally defers to AAFCO definitions while maintaining authority over new or unapproved substances. Yet, questions persist around the GRAS process, which allows companies to self-determine ingredient safety without formal FDA review. Government and academic studies have highlighted that many GRAS determinations occur with limited public oversight, raising concerns about transparency and potential conflicts of interest. 
 

Labeling also plays a critical role in maintaining consumer trust and regulatory compliance. Pet food labels must comply with federal and state requirements and include essential information such as the product name, species designation, guaranteed analysis, ingredient list, and manufacturer details. Additives, whether preservatives, vitamins, or functional compounds, must be declared by their common or usual names in descending order by weight. Furthermore, claims like 'contains probiotics' or 'no artificial preservatives' must be accurate and supported by verifiable data.  
 

However, not all substances influencing food safety and quality appear directly on labels. For example, materials that migrate from packaging, such as per- and polyfluoroalkyl substances (PFAS), have raised regulatory concerns. In 2025, the FDA reported progress in phasing out PFAS-based coatings in food packaging to minimize potential health risks. 

Balancing Palatability and Perception 

Flavorings and colorings occupy a unique position among pet food additives, as they primarily influence product appeal rather than nutritional value. Flavorings, also known as palatants, are commonly derived from hydrolyzed animal or plant proteins, yeast extracts, and natural smoke flavors, helping ensure that foods remain palatable, especially in dry formulations. These ingredients are Generally Recognized as Safe when used appropriately and are subject to AAFCO and FDA definitions regarding naming and use. For instance, a product labeled 'with beef flavor' must comply with AAFCO rules concerning the quantity of actual flavor source required. 
 

Color additives serve a different yet equally important purpose: ensuring that food's appearance aligns with consumer expectations. Many colors approved for pet food use fall under the FDA's regulations in 21 CFR Parts 70, 73, and 74, which specify certified and exempt color additives. Substances such as iron oxide and titanium dioxide are common, along with natural colorants like beet juice or annatto. However, regulatory and consumer scrutiny is intensifying. In April 2025, the FDA announced an initiative to phase out petroleum-based synthetic dyes, including FD&C Red No. 3, Red No. 40, Yellow No. 5, Yellow No. 6, Blue No. 1, and Blue No. 2, with compliance required over the next two years. 
 

While pets themselves do not perceive color as humans do, pet owners often judge quality visually. As a result, pet food manufacturers have relied on colorants to ensure a consistent product appearance. The transition away from synthetic dyes is prompting manufacturers to explore FDA-approved natural alternatives such as anthocyanins, betalains, carotenoids, chlorophylls, spirulina, butterfly pea flower extract, and algae-derived pigments. These natural colorants present challenges, including variable stability under heat, pH sensitivity, lower color strength, and potential flavor carryover. Manufacturers may also use blends or 'exempt-from-certification' pigments to maintain visual consistency while adhering to regulatory restrictions. In some cases, companies are reducing or eliminating color altogether and emphasizing 'natural appearance' on labels to meet consumer expectations and avoid synthetic dyes. 

Future Innovation, Transparency, and Consumer Trust 

Scientific evidence, regulatory developments, and consumer preferences will likely shape the future of additives in pet food. Traditional additives such as vitamins, preservatives, and texturizers will remain integral, but newer substances, including enzymes, probiotics, and botanical extracts, face heightened scrutiny. Legislative proposals to establish new categories like 'zootechnical additives' underscore the evolving regulatory landscape. Meanwhile, market trends toward 'clean-label' and naturally formulated products are driving innovation and reformulation. 
 

Some food additives are classified as drugs, and their withdrawal times must always be considered. Although withdrawal periods are most commonly associated with livestock feeds, they remain an important consideration across the broader feed industry. These periods represent the time between the administration of a medicated feed or drug and when an animal or its products can safely enter the food supply, ensuring that residue levels remain below established safety limits. Even in pet food facilities that may also handle medicated livestock feed, observing withdrawal times helps prevent cross-contamination and supports the highest standards of safe manufacturing practices.  

Your Trusted Partners 

Successfully navigating this complex environment requires both scientific expertise and strategic compliance planning. BSM Partners provides this support, assisting companies with regulatory compliance, additive safety evaluation, state registration submissions, and label claim development. BSM Partners can also help pet food manufacturers transition to natural colorants, ensuring that formulations maintain product appeal, stability, and regulatory compliance while meeting evolving consumer expectations. By partnering with BSM Partners, companies can proactively manage risk, innovate confidently, and bring safe, appealing products to market. 

 

By Dr. Emily Taylor
Source: BSM Partners