Less than six months later on May 12, 2025, the agency issued a Notice of Proposed Rulemaking to fully rescind the standard for mushrooms and pet food, citing efforts to reduce the regulatory burden for smaller certifiers and producers. This proposal has been ill-received by industry stakeholders and consumers alike, with many claiming that market development of organic mushroom and pet food products would suffer.
The term 'organic' carries some scrutiny among consumers, regardless of whether it's on a pet food package or a bundle of carrots. This is for good reason, as there have been several documented cases of organic certifiers validating operations that violated organic standards, going so far as to take money from agribusiness giants and concentrated animal feeding operations (CAFOs) to fudge certifications in their favor. One particularly public example was Jirah Milling, a Canadian grain exporter that was caught mixing non-organic grains with organic grains and selling the mixture as 'certified organic.'
Without a standard, what's stopping this from happening in pet food?
The Public Reacts
The Organic Trade Association (OTA) was one of the first to sound off in opposition to the proposed rescission, noting it was issued without insight from the National Organic Standards Board (NOSB), which is a Congressional entity put in place to ensure industry voices are heard in conversations about organic standards, as well as to promote standards transparency.
'This departure from established protocol threatens to undermine stakeholder trust and the integrity of the organic regulatory process while also setting a troubling precedent,' the OTA stated in its press release.
The Pet Sustainability Coalition took up the mantel for organic proponents in the pet industry, stating, 'Rescinding the rule would reverse years of progress, increase regulatory confusion, and harm small businesses, processors, and pet food companies working to meet growing consumer demand for organic options.'
The public also expressed its concern through more than 9,800 comments received during a public comment period which ended June 11.
'If adopted, this rollback would result in organic pet food being regulated under the same standards as livestock feed. This is fundamentally inappropriate. Pets are not livestock—they are family members,' said one commenter.
'Organic pet food deserves regulations that reflect its intended purpose—feeding pets safely—not loopholes that compromise quality and trust,' another commenter posted.
'Our pets deserve better,' added another.
On the surface, these concerns stem from regulatory uncertainty and the negative impacts that come with it, but at their core, they're really about preserving consumer trust and pet health.
Understanding Demand for Organic
Clearly, regulatory rollbacks and inconsistent enforcement pose a risk to organic demand as a whole. But just how strong is this demand in the first place?
In 2022, organic products accounted for roughly 6% of total human food sales in the United States, according to data from Euromonitor International. This represents a mere 1% increase from 2015, when organic product sales made up 5% of total food sales. This slow growth begs the question—is the demand really there?
Organic pet food sales, however, seem to be outpacing overall organic food sales. Organic pet food products saw high single-digit annual sales growth over the last five years, according to data from Future Market Insights Inc., driven largely by trends toward humanization and increasing interest in functional, sustainable pet food products.
However, inflation and economic uncertainty are a sticking point for pet nutrition, and organic pet nutrition is no exception. Competing claims like 'regenerative,' 'local,' and 'carbon-neutral' could be fragmenting consumer trust and attention, and removing the official standard for organic labeling would only make matters worse.
Further, in the eyes of consumers, organic claims are certainly subject to greenwashing accusations, which serve to undermine the growth of this category as a whole. Third-party certifying bodies tend to vary in their defined standards and requirements when vetting suppliers and brands against organic claims. This makes it easier for brands to overstate their organic positioning and could lead to greenwashing—and the quick devolution of consumer trust in this category.
If the pet industry—inclusive of growers, ingredient suppliers, manufacturers, brands, retailers, and pet parents—want to keep organic pet food on the table, it is imperative to establish regulatory standards that streamline certifications and clarify producer requirements, both of which would support consumer trust in organic label claims.
What Now?
The USDA's public commentary period ended June 11 and the organization is now reviewing submissions to help guide its decision-making process. However, the wheels of government turn slowly, and it could be several months before the USDA releases a decision to either uphold the current standard, refine it, or rescind it entirely.
While organic pet food producers are stuck in a holding pattern, taking a 'wait and see' approach to brand strategy could put you behind the ball. You can monitor this docket for updates as this story develops, but better yet, now is the time to start educating your consumers about the importance of organic standards and how your brand will maintain claim integrity in the potential absence of this standard. If your business relies heavily on organic claims, it could be useful to discuss differentiation strategies to ensure your brand is meeting demand where it wants to be met.
BSM Partners' expert team is perfectly positioned to help brands navigate new regulatory uncertainties and shifts like this one. Our Nutrition and Innovation practice can formulate and reformulate to meet evolving consumer needs and expectations, as well as provide claim substantiation guidance to ensure nobody can poke holes in your labels. Additionally, our Branding, Strategy, and Marketing (BSM2) practice, led by Michael Johnson, can help you build your brand with the right pet owners, in the right retail channels, and with the right messages.
In a market where trust is currency, the rollback of formal organic standards for pet food creates more questions than it answers. Will your brand be seen as an organic leader that upholds integrity, or will it be lost in the fog of vague claims and fractured credibility? The future of organic pet food depends on our ability to bake trust into the claim, and without a clear set of standards to level the playing field for certifiers and producers, brands must lead the charge with transparency, credibility, and consumer education. If we fail, the organic label won't disappear overnight—it will simply fade into irrelevance.
About the Author
Jordan Tyler is the Director of Media at BSM Partners and co-host of the Barking Mad podcast. She has more than five years of experience reporting on trends, best practices and developments in the North American pet nutrition industry. Jordan resides in Bentonville, Arkansas, with her husband and their four furry family members.
By Jordan Tyler
Source: BSM Partners
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Market Information
01/07/2025