Appendix: DRAFT Guidance Document, Permitted Label Claims, Organic Pet Food Task Force Initial Report 04/07/06 

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Appendix: USDA-NOP Organic Pet Food Task Force Initial Report April 7, 2006 

DRAFT GUIDANCE DOCUMENT FOR DISCUSSION ONLY 

Examples of Labeling Terms Allowed for Pet Food 

Compliant with State Regulations and Proposed Organic Regulations 

AAFCO Model Regulations for Pet Food 

(as adopted by States) www.aafco.org

Added Organic Claims under Proposed 

Organic Regulations, Pet Food Task Force 

http://www.ams.usda.gov/nop/TaskForces/PetFood.html

 

100% rule – AAFCO PF3(a) 100% Organic, proposed 7 CFR 205.301(g)(1) 

“100% Beef Dog Food” 

• Must be 100% of one ingredient (in this 

case, beef), excl. water and trace amounts 

condiments and preservatives 

• If there are other added minerals, cannot be 

called “100% beef” 

“100% Organic Beef Dog Food” 

“100% Organic Food For Dogs” 

• If claimed, must be 100% organic beef, 

excluding water and salt. 

• A product labeled 100% organic can 

include flavorings and approved 

preservatives only if they are all from 

organic sources. 

• Cannot claim- “100% Organic Dog Food,” 

as the modifiers imply the product is 

derived from organic dogs. 

95% rule – AAFCO PF3 (b)(1) Organic- 95% 205.301(g)(2) 

“My Favorite Beef Dog Food” 

“My Favorite Beef, Turkey, and Lamb Dog 

Food” 

• Named ingredient must be from 

animals, poultry or fish 

• Ingredient or combination of named 

ingredients named must be 95% of the 

product (excluding water) in 

descending order by weight 

o At least 3% of each named 

ingredient must be in the 

product 

o The same named ingredient 

must appear in the ingredient 

deck 

• Cannot name other ingredients: “My 

Favorite Oats, Barley and Rice Cat 

Food” 

“My Favorite Organic Beef Dog Food” 

“My Favorite Organic Beef, Turkey, and Lamb 

Dog Food” 

“My Favorite Organic Food for Dogs” 

• Named ingredient must be from 

animals, or poultry (no standards yet 

for organic fish) 

• Must have 95% organic beef or 

• Must have combination totaling 95% 

organic beef, turkey, lamb –listed in 

decreasing order by weight 

o Must include at least 3% of 

each named ingredient 

o Each named ingredient must 

appear in the ingredient deck 

• 95% of ingredients must be organic, the 

other 5% must be on the National List 

at 205.605 or 205.606. 

• Cannot claim “My Favorite Chicken, 

Organic Rice and Organic Barley Dog 

Food” (all named ingredients must be 

from poultry or animals) 
Appendix: DRAFT Guidance Document, Permitted Label Claims, Organic Pet Food Task Force Initial Report 04/07/06 

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AAFCO Model Regulations for Pet Food 

(as adopted by States) www.aafco.org

Added Organic Claims under Proposed 

Organic Regulations, Pet Food Task Force 

http://www.ams.usda.gov/nop/TaskForces/PetFood.html

 

25% Rule – AAFCO PF3 (b)(2) 95% Organic with descriptor 

 “My Favorite Beef Dinner” 

 “My Favorite Tuna Platter” 

 “My Favorite Chicken Entrée” 

 “My Favorite Beef and Lamb Dinner” 

• Must be minimum 25% of named 

ingredient (excluding water) 

• Descriptor (dinner, platter, entrée, etc) 

is same size as name 

• If more than one ingredient is named, 

the total of the named ingredients must 

be 25% of product. All named 

ingredients must be a minimum of 3%, 

 e.g, “My Favorite Beef and Lamb 

Dinner”could be 22% beef and 3% 

lamb 

• The named ingredients must appear in 

order of weight 

• The same named ingredient* must 

appear in the ingredient deck. If 

“chicken” appears in product name, it 

must appear in the ingredient list, ie. 

not poultry by-products or chicken 

meal. 

* Names of ingredients must be as 

provided in approved feed ingredient 

definitions, AAFCO Official Publication 

“My Favorite Organic Beef Dinner” 

• Must be 95% organic, with minimum 

of 25 % organic chicken 

• Could have 25 % organic chicken, plus 

70% other organic grains, or organic 

meat 

• All beef (meat as defined by AAFCO at 

9.2) in ingredient list must be organic. 

[Other animal products such as liver or 

meat meal could be non-organic if not 

commercially available and listed on 

205.606, and total organic ingredients 

are 95%] 

“My Lamb and Beef Organic Dinner for Dogs” 

• Must be 95% organic 

• Must have a total of 25% organic lamb 

and organic beef, with a minimum of 

3% for any ingredient 

“My Favorite Organic Whole Grain Corn and 

Chicken Entrée” 

• Must be 95% organic. 

Could have 22% organic corn, 3% organic 

chicken, and 70% organic other ingredients. 

Cannot claim 

• “My Favorite Organic Tuna Platter” –

since there are no standards for organic 

fish under USDA at present. 

• “My Favorite Beef Organic Dinner” 

- and have 25% non-organic beef, 70% 

organic grains, 5% minerals. (does not 

meet 95% NOP organic requirement) 

“With” Rule – AAFCO PF3(c) Made with Organic 205.301(g)(3) 
Appendix: DRAFT Guidance Document, Permitted Label Claims, Organic Pet Food Task Force Initial Report 04/07/06 

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AAFCO Model Regulations for Pet Food 

(as adopted by States) www.aafco.org

Added Organic Claims under Proposed 

Organic Regulations, Pet Food Task Force 

http://www.ams.usda.gov/nop/TaskForces/PetFood.html

 

“My Favorite Dog Food with Beef” 

“My Favorite Dog Food with Beef, lamb and 

turkey” 

• must have 3% of named ingredients 

• Ingredients listed in descending order 

by weight 

“My Favorite Dog Food Made with Organic 

Chicken” 

• Must have 3% organic chicken (flesh 

and skin as per the AAFCO definition 

of poultry at 9.57) and at least 67% 

other organic ingredients 

• Could contain non-organic chicken 

meal, or non-organic chicken fat 

“My Favorite Cat Food Made with Organic 

Chicken, Rice, and Eggs” 

• Must have at least 3% organic chicken, 

3% organic rice, and 3% organic eggs; 

plus 61% other organic ingredients 

• Ingredients must be listed by name in 

descending order by weight 

Any category of pet food labels, AAFCO Multi-ingredient products containing less than 

70% organic ingredients 

• Any class of pet food could list organic 

ingredients in the ingredient listing, if 

truthful. 

• All other AAFCO requirements must 

be followed. 

“My Favorite Dog Food with Beef” 

• Must only describe organic ingredients 

in the ingredient listing, not on primary 

display panel 

• Products cannot be certified organic 

• Products cannot bear the USDA 

organic seal or certifier name. 

• Products may declare the percentage of 

organic ingredients in the ingredient 

statement. 

Questions and Answers: 

Q. Can a product be labeled “100% Organic Soy Pet Treat”? 

A. Yes, provided it is composed of 100% organic ingredients, and no claims for complete and 

balanced diet are made. 

Q. Can a product be labeled “100% Organic Sunflower, Flax, Thistle Seed for Pet Birds”? 

A. Yes this is permitted for pet birds as long as no nutritional claims are made. 

Q. Can a product be labeled “Wild Bird Food, Made with Organic Sunflower Seeds”? What 

about horse and rabbit food? 
Appendix: DRAFT Guidance Document, Permitted Label Claims, Organic Pet Food Task Force Initial Report 04/07/06 

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A. No, wild birds, horses, and rabbits are not considered specialty pets under the definition 

proposed at 205.2. Wild Bird Food, equine, llama, and rabbit foods must meet the USDA organic 

livestock feed standards, and can be formulated with 100% organic agricultural ingredients, plus 

any approved additives listed for livestock. 

Q. Can a product be labeled “100% Organic Catnip”? 

A. Yes, provided it only contains organic catnip, and makes no nutrient claims. 

Q. Why can’t I have a product labeled “My Favorite Chicken, Organic Rice and Organic 

Barley Dog Food”? 

A. The AAFCO model regulation, which is the basis for most state regulations on pet food and 

livestock feed, requires that when a pet food uses ingredients in the product name, they must be 

derived from animals, poultry or fish, to indicate a 95% claim on those ingredients, unless a 

modifier such as “entrée”, “dinner”, or “platter” is used – in which case other named ingredients 

can be specified provided there is a minimum of 25% of the named ingredients in the product. 

Q. Can pet food make an organic claim if it is not certified by a USDA accredited agency? 

A. Products that only indicate organic ingredients in the ingredient listing of the product, but not 

on the principal display panel may be marketed without certification. Products that are not certified 

cannot display the USDA organic seal, or name or seal of a certification agency. Products that 

contain less than 70% organic ingredients cannot be certified as organic, but they may list the 

organic ingredients in the ingredient listing. State officials charged with reviewing pet food labels 

under state laws may ask manufacturers to provide documentation of certification for ingredients 

described as organic when the product is not certified. 

Q. Can a company name use the word “organic” and market a product that is not certified 

organic? Example: “Betty’s Organic Lifestyle” markets a product called “Premium Natural 

Dog Food” 

A. Yes, the USDA does not regulate company names. However the USDA has stated they will 

monitor the use of the term “organic” in company names, and work with the Federal Trade 

Commission to take action against misuse of the term. 

For full details, see the Initial Pet Food Task Force Report: 

Available at http://www.ams.usda.gov/nosb/meetings/OrgPetFood.pdf

Comments welcome: send to NOSB.Processing@usda.gov