Interim Report of the 

National Organic Program 

ORGANIC PET FOOD TASK FORCE 

April 7, 2006 

Recommendations for Regulatory Change 

7 CFR Part 205 
Members of the Organic Pet Food Task Force 

Nancy K. Cook: TF Chair 

Pet Food Institute 

Washington, DC 

Emily Brown Rosen: TF Secretary 

Organic Research Associates 

Titusville, New Jersey 

Brian Connolly 

Pet Appeal, Inc 

Clackamas, Oregon 

E. Rod Crossley 

Crossley Consulting 

Montrose, California 

 

Rochelle A. Lavens 

Heidi's Homemade, Inc. 

Columbus, Ohio 

Robert S. Lepp 

The Meow Mix Company 

Secaucus, NJ 

Lois Luthy 

C.J. Foods Inc. 

Pawnee City, Nebraska 

Gerald G. May 

The IAMS Company 

Dayton, Ohio 

Edward Moser, DVM 

Companion Animal Nutrition 

Sellinsgrove, Pennsylvania 

Dr. Rodney J. Noel, for 

The Association of American Feed 

Control Officials 

West Lafayette, Indiana

Sharon Sherman 

Pet Guard, Inc. 

Green Cove Springs, Florida 

Anthony Zolezzi 

Natural Pet Nutrition Inc. 

Long Beach, California 

 

Special thanks to: 

Dr. William J. Burkholder, FDA Center for Veterinary Medicine 

Keith Jones, National Organic Program 

Valerie Frances, National Organic Standards Board 

Kevin O’Rell, National Organic Standard Board 

Julie Weisman, National Organic Standard Board 

Jim Riddle, National Organic Standard Board 
Executive Summary 

Background 

The National Organic Standards Board recommended in October 2004 that a Task Force be formed to 

develop labeling standards for organic pet food. A Federal Register notice was posted on January 24, 

2005 to solicit nominations, and the Pet Food Task Force was selected by NOP in May 2005. The Task 

Force includes individuals experienced in organic and conventional pet food manufacture, consultants 

with organic expertise, as well as state and federal regulatory authorities. The NOP has acknowledged 

in the Federal Register notice that pet food is “unregulated” by NOP regulations, but that further 

consultation with the pet food industry and NOSB was needed to craft specific regulations for organic 

pet food. The NOSB noted that the existing organic livestock regulations may not be suitable for pet 

food application, as they restrict the use of mammalian products fed to mammals, and do not allow a 

“Made with Organic” label claim. The existing human food processing standards do not allow for use 

of natural feed additives and processing aids that are allowed in livestock feed. 

In establishing the regulatory objectives for the Pet Food Task Force, the NOSB specifically asked the 

Task Force to: 

• Determine which aspects of the existing regulation pertain to pet foods; 

• If needed, draft amendments to the regulation for consideration by the full board; and 

• Identify substances used by pet food manufacturers to be petitioned for possible addition to 

the National List.1

The organic Pet Food Task Force (PFTF) decided that the primary tasks should be undertaken in two 

phases: 

1) Propose changes in the organic regulations to support labeling of organic pet food, and 

2) Evaluate where any conflicts may exist between organic labeling claims and the existing state 

requirements for pet food labeling, and propose remedies in collaboration with state officials. 

At the present time, the PFTF has completed a draft proposal for organic regulation changes for public 

and NOSB consideration. The PFTF will continue to work further on evaluating any conflicts with 

state requirements, as embodied in the Association of American Feed Control Officials (AAFCO) 

model Pet and Specialty Pet Food regulations. Organic pet food manufacturers will have to comply 

with both the NOP regulations and existing state pet food regulations, so the goal will be to reconcile 

any conflicts and propose guidance for the AAFCO officials in interpreting organic claims. 

Highlights of the Proposed Rule Changes 

In general, the PFTF finds that pet food regulations are a better fit under the livestock section of the 

organic rules. Pet food is currently regulated by states as a subset of livestock regulations. Ingredients 

and additives permitted in pet food are regulated similarly to livestock feed. We have recommended 

that the product composition requirements for organic pet food be similar to those for livestock, but 

that labeling categories be the same as for processed human food. There was strong agreement by the 

PFTF that the eligible label claims for organic pet food match the requirements for human food: i.e. a 

minimum of 70% organic ingredients for a “made with organic” claim, and at least 95% organic 

content for an “organic” claim. 

 1

 Recommendation on “National Organic Program Scope”, adopted by NOSB, as revised Oct.13, 2004 

Initial Report, Organic Pet Food Task Force April 7, 2006 Page 3 of 11

 
Definitions: We have proposed a number of new definitions that are based on existing AAFCO 

definitions for pets, and specialty pets. It is important to know that the definitions of “pets” and 

“specialty pets” do not include horses, llamas, alpacas, rabbits, or wild birds. Feed for such animals 

must meet the NOP livestock feed standard in order to carry an organic claim. Please also note that, for 

the purposes of this regulation unless specifically noted, the term “pet food” will include both pet and 

specialty pet food. 

We have also proposed some definitions for slaughter products and various types of meat feed 

ingredients. This will aid in further discussions about suitability of slaughter products and by-products 

in pet food. 

Slaughter products: We have clarified that prohibition for feeding mammalian and poultry slaughter 

by-products to animals applies only to livestock, but not to pets. We would like to solicit further 

comments on the proposed changes to 205.237. 

These proposed changes allow non-organic meat and meat products in the non-organic fraction of an 

“organic” (95%) or “made with organic” (70%) product. This will address the pet food manufacturers’ 

concern that lack of organic animal protein sources would limit their ability to formulate products. 

We did include a requirement that organic and non-organic sources for the same ingredient cannot be 

included in the same product. This will prevent a product with organic meat from also including the 

same type of non-organic meat. Identification of specific types of meat ingredients should be based on 

standardized AAFCO feed ingredient definitions. It would be possible to have organic beef and nonorganic chicken in the same product, or organic chicken and non-organic chicken meal in the same

“made with organic” product, so long as both are correctly identified in the product’s ingredient 

statement. 

Description of product composition requirements: 

• Products labeled “100% Organic” – must have 100% organic ingredients and additives, 

including processing aids. 

• Products labeled “Organic” – must have 95% organic agricultural ingredients, and the 

remainder may be nonsynthetic substances or synthetic substances on the National List at 

205.603 (substances allowed for livestock) or 205.605 (nonsynthetic or synthetic 

substances approved for food use, provided they are also FDA approved for livestock). 

• Products labeled “Made with organic” – must have 70% organic agricultural ingredients, 

and the remainder may be non-organic agricultural ingredients, nonsynthetic substances or 

synthetic substances on the National List at 205.603 or 205.605. 

• All products labeled as “Organic” or “Made with Organic Ingredients” can not include 

ingredients that are genetically engineered (produced using “excluded methods”), be 

produced using sludge or irradiation, synthetic substances not on the National List, contain 

sulfites, nitrates or nitrites, or include organic and non-organic forms of the same

ingredients. Products labeled “organic” cannot contain non-organic ingredients when 

organic sources are available. 

The intent of this proposed regulation is to create a pet food label that is consistent with labeling for 

human food. We recognize that these requirements will present challenges for pet food manufacturers, 

especially sourcing non-genetically engineered ingredients in the non-organic fraction of the products. 

Initial Report, Organic Pet Food Task Force April 7, 2006 Page 4 of 11

 
We have also provided an appendix with a list of substances that manufacturers believe may need 

inclusion on the National List specifically for pet or specialty pet food, subject to the existing petition 

process for adding substances. 

Additional comments are provided in footnotes to the proposed regulatory changes. 

Initial Report, Organic Pet Food Task Force April 7, 2006 Page 5 of 11

 
Proposed Changes in 7 CFR Part 205 to include Organic Pet Food 

Suggested additions to 7 CFR Part 205 are included in underline format. Deletions are marked in 

strikethrough format. 

Subpart A Definitions: 

205.2 Terms defined 

Agricultural product. Any agricultural commodity or product, whether raw or processed, 

including any commodity or product derived from livestock, that is marketed in the United 

States for human, pet, specialty pet or livestock consumption.2

Livestock. Any cattle, sheep, goat, swine, poultry, or equine animals used for food or in the production 

of food, fiber, feed, or other agricultural-based consumer products; wild or domesticated game; or other 

nonplant life, except such term shall not include pets or specialty pets. aquatic animals or bees for the 

production of food, fiber, feed, or other agricultural-based consumer products.”3

Meat (feed ingredient) is clean flesh derived from slaughtered mammals and limited to that part of the 

striate muscle which is skeletal or that which is found in the tongue, in the diaphragm, in the heart, or in 

the esophagus; with or without the accompanying overlying fat and the portions of the skin, sinew, 

nerve, and blood vessels which normally accompany the flesh.4

Pet - dog or cat

Pet food - any commercial feed prepared and distributed for consumption by dogs or cats.

For the purposes of this regulation unless specifically noted the term “pet food” will include 

both pet and specialty pet food.

Poultry (feed ingredient) – is the clean combination of flesh and skin with or without 

accompanying bone, derived from the parts or whole carcasses of poultry or a combination 

thereof, exclusive of feathers, heads, feet and entrails.5 

Slaughter by-products are all parts of the animal or poultry produced at slaughter, such as, but 

not limited to organs, blood, plasma, etc. but does not include meat from animals, poultry, or 

fish, milk or milk products.6

Specialty pet- any domesticated animal normally maintained in a cage or tank, such as, but not 

limited to, gerbils, hamsters, canaries, psittacine birds, mynahs, finches, tropical fish, goldfish, 

snakes, and turtles.

Specialty Pet food: any commercial feed prepared and distributed for consumption by 

specialty pets: which includes any domesticated animal normally maintained in a cage or tank, 

such as, but not limited to, gerbils, hamsters, canaries, psittacine birds, mynahs, finches, 

 2

 This addition was necessary due to many other references in the rule to “agricultural product.” 

3

 We have proposed removing the reference to aquatic animals to be consistent with the recommendation of the 

Aquaculture Task Force. 

4

 AAFCO 2005 Official Publication, Feed ingredient definition 9.2 

5

 AAFCO 2005 Official Publication, Feed ingredient definition 9.57 

6

 AAFCO, 2005, sections 9 and 54 of Feed ingredient definitions. 

Initial Report, Organic Pet Food Task Force April 7, 2006 Page 6 of 11

 
tropical fish, goldfish, snakes and turtles. For the purposes of this regulation unless specifically 

noted the term “pet food” will include both pet and specialty pet food.

Subpart B Applicability: 

§ 205.100 What has to be certified.

(a) Except for operations exempt or excluded in § 205.101, each production or handling 

operation or specified portion of a production or handling operation that produces or 

handles crops, livestock, livestock products, pet food or other agricultural products that are 

intended to be sold, labeled, or represented as "100 percent organic," "organic," or "made 

with organic (specified ingredients or food group(s))" must be certified according to the 

provisions of subpart E of this part and must meet all other applicable requirements of this 

part. 

§205.105 Allowed and prohibited substance, method, and ingredients in organic 

production and handling. 

To be sold or labeled as "100 percent organic," "organic," or "made with organic (specified 

ingredients or food group(s))," the product must be produced and handled without the use 

of: 

(a) Synthetic substances and ingredients, except as provided in § 205.601 or § 205.603; 

(b) Nonsynthetic substances prohibited in § 205.602 or § 205.604; 

(c) Nonagricultural substances used in or on processed products, except as otherwise provided 

in § 205.605; 

(d) Nonorganic agricultural substances used in or on processed products, except as otherwise 

provided in § 205.606; 

(e) Synthetic substances and ingredients used in or on pet food, except as provided in §205.603, 

or §205.605; 7

(e f) Excluded methods, except for vaccines, Provided, That, the vaccines are approved in 

accordance with § 205.600(a); 

(f g) Ionizing radiation, as described in Food and Drug Administration regulation, 21 CFR 

179.26 and 21 CFR 579; 8

(g h) Sewage sludge. 

Subpart C Organic Production and Handling Requirements: 

§ 205.237 Livestock feed and pet food.

(a) The producer of an organic livestock operation must provide livestock with a total feed 

ration composed of agricultural products, including pasture and forage, that are organically 

produced and, if applicable, organically handled: Except, That, nonsynthetic substances and 

synthetic substances allowed under § 205.603 may be used as feed additives and supplements. 

(b) The producer of an organic livestock operation must not: 

(1) Use animal drugs, including hormones, to promote growth; 

(2) Provide feed supplements or additives in amounts above those needed for adequate 

nutrition and health maintenance for the species at its specific stage of life; 

 7

 This means that synthetic substances approved for use either in human food processing or for livestock use 

may be used in pet food formulations as feed additives or supplements, must also be FDA approved for this use, 

see new 205.237(c). 

8

 21 CFR 179.26 applies specifically to production, processing and handling of food. 21 CFR 579 is the 

appropriate reference for irradiation applied to livestock feed and pet food. 

Initial Report, Organic Pet Food Task Force April 7, 2006 Page 7 of 11

 
(3) Feed plastic pellets for roughage; 

(4) Feed formulas containing urea or manure; 

(5) Feed mammalian or poultry slaughter by-products to mammals or poultry; or 

(6) Use feed, feed additives, and feed supplements in violation of the Federal Food, Drug, 

and Cosmetic Act. 

(c) Pet food must be composed of agricultural products that are organically produced and, if 

applicable, organically handled: Except that, nonsynthetic substances, and synthetic 

substances allowed under §205.603, and 205.605 provided they are allowed by FDA in 

animal feed, may be used as feed additives and supplements. 

Subpart D Labels, Labeling and Market information: 

§ 205.300 Use of the term, “organic.” 

(a) The term, “organic,” may only be used on labels and in labeling of raw or processed 

agricultural products, including ingredients, that have been produced and handled in 

accordance with the regulations in this part. The term, “organic,” may not be used in a product 

name to modify a nonorganic ingredient in the product. 

(b) Products for export, produced and certified to foreign national organic standards or foreign 

contract buyer requirements, may be labeled in accordance with the organic labeling 

requirements of the receiving country or contract buyer: Provided, That, the shipping 

containers and shipping documents meet the labeling requirements specified in § 205.307(c). 

(c) Products produced in a foreign country and exported for sale in the United States must be 

certified pursuant to subpart E of this part and labeled pursuant to this subpart D. 

(d) Livestock feeds produced in accordance with the requirements of this part must be labeled 

in accordance with the requirements of § 205.306. 

(e) Pet foods produced in accordance with the requirements in this part must be labeled in 

accordance with the requirements of subpart D, except for section 205.306. Pet food must be 

composed in accordance with the requirements of 205.301(g) and must be labeled in 

accordance with state and federal regulations.9

§ 205.301 Product Composition 

(f) All products labeled as "100 percent organic" or "organic" and all ingredients identified as 

"organic" in the ingredient statement of any product must not: 

(1) Be produced using excluded methods, pursuant to § 201.105(e); 

(2) Be produced using sewage sludge, pursuant to § 201.105(f); 

(3) Be processed using ionizing radiation, pursuant to § 201.105(g); 

(4) Be processed using processing aids not approved on the National List of Allowed and 

Prohibited Substances in subpart G of this part: Except, That, products labeled as "100 

percent organic," if processed, must be processed using organically produced processing 

aids. 

(5) Contain sulfites, nitrates, or nitrites added during the production or handling process, 

Except, That, wine containing added sulfites may be labeled "made with organic grapes"; 

(6) Be produced using nonorganic ingredients when organic ingredients are available; or 

(7) Include organic and nonorganic forms of the same ingredient. 

 9

 This change means that almost all of subpart D, except for the section specific to livestock feed labeling will 

apply to pet food. Pet food will be composed according to the new section 205.301(g), rather than the current 

205.301 (a-f). 

Initial Report, Organic Pet Food Task Force April 7, 2006 Page 8 of 11

 
(g) Pet Food 

1. Products sold, labeled, or represented as "100 percent organic.” A raw or processed 

agricultural product sold, labeled, or represented as "100 percent organic" must contain 

(by weight or fluid volume, excluding water and salt) 100 percent organically produced 

ingredients. If labeled as organically produced, such product must be labeled pursuant 

to § 205.303. No products may be produced using prohibited practices or substances 

specified in §205.301(f).

2. Products sold, labeled, or represented as "organic.” A raw or processed agricultural 

product sold, labeled, or represented as "organic" must contain (by weight or fluid 

volume, excluding water and salt) not less than 95 percent organically produced raw or 

processed agricultural ingredients products.

10 Any remaining product ingredients or 

processing aids must be organically produced, unless not commercially available in 

organic form, or must be nonsynthetic substances or synthetic substances in accordance 

with 205.237(c). No products may be produced using prohibited practices or substances 

specified in §205.301(f), except that nonsynthetic processing aids may be used. If 

labeled as organically produced, such product must be labeled pursuant to § 205.303. 

3. Products sold, labeled, or represented as "made with organic (specified ingredients or 

food group(s))." Multiingredient agricultural product sold, labeled, or represented as 

"made with organic (specified ingredients or food group(s))" must contain (by weight or 

fluid volume, excluding water and salt) at least 70 percent organically produced 

ingredients which are produced and handled pursuant to requirements in subpart C of 

this part. Nonorganic ingredients must be in accordance with 205.237(c). No products 

may be produced using prohibited practices specified in paragraphs (1), (2), (3), (5), 

and (7) of § 205.301(f). If labeled as containing organically produced ingredients or 

food groups, such product must be labeled pursuant to § 205.304.

11 

4. Products with less than 70 percent organically produced ingredients. The organic 

ingredients in multiingredient agricultural product containing less than 70 percent 

organically produced ingredients (by weight or fluid volume, excluding water and salt) 

must be produced and handled pursuant to requirements in subpart C of this part. The 

nonorganic ingredients may be produced and handled without regard to the 

requirements of this part. Multiingredient agricultural products containing less than 70 

percent organically produced ingredients may represent the organic nature of the 

product only as provided in § 205.305. 

 10 Product labeled “organic” may contain multiple organic agricultural ingredients. 

11 We have included the requirement from 205.301(f) that organic and non-organic forms of the same ingredient 

are not permitted in a “Made with Organic” claim. This is an effort to prevent a misleading label claim; such as 

a product that claims it is “made with organic chicken” that might have 5% organic chicken and 25% nonorganic chicken, as well as 65% other organic ingredients. A “made with organic” product could have organic 

chicken, as well as non-organic chicken meal however, as these are two distinct ingredients according to 

AAFCO definition. Although there is some uncertainty in the industry if organic and non-organic forms of the 

same ingredient are prohibited in a “Made with Organic” claim for human food, NOP has stated it concurs that 

this is the correct interpretation. NOSB has recommended this clarification; see “Final Recommendation for 

Rule Change Concerning Made with Organic Ingredients”, March 18, 2005. This pet food requirement should 

be made in concert with change to the requirements for human food. 

Initial Report, Organic Pet Food Task Force April 7, 2006 Page 9 of 11

 
Subpart G Administrative: 

§205.600 Evaluation criteria for allowed and prohibited substances, methods, and 

ingredients. 

The following criteria will be utilized in the evaluation of substances or ingredients for the 

organic production and handling sections of the National List: 

(a) Synthetic and nonsynthetic substances considered for inclusion on or deletion from the 

National List of allowed and prohibited substances will be evaluated using the criteria 

specified in the Act (7 U.S.C. 6517 and 6518). 

(b) In addition to the criteria set forth in the Act, any synthetic substance used as a 

processing aid or adjuvant will be evaluated against the following criteria: ...... 

(c) In addition to criteria set forth in the Act, any synthetic nutrient used in pet food should 

be considered in accordance with need established as requirements under FDA or in 

AAFCO Nutrient Profiles. 12

§205.603 Synthetic substances allowed for use in organic livestock and pet food

production. 

In accordance with restrictions specified in this section, the following synthetic substances may 

be used in organic livestock production, and for organic pet food production, as applicable. 

(c) As livestock feed supplements—Milk replacers—without antibiotics, as emergency use 

only, no nonmilk products or products from BST treated animals. 

(d) As feed supplements for pet food (reserved) 

(d e) As feed additives. 

(1) DL-Methionine, DL-Methionine—hydroxy analog, and DL-Methionine—hydroxy analog 

calcium—for use only in organic poultry production until October 21, 2008. 

(2) Trace minerals, used for enrichment or fortification when FDA approved. 

(3) Vitamins, used for enrichment or fortification when FDA approved. 

(4) Other nutrients for use in pet foods: (reserved)

§ 205.604 Nonsynthetic substances prohibited for use in organic livestock and pet food

production.

The following nonsynthetic substances may not be used in organic livestock production: 

(a) Strychnine 

 (b)-(z) [Reserved] 

 

12 Determinations of necessity of a nutrient in a specific pet food diet can be justified by the requirements as 

established under FDA regulations or by the Dog and Cat Food Nutrient Profiles, as referenced in the most 

current AAFCO Official Publication. See www.aafco.org for ordering information. The other OFPA criteria at 

6518(m) would also apply (lack of organic alternatives, toxicity, environmental contamination, etc.) 

Initial Report, Organic Pet Food Task Force April 7, 2006 Page 10 of 11

 
Appendix 

Materials for possible petition to the National List for use in Pet Food 

205.603(d) Feed additives 

l-arginine - for pet food (amino acid) 

d-l Methionine for pet food (amino acid) 

Carnitine for pet food (amino acid) 

l-cysteine for pet food (amino acid) 

l-lysine, l-lysine monochloride for pet food (amino acids) 

Taurine for pet food (amino acid) 

l-tryptophan for pet food (amino acid) 

Phosphoric acid – used as acidifier for pet food, and for metabolic purposes for cats (already 

approved as mineral source) 

Tocopherols – for pet food (Vitamin E) derived from vegetable sources 

205.604 Non-synthetic substances – prohibited for use in organic livestock and pet food production.

Propionic acid – prohibited except as preservative in pet food (and possibly livestock feed) 

Sorbic acid – prohibited except as preservative in pet food (and possibly livestock feed) 

205.605(b) 

Magnesium stearate – add pet food to the annotation - for use only in pet foods labeled "made 

with organic (specified ingredients or food group(s))," prohibited in pet foods labeled 

"organic," 

Potassium iodide – add pet food to the annotation: for use only in pet foods labeled "made with 

organic (specified ingredients or food group(s))," prohibited in pet foods labeled "organic." 

Initial Report, Organic Pet Food Task Force April 7, 2006 Page 11 of 11