ITEM FOR PUBLIC COMMENT 

NOSB Pet Food Task Force Interim Report

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 interim report of pet food task force,

submitted April 7, 2006. 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. 

 

1

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

2004 
In the meantime, public comment on the pet food task force’s interim report is sought. 

Please submit comments by September 1, 2006. With respect to the receipt of comments, 

the following provisions have been established: 

• Mail: Persons may submit comments on the Pet Food Task Force Interim Report 

to: 

 Valerie Frances, Executive Director, 

 National Organic Standards Board (NOSB) 

 USDA-AMS-TM-NOP 

 Room 4008-South Building 

 1400 Independence Ave, SW 

 Washington, DC 20250-0001 

• E-mail: Comments may be sent via internet to: NOSB.Processing@usda.gov

• Fax: Comments may be sent via fax to (202) 205-7808 

In reviewing and commenting the Pet Food Task Force’s interim report, please consider 

and respond to the following criteria: 

1. Do the recommended standards communicate effectively? 

2. Provide clear and adequate context of scope, product coverage, and production 

systems? 

3. Identify and address key stakeholders and their concerns and challenges? 

4. Include vision and strategy for achieving consistency with organic principles 

demonstrated in the Organic Foods Production Act of 1990 and its implementing 

regulations? 

5. Present measurable objectives that are enforceable? 

6. Present a clear expectation of targets and goals? 

Clearly indicate if you are for or against the recommended standards or some part of it 

and why. Include recommended wording changes as appropriate. Include a copy of 

articles or other references that support your comments. Only relevant material should be 

submitted.