WHNN Atlanta, Georgia
The Kennel

It Cannot Be Bigger Than “Dog Food”

"Human grade" is a defined term with a size limit, a facility requirement, and an all-or-nothing rule. Most people reading it on a bag know none of that.

By D. Jackson II  · 

Start with the smallest rule, because it is the one nobody expects.

If a pet food label carries the words human grade, those words cannot appear anywhere on that label in type larger than the statement of intended use — the words dog food or for cats that the regulations already require.

The claim is not allowed to be the biggest thing on the package. That limit exists because the term is a qualifier, not a product name, and regulators decided the label should read that way.

It is a defined term, not a description

"Human grade" is a feed term with a definition. Under the AAFCO standard, every ingredient and the resulting product must be stored, handled, processed and transported in a manner consistent and compliant with 21 CFR Part 117 — the FDA's current good manufacturing practice and preventive controls regulation for human food — and with applicable federal human food laws as required by the ingredient, the process, or the facility type.

That is a manufacturing standard. It describes a building and a process, not an ingredient list.

All or nothing

The term is acceptable only in reference to the product as a whole.

A manufacturer cannot claim human grade ingredients in a product that is not itself human grade. If the finished food is not human edible, the claim is false and misleading — including a claim made about individual ingredients inside it.

This is the rule that does the most work and gets ignored the most often. "Made with human grade chicken" in a food that is not itself human grade is not a partial version of the claim. Under the standard it is a violation of it.

The facility requirement

The claim is voluntary. Nothing requires a company to make it.

But a company that does make it takes on a facility obligation: the facilities involved in producing a human grade pet food must be registered as both an FDA food facility and an FDA feed facility. A plant registered only as a feed facility cannot produce a product carrying the claim, whatever is going into it.

That single requirement is why the term is uncommon rather than universal. It is a question of where the food is made, not of how good the ingredients are.

What has to be on file

A firm making the claim has to maintain documentation and make it available on request. It has to be able to show that every individual ingredient supplied to the manufacturer and used in the product is fit for human consumption, and that ingredients and finished product are stored and handled under human food controls.

It also has to maintain written procedures for proper handling of the product through the distribution channel — which extends the obligation past the plant door.

AAFCO encourages states to accept a USDA Agricultural Marketing Service Process Verified Program certificate as validation. It also advises manufacturers to contact the feed control officials in each state they intend to distribute into, because the appropriate course of action varies by state.

The thing underneath all of it

USDA inspects meat and poultry intended for human consumption continuously. It does not inspect pet food to that standard.

That asymmetry is the entire reason a term like this exists. Human food and animal food run on separate regulatory tracks with separate facility requirements, and "human grade" is the mechanism by which a product asserts it was made on the first track rather than the second.

It is a statement about which system a food passed through. Read that way, the size limit on the label makes more sense: it is a qualifier about process, and the regulations do not want it operating as a headline.

Where to actually look it up

The AAFCO Pet Food and Specialty Pet Food Labeling Guide covers this claim alongside natural, organic and tartar control claims, and has been updated with the model regulations from the Pet Food Label Modernization project. It is the document state feed control officials and industry both work from.

It is not free — AAFCO sells it, and the Official Publication is copyrighted — which is worth knowing before assuming the rules are a search away.

Standard and documentation requirements as published by AAFCO in its human grade claim guidance and labeling guide, and as summarized by the American Pet Products Association. AAFCO writes model regulations; states adopt and enforce them, and requirements vary by state.