What GRAS Means For Pet Foods in the United States

What GRAS Means For Pet Foods in the United States

May 29, 2026 By

Pet food innovation is moving quickly across the United States. From novel proteins and functional ingredients to fermentation-derived compounds and upcycled materials, manufacturers are continuing to develop increasingly sophisticated products for companion animals.

But innovation in pet food comes with regulatory considerations.

In the U.S., ingredients intended for use in animal food — including pet food — must fit within FDA’s regulatory framework. One of the most important concepts in that framework is GRAS, or Generally Recognized as Safe.

As innovation in animal nutrition accelerates, understanding how GRAS applies to pet food ingredients is becoming increasingly important for manufacturers entering the U.S. market.

What is GRAS?

Under the Federal Food, Drug, and Cosmetic Act (FD&C Act), substances intentionally added to food for humans or animals are generally considered food additives unless an exemption applies. One of the primary exemptions is GRAS status.

In simple terms, a substance may be considered GRAS when qualified experts generally recognize it as safe under its intended conditions of use.

For pet food ingredients, this is an important distinction because GRAS status is not universal. It applies to:

  • A specific ingredient
  • A specific manufacturing process
  • Specific conditions of use
  • Specific inclusion levels
  • Specific animal species

An ingredient considered acceptable in one application is not automatically acceptable across all animal food uses. The regulatory assessment often depends heavily on the ingredient’s composition, intended use, manufacturing process, and target species.

Why GRAS matters in pet food

The modern pet food market extends far beyond traditional feed ingredients.

Today’s products increasingly incorporate:

  • Functional ingredients
  • Novel proteins
  • Mushroom ingredients
  • Specialty oils
  • Fermentation-derived materials
  • Probiotics and postbiotics
  • Botanical ingredients
  • Upcycled food processing byproducts

As these ingredients become more specialized, companies often require stronger scientific and regulatory substantiation to support commercialization in the U.S. market.

Many ingredients originally developed for dietary supplements, food and beverage applications, or biotechnology platforms for humans, may require additional evaluation before they can be used in pet food.

In many cases, GRAS becomes one of the clearest pathways for supporting the lawful use of an ingredient in animal food.

GRAS vs. Food Additive Petitions

For animal food ingredients in the United States, there are generally two primary FDA-recognized regulatory pathways:

  • GRAS determinations
  • Food Additive Petitions (FAPs)

The GRAS pathway is commonly used when sufficient scientific evidence exists to support safety under the intended conditions of use.

Food Additive Petitions are more formal FDA approval processes generally used when an ingredient does not meet GRAS criteria or when additional regulatory authorization is needed.

The appropriate pathway often depends on the ingredient itself, the intended species, available safety data, and the proposed conditions of use.

The changing regulatory landscape for pet food ingredients

Historically, many animal food ingredients entered the U.S. market through the Association of American Feed Control Officials (AAFCO) Ingredient Definition process. These ingredients would then be listed in chapter 6 of AAFCO’s Official Publication, following which they were generally considered acceptable by states for use in pet food.

However, the regulatory landscape changed significantly following the expiration of the Memorandum of Understanding (MOU) between AAFCO and FDA in October 2024.

As a result:

  • New ingredients may no longer be able to rely solely on the traditional AAFCO Ingredient Definition pathway
  • FDA-recognized GRAS and Food Additive Petition pathways have become increasingly important
  • FDA introduced the interim Animal Food Ingredient Consultation (AFIC) process, as a scientific consultation procedure to help inform companies of a suitable regulatory strategy
  • Manufacturers are placing greater emphasis on scientific substantiation and regulatory planning

FDA has stated that ingredients intended for animal food generally must either:

  • Be approved through a Food Additive Petition, or
  • Be GRAS for the intended use in animal food

This shift has created a more structured regulatory environment for companies developing innovative pet food ingredients.

What does a GRAS evaluation involve?

Establishing GRAS status for a pet food ingredient typically involves a detailed scientific and regulatory review.

This may include evaluation of:

  • Ingredient identity and composition
  • Manufacturing methods
  • Specifications and contaminant controls
  • Intended species
  • Intended use levels
  • Dietary exposure estimates
  • Published Toxicological information (typically species-specific)
  • Nutritional considerations
  • Historical food or feed use

FDA’s GRAS framework also emphasizes that the safety conclusion should be generally recognized among qualified experts and supported by publicly available scientific information.

For novel ingredients, this can require significant scientific and regulatory substantiation before commercialization.

Self-affirmed GRAS vs. FDA-notified GRAS

Companies pursuing a GRAS pathway for pet food ingredients may choose between:

  • Self-affirmed GRAS conclusions
  • FDA-notified GRAS submissions

With a self-affirmed GRAS conclusion, the company independently determines that the ingredient is GRAS based on the available evidence and commissions review of this conclusion by an independent and qualified expert panel.

Alternatively, companies may voluntarily submit a GRAS notice to FDA’s Center for Veterinary Medicine (CVM). FDA may then respond with a “no questions” letter if it does not object to the notifier’s conclusion.

While FDA notification is currently voluntary, many manufacturers pursue it to provide additional transparency and commercial confidence.

Why early regulatory strategy matters

One of the biggest challenges in pet food innovation is that regulatory considerations are often addressed late in development.

Since an ingredient’s regulatory pathway may depend on:

  • Manufacturing processes
  • Degree of processing or chemical alteration
  • Intended species
  • Inclusion levels
  • Existing scientific literature
  • Comparable regulatory precedents

Evaluating regulatory positioning early can help identify potential data gaps/concerns, reduce delays, and support long-term commercialization planning.

How dicentra can help

dicentra supports companies developing pet food ingredients, feed additives, and novel animal nutrition products for the U.S. market.

Our services include:

Whether your ingredient is a novel protein, functional additive, fermentation-derived ingredient, or upcycled material, our team can help assess the appropriate regulatory pathway and support your commercialization goals.

If your company is developing a pet food ingredient or animal feed additive for the U.S. market, reach out to us to discuss your GRAS strategy, regulatory considerations, and animal food compliance requirements.

Talk to our team about your GRAS strategy for Pet Food →