The PURR Act of 2025 would create a single, nationwide federal framework for regulating companion animal pet food (dog and cat food) under the Food and Drug Administration (FDA), specifically its Center for Veterinary Medicine (CVM). It would add a new section (Section 425) to the Federal Food, Drug, and Cosmetic Act (FD&C Act) that defines key terms, sets rules for ingredient submissions and approval timelines, prescribes how ingredients must be listed on labels, and allows certain marketing claims with FDA pre-approval. Importantly, it would preempt most state authority over pet food labeling and advertising, moving regulation to a uniform federal standard. The bill also requires FDA to issue guidance on technical topics, directs the CVM to take on primary regulatory responsibilities, and obliges the agency to propose and finalize regulations within specified timeframes, using model regulations from the Association of American Feed Control Officials (AAFCO) as a baseline. Overall, the act aims to streamline and standardize how pet food is labeled, what claims can be made, how ingredients are reviewed (including GRAS ingredients), and how quickly new ingredients can be reviewed, with the goal of improving consistency, safety, nutrition, and marketplace certainty for pet owners, manufacturers, veterinarians, and regulators.
Key Points
- 1Preemption and uniform national regulation
- 2- States would be prohibited from directly regulating pet food labels, labeling, and advertising, creating a single federal standard (with limited exceptions for certain safety, outbreak investigations, and consumer complaint work under existing FDA authority).
- 3New federal framework for pet food
- 4- Adds a dedicated PET FOOD section (Sec. 425) to define “companion animal,” “pet food,” “pet food ingredient,” and related terms; establishes rules for how pet food ingredients and GRAS ingredients are treated and reviewed.
- 5GRAS ingredients and approval timelines
- 6- Ingredients used in pet food that are not expressly approved as a food additive or color additive would be deemed GRAS if they appear in the 2024 AAFCO Official Publication and FDA has not found otherwise. Pet food manufacturers may voluntarily notify FDA of GRAS ingredients not previously recognized.
- 7- The FDA must issue an action letter within 90 days of receiving a pet food ingredient submission, either approving the submission or identifying deficiencies and required actions.
- 8Ingredient labeling and permissible claims
- 9- Ingredient lists must be in descending order of weight. A 2% (or smaller) ingredient may be listed at the end with a qualifying statement (e.g., “contains 2% or less of…”).
- 10- Certain marketing claims would be permitted if truthful, not misleading, and adequately substantiated, subject to FDA premarket approval. Examples include hairball control, tartar control, urinary tract health, and “human grade” claims under strict conditions (including facility registration as a human food facility and clear labeling).
- 11- Restrictions and detailed definitions apply to “natural” claims, including specific disclosures if synthetic nutrients are used.
- 12Guidance and regulatory timelines
- 13- The Secretary (HHS/FDA) must issue guidance on key pet food topics (nutritional adequacy substantiation, energy protocols, testing, and specific additives) and must issue initial guidance within 18 months of enactment, basing it on the 2024 AAFCO guidance.
- 14- Regulations to implement these changes must be proposed within 1 year and finalized within 2 years, with initial regulations incorporating 12 model PF (Pet Food) regulations from the 2024 AAFCO publication.
- 15Agency responsibilities and oversight
- 16- The Secretary would delegate responsibility for pet food regulation to the FDA’s CVM Director, who would handle science-based review of ingredient submissions, annual performance reporting to Congress, education and communication with stakeholders, and related research to support policy decisions.