The US Food and Drug Administration (FDA) is proposing an update to its GRAS (Generally Recognized as Safe) food regulations. This follows media reports about how new ingredients are getting into human foods without any review or oversight by FDA. (See this article on Self-Affirmed GRAS for details.)
GRAS also applies to animal foods, and here’s where it matters to pet parents.
The new GRAS rule is only a proposal, which means you have an opportunity to tell FDA what you think.
Comments from regular consumers and pet parents are 100% valid and needed. Tell FDA why this matters to you and your pet. Comments in your own words are always best. But even a short comment is better than saying nothing.
I suggest making these points:
• Support FDA’s proposal to require companies to notify the agency when they determine that an ingredient is GRAS. Companies should not be able to introduce new ingredients into human or animal food under a GRAS determination without FDA or the public even knowing about it.
• Support public disclosure of GRAS notices and the scientific evidence supporting them.
• Ask FDA to make sure the new system does not create gaps in safety review for animal-food ingredients now that FDA and AAFCO no longer operate their former joint ingredient-definition process.
• Ask FDA to clarify its treatment of ingredients in the 2024 AAFCO Official Publication. If that particular edition is incorporated into federal regulations, what happens when AAFCO adds a new ingredient or changes an existing ingredient definition?
If you would rather have a paragraph to simply cut and paste, here you go:
I support FDA’s proposal to require notification of GRAS determinations. Consumers should be able to know what substances are being added to human and animal foods and what scientific evidence supports their safety. I particularly urge FDA to ensure that animal-food ingredients receive appropriate safety review following the end of FDA’s former ingredient-definition partnership with AAFCO. FDA should also clarify how it will handle additions and changes to the AAFCO Official Publication if the 2024 edition is incorporated into the regulation. The final system should provide transparency, meaningful safety oversight, and a clear regulatory pathway for new animal-food ingredients.
Submit your comment here: Regulations.gov under Docket FDA-2025-N-3262. (Click on the blue COMMENT box.) The comment deadline is December 9, 2026.