NGFA Submits Comments to FDA on Policies Regulating Animal Food

According to NGFA, in comments submitted to the U.S. Food and Drug Administration (FDA) on Nov. 17, NGFA recommended that the agency modernize its existing policies so that animal foods with demonstrated production, health and environmental benefits can be brought to market in a more efficient manner.

NGFA submitted its statement in response to the Center for Veterinary Medicine’s (CVM) request for comment on how the Policy and Procedures Manual (PPM) 1240.3605, Regulating Animal Foods with Drug Claims, could be updated to reflect evolving scientific knowledge and promote innovation.

Based on the current PPM, FDA traditionally has reserved claims for improving animal production (production claims), such as increased milk production, increased leanness, and improved growth and efficiency of gain, to animal drugs. FDA requires such animal foods with production claims to gain premarket approval through its animal drug approval process, a process that is very complex, time-consuming and expensive.

In comments submitted to the agency, NGFA stated that the current statutory definitions of “food” and “drug” provide FDA with the regulatory flexibility to modify its current policy and allow animal food with claims related to environmental benefits, production efficiency, modifying the digestive tract, and changes to the microbiome to be classified as animal food, rather than animal drugs.

Animal food manufacturers can use existing animal food review pathways to demonstrate the safety of products and substantiate truthful production and environmental claims, NGFA noted.

“Providing a more efficient regulatory framework to bring these products to market with such claims will benefit the well-being of animals, farmers and ranchers, consumers and the public at large,” NGFA said during a listening session conducted by FDA on Oct. 18.

“FDA’s characterization of these products as animal food will allow new technologies and innovation to reach the market sooner, resulting in increased efficiencies within U.S. animal agriculture, enhanced safety of animal-derived foods, and reduced greenhouse gas emissions and other environmental benefits.”