A Home-BasedPet Treat Business

What You Need To KnowConnie E. White, Compliance Officer

Office of Plant Industry Services-Agricultural Commodity Inspection

Animal Feed and Pet Food Law and Regulation

Products are regulated primarily at the state level by the Virginia Department of Agriculture and Consumer Services (VDACS), with support from FDA and USDA.

Virginia’s Commercial Feed Law [§3.2-4800 – 3.2-4817] and regulation [2 VAC 5-360-10 – 2 VAC 5-360-100] require manufacturers of commercial feed products to have an annual feed license or permit.

The law and regulation were developed to help safeguard the health of livestock and pets, protect the consumer and the industry by ensuring that approved ingredients are used in products offered for sale.

As part of our efforts to maintain uniformity, Virginia is a member of the Association of American Feed Control Officials (AAFCO), the organization that provides information on approved ingredients and guidance in developing laws and regulations regarding all animal feed products.

Home-made pet foods and treats are commercial feed products and usually classified as a small package commercial feed.

The processing of home-made treats and foods for pets does not require a kitchen or facility inspection but common sense sanitation and preparation methods should be followed.

As with any home business, all local licensing and permitting is the responsibility of the individual.

As part of our office’s efforts to ensure safe products are offered for sale, our Field Compliance Officers conduct random inspections and will remove products from the channels of trade if they find products containing unapproved ingredients or ingredients that are known to cause problems.

There is also the option for removal of products from non-licensed manufacturers or vendors.

However, the law allows 15 days for the manufacturer or vendor to obtain the feed license and any required product registrations, what we refer to as ‘voluntary compliance’.

REGISTRATIONPre-Packaged vs Bulk

Home-made pet foods and treats are considered a commercial feed product.

Several factors determine if individual products will require registration before being offered for sale in Virginia.

If your vendors offer the treats in a ‘loose’ or self-serve form, such as in different plastic containers, this is considered a bulk product.

Individual products do not need to be registered.

But, if they have their pet treats already in distinct packages (bags/boxes), they will need to register each ‘flavor’ or type of treat with VDACS and include specific information on the package label.

Product Labeling - Label Requirements

If pre-packaged, each package must have a label that includes, at a minimum:

the product name,

an ingredient statement,

a guaranteed analysis,

a net weight statement (U.S. and metric), and

the name & address of the manufacturer.

BUCKY’S BISCUIT BITSA howlin’ good treat for your best friend

LIVER & BEEF FLAVORED DOG TREATS Ingredients: Whole wheat flour, freeze dried liver, beef broth.

Guaranteed analysis: Crude Protein (min) 12%; Crude Fat (min) 6%; Crude Fiber (max) 3%; Moisture 10%.

Keep refrigerated to maintain freshness for up to two weeks.

Net wt: 8 oz (227 g)Bucky’s Bakery, Barkville, VA 12345-6789 buckedog@email.net

Vendors will need to contact a private laboratory for the analysis testing. Each laboratory has their own procedures, pricing and time table for results.

Unfortunately, VDACS does not have a lab for this testing

‘Google’ or ‘Bing’ search for pet food testing labs

If the treats are offered in a “self-serve” manner – in those separate plastic containers – the same basic label information must be available to the purchaser.

We recommend having a simple one-page handout or index cards that list all of the products available to their customers.

Their handout will have all the required label information – especially a complete list of all product ingredients.

This will help assure the vendors that no questions or problems will arise if any of the treats are given to pets with known allergies.

Bucky’s BakeryP O Box 945 – Barkville VA 12345-6789

800-My- Dogge (693-6443)

Liver & Beef Flavor Treats Daisy Mae’s Cheese Treats Buddy’s Peanut Butter BitesWhole wheat flour, freeze White flour, cheddar cheese, White flour, peanut butter (peanuts,dried liver, beef broth eggs, water vegetable oil,

sugar, salt), water

Crude Protein (min) 12% Crude Protein (min) 10% Crude Protein (min) 14%

Crude Fat (min) 6% Crude Fat (min) 8% Crude Fat (min) 7%Crude Fiber (max) 3% Crude Fiber (max) 4% Crude Fiber (max) 5%Moisture 10% Moisture 15% Moisture 12%Feed as a treat. Feed as a treat. Feed as a treat.

How Long Does The Process Take

Varies for each company/vendor. Product (treat or food) development

Receipt of laboratory results from private laboratory

Label development

Submission to VDACS for review and acceptance

Issuance of license and product registration

Busiest time for VDACS – November through March Renewal packets prepared and mailed Review of license application and new product labels Contact with company if changes required Re-issuance of license/registrations for current year

During those months, it will take at least several weeks after submission before the packet is reviewed and the license and registration certificate printed and mailed.

In 2010, we processed just over 1,100 company licenses and just under 12,000 product registrations – all classes of livestock feed, medicated feeds, animal remedies and pet foods and treats.

As of March 1, I’ve only renewed 800 licenses and 4,500 products.

So . . If new applications are submitted, please be patient . . .

What Does Licensing and Registration Cost?

The annual license fee is $50.00

Individual product registration is $50.00 per product, also paid annually.

When products do not have to be individually registered, there is an annual tonnage inspection fee of $0.07 per ton on total products sold. There is a minimum annual fee of $35.00 that would equal 500 tons of treats sold.

The license and product registration applications are available on our agency website at www.vdacs.virginia.gov as the first item under our “Important Links” heading on the home page.

There is a copy of the license packet in your folder and I do have a few extra packets here if you would like to have them on hand for your vendors. If you need more, please call my office.

Office of Plant Industry Services - Agricultural Commodity Inspection

CONTACTS

Richmond Office Field Compliance StaffDonald R. Delorme, Program Supervisor Mike Anderson – Southside Virginia

804-371-2303 Compliance Officer 804-371-2667

Debra Hargrave, Rapid Response Team Lee Blanchard – Tidewater VirginiaAnimal Feed Specialist Compliance Officer

804-225-4558 804-382-1013

Jim Schwerdtfeger – Central & Northern VirginiaConnie E. White, Compliance Officer Compliance Officer

804-371-2667 804-382-1647

Ed Huffman, Shenandoah Valley

Compliance Officer 540-910-2496

John Wampler, Southwest Virginia Compliance Officer 804-382-1433

QUESTIONS

Connie E. White, VDACS Compliance OfficerOffice of Plant Industry Services-Agricultural Commodity

InspectionPhone: 804-371-2667