Pet Food Exports to the U.S.: APHIS, FDA, and AAFCO Guidelines (2026)

Pet Food Exports to the U.S.: A Guide to APHIS, FDA, AAFCO, and Amazon

Pet food exports to the U.S. have been one of the fastest-growing export channels for Turkey’s food and meat processing industry in recent years. The reason is clear: The U.S. pet products market has surpassed $270 billion, and the segments experiencing the highest growth are premium treats, freeze-dried meats, single-protein foods, and functional foods. Turkey’s meat processing quality, variety of offal products, and flexibility in contract manufacturing offer a real competitive advantage in this segment.

But pet food is not considered “ordinary food” when it comes to entering the U.S. This product category—which is regulated jointly by the FDA and USDA, governed by AAFCO labeling standards, and falls under one of Amazon’s approval-required (gated) categories—can cause issues both at customs and on the marketplace if the process architecture isn’t set up correctly from the start. In this guide, we cover every aspect of pet food’s journey to the U.S.

The U.S. Pet Food Market: From Where to Where?

Market figures clearly illustrate the window of opportunity for Turkish manufacturers:

  • Total market: The U.S. pet products market is projected to reach ~270 billion USD in 2025 and is on track to reach the 400 billion USD range by 2030.
  • Premium growth: While mainstream dry pet food is growing at a low single-digit rate, the premium treat and functional pet food segment is growing at a double-digit rate.
  • The "human-grade" trend: American pet owners' expectation of "pet food made from ingredients I would eat myself" is driving up demand for freeze-dried and single-protein products.
  • Offal and organ cuts: Products such as liver , heart, lungs, tripe, and larynx are very attractive in terms of price and margin in the U.S.; in Turkey, the raw materials are already available, and this category is generally undervalued in the domestic market.

In other words, supply and demand are in alignment. The key factor is whether the regulations were set up correctly from the start.

What Do the FDA and USDA Cover in the Pet Food Industry?

The roles of these two institutions are often confused; the clear distinction is as follows:

FDA, Product Safety and Facility-Related Matters

The FDA essentially regulates pet food the same way it regulates human food: facility registration, a U.S. Agent, prior notice, preventive controls, and labeling requirements. In other words, even if the product does not come into contact with humans, safety, production conditions, and marketing claims fall under the FDA’s jurisdiction. Claims such as “cures allergies” reclassify the product as a drug, which is a red line.

USDA/APHIS, Biosecurity and VS Permit

APHIS Veterinary Services (VS) authorization is required for pet food and treats containing animal-derived ingredients. The reason is biosecurity: to prevent foreign animal diseases (foot-and-mouth disease, ASF, avian influenza) from entering the U.S. along with imported animal products. The VS Permit process is based on the product-country-of-origin combination; for information on the application steps, the APHIS eFile system (effective as of 2022), and common mistakes made by Turkish producers, please refer to our guide, “How to Obtain a USDA/VS Permit.”

Who Does What? At a Glance

OrganizationScopeIn the Context of Pet Food
FDAProduct safety, facility registration, labeling, claim languageAll pet food products (plant-based + animal-based)
USDA APHIS/VSAnimal health, biosecurity, import permitPet food/treats containing animal-derived ingredients (VS Permit)
State & AAFCOLabeling and content standards (de facto standards)All pet food products (label compliance)

AAFCO Label: Not a Government Standard, but a De Facto Standard

The most confusing aspect of pet food labels is AAFCO. Let’s break it down: AAFCO (Association of American Feed Control Officials) is not a federal agency; it is an umbrella organization for the animal feed control agencies of U.S. states. Its influence, however, is significant: every state has adopted AAFCO’s model regulations and labeling standards. In other words, AAFCO compliance is not a “preference” but a de facto prerequisite for selling products on U.S. store shelves.

Required Elements of the AAFCO Label

  • Product name and brand: Restrictions based on product content (there is a significant difference between “chicken,” “with chicken,” and “chicken flavor”)
  • Species (target animal) declaration: Dog food / Cat food, etc.
  • Guaranteed Analysis: Crude protein, crude fat, crude fiber, moisture, with minimum/maximum values
  • Ingredient statement: List of ingredients , in order of weight; using AAFCO-defined names
  • Nutritional adequacy statement: If the product claims to be “complete and balanced,specify for which life stage and how this claim is substantiated (AAFCO nutrient profile or feeding trial)
  • Feeding instructions: Feeding guidelines
  • Net quantity, manufacturer information, country of origin: Metric + oz/lb; “Product of Türkiye”; English

For treats, the nutritional adequacy statement is generally declared as “for intermittent or supplemental feeding only”; avoiding the claim that the product is “complete and balanced” is the safer approach for most manufacturers.

Process Differences by Product Group

Dry Dog Food (Dry Kibble)

If the product contains animal-derived ingredients, an APHIS VS Permit and health certificate are required. Since this is a mainstream category, platforms—including Amazon—require the AAFCO label and “complete and balanced” verification. It’s a volume-driven market with intense price competition.

Wet Food (Wet / Canned)

Since this is a canned product, there are some critical additional requirements: If it falls under the LACF (low-acid canned food) category based on pH and water activity, an FCE registration and an SID process notification may also be required. In other words, in the case of “pet food + canned,” the FDA, USDA, and FCE/SID all come into play. The formulation and process must be scientifically documented from the outset.

Freeze-Dried Treats and Meats

The most attractive segment. However, since the raw materials consist mostly of offal and organs, the APHIS VS Permit requirements are the strictest here: for products such as beef liver, heart, tripe, throat, and lungs, import eligibility must first be verified based on the country-plus-product combination. Turkey’s foot-and-mouth disease status is a determining factor for this product; containers should not be loaded without first obtaining approval from the VS Permitting Assistant.

Chew Toys

APHIS authorization is required for chewable products such as hide, nerve, and tripe; furthermore, the “animal by-product” classification must be carefully determined by CBP. Shipments with an incorrect HTS code are generally held up at customs.

Fish and Fish-Based Products

Pet foods containing fish-based ingredients and fish oil are regulated under the FDA; however, for certain types, the importer may request additional documentation (such as catch area and processing certificates). USDA regulations on fish are limited, which makes market entry easier for Turkish producers.

Amazon Pet Food: Gated Category

In the U.S., pet food is a "gated" category on Amazon. This means listings must be approved by Amazon before they go live; the standard "Add a New Product" process does not apply. The following are typically required for gated approval:

  • Product photos (with legible labels and all required elements included)
  • Supplier invoices (issued by the manufacturing facility)
  • Company and contact information, U.S. address
  • In some cases, safety/quality certificates or laboratory analyses

Our experience shows that submitting a “gated” application with FDA facility registration confirmation and the correct AAFCO label significantly increases the likelihood of approval. After “gated” approval, Brand Registry, A+ content, and PPC setup come into play. For trademark registration and Brand Registry, we recommend our Amazon Brand Registry guide and our page on trademark registration in the U.S.

Roadmap, Specifically for Pet Food

StageWhat's HappeningWhy It Matters
1. AccessibilityAPHIS vs. Permitting Assistant CheckDecision to Keep or Discontinue Animal-Based SKUs
2. FDA BasicsFacility Registration + U.S. Agent + Prior NoticeFDA Requirements for Pet Food
3. APHIS vs. PermitApplication for a product-origin combinationOffal/Organ/Pet Food Entry Key
4. AAFCO LabelLabel Compliance by SKUPrerequisite for Amazon and the shelf
5. Amazon GatedApproval File and ApplicationPrerequisite for listing
6. LaunchBrand Registry, A+ Content, PPCThe sale itself

Common Mistakes

  • The “FDA is sufficient” assumption: If the APHIS VS Permit is omitted for a product containing animal-derived ingredients, the container will be held up at customs.
  • Viewing AAFCO as optional: It is not federal but is binding at the state level; if the label is not AAFCO-compliant, it will cause problems for both Amazon and retailers.
  • False “complete and balanced” claim: Using this claim in an award or making it without supporting evidence from a profile or feeding trial poses a risk.
  • Thinking about Amazon Gated after the fact: If you try to submit a Gated application after the product has arrived in the U.S., the inventory will sit idle.
  • Treating the formulation and the label separately: The inclusion of “chicken” in the product name has specific implications, such as the AAFCO 25% rule; the product name must be determined in conjunction with the formulation.

Frequently Asked Questions (FAQ)

Is an APHIS VS Permit required for every pet food product?

For animal-derived products, yes; for plant-based products, mostly no. The final decision is determined through the APHIS VS Permitting Assistant based on the product and country-of-origin combination.

Is there such a thing as AAFCO approval?

The phrase “AAFCO-approved” is technically incorrect; AAFCO does not approve products—it publishes model regulations and standards. State regulatory agencies review labels based on these standards.

How long does it take to get Amazon Pet Food Gated approval?

It varies from a few days to a few weeks, depending on the quality of the file. Missing or incompatible tags and facility records are the most common causes of delays.

Do cat food and dog food go through the same process?

The basic ingredients are the same; however, they differ in terms of AAFCO nutrient profiles, target animal specifications, and marketing. Labeling and claim language are determined on a species-by-species basis.

Can I use the term “human-grade” on freeze-dried treats?

In order for the product to be used, it must have been produced in a facility suitable for human consumption, in accordance with the relevant regulations and to human food standards. If this cannot be documented, the safest course of action is to avoid using the statement.

Can the label be in Turkish?

No. The entire label must be in English and include the required elements in the AAFCO/FDA format.

The Formula for Success in Pet Food

Pet food is the category with both the highest growth potential and the most complex regulatory framework for exports to the U.S. For a manufacturer proceeding in the right order, the outcome is predictable: market access with APHIS is clarified, the foundation for FDA compliance is laid, AAFCO labeling is established, Amazon’s “gated” approval is obtained, and the product launch is built on this foundation. Projects that deviate from this sequence, unfortunately, learn the hard way during their first shipment.

We provide end-to-end support for pet food exports from Turkey to the U.S., including the APHIS VS Permit, FDA registration, AAFCO labeling, and Amazon’s gated processes. For more information, please refer to our guides on “Exporting Pet Products from Turkey to the U.S.” and “How to Obtain a USDA/VS Permit.”

Related guides: FDA Registration and Documentation · Amazon Brand Registry · Trademark Registration in the U.S. · FDA Labeling and Customs Consulting Guide

Other guides in this series

This guide is part of a series explaining FDA processes for exporting to the U.S. Other related guides:

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