Pet Food Sales on Amazon in the U.S.: FDA, AAFCO, and Approval Guidelines

Amazon Pet Food Sales in the U.S.: A Complete Guide from FDA Compliance to Amazon Approval

The U.S. pet products market is the world’s largest and continues to grow. The sector is projected to reach approximately $273 billion by 2025 and is expected to exceed $427 billion by 2032. For Turkish food manufacturers, selling pet food (pet food and treats) through Amazon U.S. can be an extremely profitable export channel when properly structured.

However, there is a critical fact to keep in mind: Pet food is a “gated” category on Amazon. This means that before you can start selling, you must complete both the FDA compliance process and Amazon’s approval process. If your label does not comply with AAFCO standards or if you do not have an FDA facility registration, your product may be held at customs or your Amazon listing may be removed.

In this guide, we walk you through the entire process step by step, using a real-life case study of a manufacturer we’ve advised.

Why Is the U.S. Pet Food Market So Attractive?

The U.S. is the global leader in per-person spending on pets. The premium and “natural/human-grade” segments are growing rapidly; in particular , freeze-dried treats, grain-free foods, and functional products are in high demand among American pet owners.

Turkey’s meat processing and food production infrastructure offers a significant competitive advantage in this premium segment. With the right certifications and brand positioning, it is entirely possible for a Turkish producer to establish a presence on Amazon U.S.—provided that the regulatory framework is fully in place.

Case Study: A Roadmap for a Turkish Meat Processor Entering the U.S. Market

One of the manufacturers we advise—a company with a strong meat processing and food production infrastructure in Turkey—has positioned three separate product lines under a single U.S. LLC to enter the U.S. market:

• Main product lines: Meat-based freeze-dried treats (beef liver, spleen, heart, tripe, throat, lungs; chicken, duck, salmon, anchovy), grain-free dry food, premium wet food, and functional stick treats.
• Second line: Freeze-dried fruit products.
• Third line: Online retail / marketplace brand (focused on online retail sales of pet products).

This three-tiered structure is no coincidence: each tier represents a different product category and a different Amazon strategy. Below, we share the regulatory roadmap behind this structure.

Step 1: U.S. Company and Tax ID Number (LLC + EIN)

The foundation for becoming a professional seller on Amazon in the U.S. is having a U.S. legal entity and an EIN (Employer Identification Number). In our case, this foundation was established by forming a U.S. LLC and obtaining an EIN from the IRS.

While it is technically possible to sell without a U.S. company, an LLC + EIN structure makes the process significantly easier in terms of opening a bank account, trademark registration, payment collection, and tax management. For this reason, the first step in the roadmap always starts here.

Step 2: Trademark Registration — A Prerequisite for Amazon Brand Registry

In a competitive and easily counterfeited category like pet food, selling without protecting your brand is a major risk. To enroll in Amazon’s Brand Registry program, you need a trademark that is registered (or for which an application has been filed) in the U.S.

In our case, the manufacturer filed three separate trademark applications with the USPTO on an ITU (Intent to Use) basis:

• Meat-based pet food/treat brand — Class 31 (pet food; edible pet treats)
• Freeze-dried fruit brand — Class 29 (freeze-dried fruits)
• Online retail brand — Class 35 (online retail store services / pet products)

In ITU-based applications, if the trademark is not yet in actual use in the U.S., the process of submitting proof of use begins after the “Notice of Allowance.” This is an ideal method for exporters who wish to secure their trademark rights before launching the product.

For more information on trademarks: our guide to trademark registration in the U.S. and our guide to Amazon Brand Registry & Amazon Transparency.

Step 3: FDA Compliance — A Must-Have for Pet Food

In the U.S., pet food is regulated by the FDA in the same way as “conventional food.” This means that a regulatory framework similar to that for human food applies. The main FDA requirements that must be met before importing pet food into the U.S. are as follows:

3.1. FDA Food Facility Registration + U.S. Agent

The foreign facility manufacturing the product (the factory in Turkey) must be registered with the FDA and must appoint a U.S. Agent. Without this registration, the product cannot enter the United States.

3.2. Prior Notice

Prior to each shipment, an electronic advance notification regarding the product’s arrival in the U.S. must be submitted to the FDA and CBP (Customs). This notification enables the FDA to decide whether to conduct an inspection or take samples at customs.

3.3. FSVP (Foreign Supplier Verification Program)

It is mandatory for the U.S. importer (typically your LLC), your supplier, and the product to have an FSVP plan that verifies compliance with U.S. food safety regulations. If the FDA deems this plan inadequate, it may halt the shipment even if the product is safe.

3.4. cGMP and Preventive Controls (HARPC)

Pet food manufacturing facilities must meet minimum sanitation standards (cGMP) and implement preventive controls based on hazard analysis.

3.5. Ingredient Suitability

All raw materials you use must be either an approved food additive, GRAS (Generally Recognized as Safe), or an acceptable ingredient as defined in the AAFCO Official Publication.

3.6. Special Considerations for Meat Products: USDA/APHIS Requirements

Here’s a very important point regarding meat-based freeze-dried treats: Products of animal origin may be subject to regulation not only by the FDA but also by the USDA.

• A health certificate from the country of origin and USDA FSIS documents may be required for meat and poultry products.
• Some animal by-products may require USDA APHIS authorization or certification to prevent the introduction of foreign animal diseases.

For this reason, the supply chain and certification for treats made from offal—such as beef liver, tripe, and esophagus—must be managed with greater care than for ordinary dry dog food.

We have provided a step-by-step breakdown of the USDA/APHIS inspection process and the VS Permit (Veterinary Services Permit) requirements for animal-derived products in our article titled " Exporting Pet Food to the U.S. – USDA & VS Permit."

For practical steps regarding the FDA: our FDA Registration and Certification Guide and our FDA Labeling and Customs Advisory Guide. We discuss why Turkish manufacturers are turning to this process in this article.

Step 4: AAFCO Labeling Rules

What is AAFCO? The Association of American Feed Control Officials (AAFCO) is not a government agency; it is an association of state and federal regulatory officials. It does not approve pet food itself, but it develops standards that define ingredient definitions, nutrient profiles, and label formats. Since most U.S. states have incorporated these model regulations into their own laws, compliance with AAFCO standards is effectively mandatory.

In the U.S., pet food labels are prepared in accordance with FDA federal regulations and AAFCO model regulations. The key elements that must appear on your label are:

1. Product/brand name
2. Target species declaration (e.g., “Dog,” “Cat” — clearly indicated on the main panel)
3. Net weight — in both metric and avoirdupois (lb/oz) units, in the bottom third of the panel
4. Guaranteed Analysis — minimum crude protein, minimum crude fat; maximum crude fiber, maximum moisture
5. List of ingredients — Using the correct names as defined by AAFCO
6. Nutritional Adequacy Statement — if required
7. Feeding Instructions
8. Name and address of the manufacturer/distributor

The entire label must be in English.

A Major Convenience in Treat Products

Freeze-dried treats have a significant advantage: AAFCO allows treat and snack products to be exempt from the requirement to make a full “complete and balanced” nutritional claim— provided that the term “snack” or “treat” is clearly stated on the main label.

However, since grain-free dry and wet foods are intended to serve as the primary source of nutrition, their labels must include the full “complete and balanced” statement and comply with the relevant AAFCO nutrient profiles (e.g., for adult dog food: at least 22% protein and 5% fat on a dry matter basis; for adult cat food: at least 26% protein and 9% fat).

For details on the export, labeling, and 21 CFR Part 501 compliance of dog chew and treat products, please refer to our article on Natural Dog Chew Products for the U.S.

State Records

Many states require you to register or have the label of each pet food product you intend to sell approved by them. These registrations should be planned based on the states where you intend to sell your products.

Step 5: Getting Approved (Ungating) in Amazon’s “Pet Supplies” Category

Pet food and pet health products have been a gated category on Amazon US since August 2020. You cannot send these products to FBA fulfillment centers or list them without approval.

When submitting an unblocking request, Amazon typically requires the following:

• Manufacturer invoices: Invoices dated within the last 180 days, showing the purchase of at least 10 products, and issued by an authorized supplier.
• Product photos: Images that clearly show all sides of the packaging and required panels such as the ingredient list and feeding instructions.
• FDA compliance documents: FDA/relevant agency documents based on product type.
• In some cases, a COA (Certificate of Analysis): A laboratory analysis report may be required, particularly for products with dietary supplement or health claims.

Other important points to note regarding the listing rules:

• Labels must be in English and must include the product name, manufacturer information, and any necessary warnings.
• The packaging must be original, sealed, and new; the lot number and expiration date must be clearly visible.
• Unsubstantiated health claims are prohibited —claims such as “treats” or “prevents disease” made without regulatory approval will result in your listing being removed.

Our Amazon Private Label Starter Guide is a helpful starting point for gaining experience with this process.

Roadmap — Summary

Unlike the "sell first, figure it out later" approach, this framework aims to establish compliance before product launch. In a heavily regulated category like pet food, getting the process right minimizes both customs risks and the risk of Amazon account suspension.

Frequently Asked Questions (FAQ)

Is FDA approval required to sell pet food in the U.S.?

The FDA does not grant individual “approvals” for pet food; however, requirements such as facility registration, prior notice, FSVP, and ingredient compliance are mandatory. Additionally, Amazon requires FDA compliance documents as part of its own approval (ungating) process.

What is AAFCO? Is it a government agency?

No. AAFCO is not a government agency; it is an association of regulatory authorities. It does not test or approve pet food; rather, it develops standards that define ingredient definitions, nutrient profiles, and label formats. Since most states have enacted these rules into law, they are effectively binding.

Is an additional permit required for freeze-dried meat products?

Yes. In addition to FDA approval, products of animal origin may require an USDA FSIS health certificate and, in some cases, APHIS authorization. This is the most critical distinction between meat-based treats and dry dog food.

Is the "complete and balanced" claim required for pet food products?

No. If the term “snack” or “treat” is clearly stated on the main label, reward products may be exempt from the full nutritional adequacy declaration. However, this declaration is mandatory for pet foods that serve as the primary source of nutrition.

Can my label be in Turkish?

No. According to both AAFCO and Amazon regulations, the label must be in English and include all required elements.

Selling pet food on Amazon in the U.S. presents a significant opportunity for Turkish food and meat processing manufacturers—provided it is structured correctly. However, success depends on navigating the regulatory framework before even considering product quality: LLC + EIN, trademark registration, FDA compliance, AAFCO labeling, and Amazon ungating.

Completing these steps in the correct order and in full eliminates risks related to both customs and your Amazon account.

If you’re planning to enter the U.S. market with pet food, dietary supplements, or any other food product, Export Partners is here to support you every step of the way through the FDA registration and certification processes, as well as the trademark registration process in the U.S.

Related guides: Selling Dietary Supplements on Amazon in the U.S. and the FDA Compliance Process · Selling Dietary Supplements in the U.S.