AAFCO Flags Gaps in FDA’s Proposed Mandatory GRAS Notification Rule

The U.S. Food and Drug Administration’s proposed rule to make Generally Recognized as Substance (GRAS) notifications mandatory for animal food is drawing sharp criticism from AAFCO, the association of state feed officials. FDA published the proposal on August 11, 2026; comments are due December 9, 2026.

Currently, companies can self-determine that an ingredient is GRAS without notifying FDA. The proposed rule would end that voluntary system and require companies to submit formal GRAS notices before marketing new substances in animal food, including pet food.

AAFCO’s concerns

AAFCO has identified several gaps in the proposal:

• 2024 Office of Pet Food (OP) exemption remains frozen. The proposal does not resolve the status of ingredients that were under review in the now-suspended OP program.
• State ingredient pathways are not recognized. Many states use the State Regulatory Ingredient Submission (SRIS) process. The FDA rule, as drafted, would not harmonize with SRIS, creating parallel approval tracks.
• Capacity and timing uncertainty. Without clarity on FDA review timelines, ingredient innovators could face launch delays measured in years rather than months.

Business impact

For pet food and treat manufacturers, the rule could increase compliance costs and slow new-product pipelines. Companies relying on novel proteins, novel fibers, postbiotics, or specialty additives may need to budget for formal GRAS dossiers and extended pre-market timelines.

GlobalPetIndex view: the comment window gives the industry until early December to shape the final rule. Expect trade associations and large multinationals to push for carve-outs that preserve state-level flexibility and grandfather existing ingredient approvals.