The FDA has issued a number of Compliance Insurance policies that informs trade what legal guidelines the company will or won’t implement. In every of the Compliance Insurance policies beneath, the FDA is permitting adulterated meals to be disposed of into pet meals/animal feed. And in every Coverage the company requires the adulterated meals to be authorised (by FDA) first – earlier than disposal into pet meals/animal feed.
In CPG Sec. 675.100 Diversion of Contaminated Food for Animal Use the company offers this as background info:
“FDA doesn’t object to the diversion to animal feed of human meals adulterated with rodent, roach, or chook excreta. Nonetheless, since rodent, roach, or chook excreta are vectors for microorganisms deleterious to the well being of animals, together with things like parasite eggs, salmonella, leptospira, or different pathogenic organisms, diversion has not been licensed besides following a warmth remedy applicable to destroy such organisms.”
And the FDA Coverage concerning the Diversion of Contaminated Meals for Animal Use states this:
“Diversion of rodent, roach, or chook contaminated meals for animal feed use, whether or not pursuant to a courtroom order or a voluntary motion, requires warmth remedy to destroy pathogenic organisms. The *Heart for* Veterinary Drugs (HFV-236) needs to be contacted on a case-by-case foundation regarding suitability of proposed remedy, whether or not pursuant to a courtroom order or a voluntary motion.”
With the above Compliance Coverage, the FDA permits meals that has legally been categorised as adulterated – contaminated with rodent, roach or chook feces – to be disposed of into animal feed. The FDA requires the company to be notified upfront to approve the ‘remedy’ to destroy “things like parasite eggs, salmonella, leptospira, or different pathogenic organisms” (that can quickly develop into pet meals or animal feed).
In CPG Sec. 675.300 Moisture Damaged Grain the FDA Heart for Veterinary Drugs (CVM) offers this background info:
“Prior to now CVM has licensed the diversion of moisture-damaged grain in addition to different meals supplies for animal feed use. Such authorization has at all times needed to take into accounts the character and supply of the water since fires from grain elevator explosions are sometimes quenched utilizing sea water or river water which can comprise sewage, pathogenic organisms, chemical wastes or different poisonous substances. Comparable issues are posed when foodstuff is flooded following hurricanes or different pure disasters. Much more severe is the mould progress which can happen in moist meals.”
And that is the FDA CVM Coverage concerning contaminated grain:
“Moisture-damaged and/or moldy foodstuffs could also be thought-about for conversion to animal feed use. Nonetheless, in every case authorization might be made by *CVM* in session with *CFSAN* primarily based upon info regarding the nature and supply of the moisture and the precise or suspected sort of contamination and whether or not the broken materials could also be rendered protected to be used as animal feed.” (CFSAN stands for a division of FDA, Heart for Meals Security and Utilized Diet.)
Once more, in every case of moisture broken grain (or “moldy foodstuffs”), the FDA requires the company be notified/consulted with upfront of the broken grain being diverted to pet meals/animal feed.
In CPG Sec. 675.200 Diversion of Adulterated Food to Acceptable Animal Feed Use, the FDA offers this info as background:
“Prior to now, FDA has licensed the salvage of human or animal meals thought-about to be adulterated for its meant use by diverting that meals to an appropriate animal feed use. Most of those cases have concerned, however haven’t been restricted to, the interpretation of part 402(a)(3) and (4) of the Federal Meals, Drug, and Beauty Act to permit completely different requirements for meals meant for human use vs. meals meant for animal use, e.g., defect motion ranges for filth in a meals meant for human use however not for a similar meals meant for animal feed use. Diversion requests, nevertheless, have additionally included USDA detained meat and poultry merchandise contaminated with drug or different chemical residues, in addition to meals and feed underneath voluntary trade recall or quarantine that could be thought-about adulterated for his or her meant use(s).”
That is the FDA Coverage concerning the disposal of adulterated meals into pet meals/animal feed use:
“Diversion requests might be dealt with on an advert hoc foundation. The *Heart* will take into account the requests for diversion of meals thought-about adulterated for human use in all conditions the place the diverted meals might be acceptable for its meant animal meals use. Such conditions could embody:
- Pesticide contamination in extra of the permitted tolerance or motion degree.
- Pesticide contamination the place the pesticide concerned is unapproved to be used on a meals or feed commodity.
- Contamination by industrial chemical substances.
- Contamination by pure toxicants.
- Contamination by filth.
- Microbiological contamination.
- Over tolerance or unpermitted drug residues.”
With this FDA Coverage, the company once more requires the consignee of the adulterated meals to inform the company upfront of diversion to pet meals/animal feed. Under is among the info the company requires with every adulterated meals diversion request.
- “Identify and tackle of the requestor, and the identify of the proprietor of the topic articles.
- The exact bodily location of the product.
- The rationale(s) the articles are thought-about adulterated for his or her initially meant meals makes use of.
- The degrees, on a lot-by-lot foundation, of any adulterant; all analytical information concerning such ranges of an adulterant, and the methodology utilized in figuring out the degrees of the adulterant.
- The identify and tackle of the proposed consignee.
- The reconditioning or denaturing process, if any.
- The meant use of the diverted meals. This can embody full description of the category of animals concerned, whether or not they’re meals or non-food producing, the a part of the nation during which the meals might be used, and all assurances which were secured that certainly the meals might be used as agreed.“
The FDA is aware of EXACTLY which pet meals producers embody adulterated components contaminated with all varieties of substances. The FDA is aware of EXACTLY which livestock feed producers embody adulterated components.
However the FDA doesn’t inform you.
The FDA doesn’t require the producer to inform you both. The ingredient listing offers you no clues if the rooster contains drug residues, or the grain contains pesticides or sewage.
On September 17, 2026, we filed a Freedom of Info Act (FOIA) request with FDA asking for the entire authorised adulterated meals diversion requests from 1/1/2020 by 9/17/2026. Our request included the identify of the consignee in every diversion request (which producers bought adulterated meals). We are going to share all info acquired when it’s supplied by FDA.
Nonetheless, we now have been made to attend over 5 years for beforehand submitted FOIA requests. Realizing the company doesn’t need the general public to know this info, we assume this may take years for FDA to offer. However it is going to be fascinating to see if the consignee info is supplied or not. Will FDA defend trade, or will they be clear with shoppers?
Susan Thixton
Pet Meals Shopper Advocate
TruthaboutPetFood.com
Association for Truth in Pet Food
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