Proposed SEC 507.25(a) also addresses labeling controls. It would require that containers holding animal food, raw materials, or ingredients be labeled to accurately identify the contents. The Agency considers the correct identification of animal food, raw materials, and ingredients to be an important step in preventing or minimizing inappropriate handling or utilization of the animal food products during their manufacture, processing, packing, or holding. Labeling for finished animal food products would be required to contain the specific information and instructions needed so the food can be safely used for the intended animal species. Properly labeled finished product could prevent, for example, animal food containing micronutrients such as copper or selenium from being fed to animals for which these ingredients could be injurious to health.
FDA's human food CGMPs, on which the Agency is modeling these animal food CGMPs, do not include labeling controls. However, the Agency tentatively concludes that such controls are necessary for animal food, because unlike human food, a finished animal food is often the animal's sole source of nutrition. Animals of different species can be adversely affected by too low or too high levels of certain nutrients in the food. Because of this, it is important that the labeling correctly reflects the contents of the product and provides the necessary information on how to use the product safely for the type of animals being fed.
The AAFCO Model animal food CGMPs include labeling controls. It provides that a label or other unique identifier shall be affixed to, or accompany, feed and/or feed ingredients to maintain identity and facilitate safe and effective use. Labels shall be stored, handled and used in a manner that minimizes errors. Obsolete labels shall be discarded promptly (Ref. 42). The PAS 222 provides that information on content and intended use of animal food products shall be communicated to customers, for example, on a product label. It also requires that procedures be in place detailing the correct labeling of products in accordance with applicable regulations (Ref. 44).
FDA is proposing in
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