Updated October 2026
Pet food falls under the rules for animal food, and those rules give the brand and the warehouse different jobs. The brand registers and labels the product. The warehouse that holds it has a much smaller set of duties.
Pet food is regulated as animal food, and the duties under those rules depend on your role. The brand is the registrant. It answers for a truthful label, registers with state feed officials, and makes any claim about AAFCO model profiles. The 3PL is the holder, responsible for storing the sealed product and carrying out a recall. We hold sealed animal food, and because we record each lot at receiving, we can isolate a single affected lot fast.
By The Fulfillment.com team
Most pet brands reach the regulatory part of choosing a warehouse with one worry. If something turns out to be wrong, who is on the hook, and how much of the work does the 3PL take on? Pet food is regulated as animal food, under rules that are separate from those for human food and for dietary supplements. Some of the duties under those rules belong to the brand, as the registrant of the product. One set belongs to the 3PL, as the holder of the sealed product.
Vendors sometimes blur that line. When they do, a warehouse can suggest it carries duties it doesn't, or cite certifications that don't exist. How holding works day to day, at the dock and on the shelf, is in our guide to pet food storage and holding.
Four bodies set or shape the rules for pet food. None of them approves a pet food product.
FDA, through its Center for Veterinary Medicine (CVM). FDA regulates pet food under the FD&C Act. Animal food has to be made under sanitary conditions, contain nothing harmful, and carry a truthful label. FDA does not approve a finished pet food before it goes on sale. Everyday ingredients such as meat, poultry and grains are treated as safe without a sign-off before sale, so "FDA-approved pet food" describes a status FDA never gives. Some added substances may still need FDA approval or GRAS (generally recognized as safe) status, but the finished product as a whole is not cleared in advance. The brand is responsible for a truthful label and for compliant ingredients. A facility registers with FDA for the work it does there.
AAFCO, the Association of American Feed Control Officials. No name in pet food is misused more often. AAFCO has no regulatory power. It is not a government agency, and it approves, certifies and registers nothing. It writes model rules for the states to adopt, including ingredient definitions, nutrient profiles and label standards. So "AAFCO-approved" and "AAFCO-certified" are both inaccurate. A brand can accurately say its label "meets AAFCO model nutrient profiles" or is "AAFCO-compliant." That is the brand's claim about its own product, and a 3PL never makes it.
State feed control officials. Registration happens here. Most states require the manufacturer, distributor or guarantor to license the firm and register each product label before the product can be sold in that state. Each state does this separately, on top of FDA compliance. The party that registers is the registrant, which is usually the brand or its named guarantor rather than the warehouse holding the stock. Selling in many states is one reason a brand moves its orders to a 3PL in the first place. A national fulfillment contract still leaves each state's label registration with the brand.
FSMA's Preventive Controls for Animal Food rule (21 CFR Part 507). This rule sorts facilities by what they do with the product. Making or processing animal food puts a facility on one side, and holding it puts the facility on the other. Some warehouses only hold sealed, packaged animal food, meaning product that stays in its packaging and doesn't need refrigeration to stay safe. Those warehouses follow the lighter holding-facility provisions. A maker has to run the full program of hazard analysis and preventive controls. The holding provisions are the one set of duties on the 3PL's side, and they are the lighter set.
We are a 3PL that receives and holds finished, sealed pet food and treats. We don't produce, fill or package any of it, so we are not the manufacturer. We are not the state feed-label registrant for any brand we ship, either. Our role is the holder. Labeling and ingredient duties stay with the brand. So do its AAFCO-profile claims and its registration in each state. Those duties follow the product and the company that sells it, wherever the stock happens to be stored.
Our share is smaller, and it is physical work. We store sealed animal food, record each lot as it arrives and keep that lot on every order it ships in, so when a lot is recalled we can find it and pull that lot alone, fast. The brand handles the regulatory paperwork, and we answer for how quickly the physical pull happens. Our guide to pet food lot tracking and expiration control explains how the record is kept.
A warehouse that calls itself "AAFCO-certified" or "FDA-approved" is using phrases that describe no real status. A vendor that uses them is either careless about rules it wants you to trust it with, or counting on you not to check. A warehouse that knows the rules describes itself as a holder of sealed animal food. It names the holding-facility provisions as its share, and it supports your compliance without claiming to take it over. Ask any 3PL for its FDA food facility registration and how it meets the Part 507 holding provisions. You should get a straight answer.
Your brand does. State feed control officials typically require the manufacturer, distributor or guarantor to license the firm and register each product label before it goes on sale. That happens state by state, on top of FDA compliance. The registrant is usually the brand or its named guarantor. As a 3PL that holds your product, we are not the registrant, and signing a fulfillment contract leaves each state's label registration with you.
No, because there is no such approval. AAFCO has no regulatory power, and it approves, certifies and registers nothing. It publishes model nutrient profiles and label standards, and the states adopt them. What you can accurately say is that your label "meets AAFCO model nutrient profiles" or is "AAFCO-compliant." That claim is yours to make about your own product. No 3PL issues it as a stamp, and neither does anyone else.
Under the FD&C Act, a truthful label is the brand's duty. Registering that label with state feed officials is the brand's duty too. A warehouse that receives and ships sealed, finished product doesn't write the label or take it on. We are the holder, so labeling and registration stay with the brand. Our job is careful storage of the sealed product and a fast pull of the affected lot when a recall is called.
Two jobs, and both are physical work rather than paperwork. The 3PL stores sealed animal food, and it pulls one affected lot when a recall is called. Under FSMA Part 507, a facility that only holds sealed, packaged animal food follows the lighter holding-facility provisions. A maker has to run the full preventive-controls program. Ask any 3PL how it meets the holding provisions. We record lot and expiry as stock arrives, and that record is how a single lot gets found and isolated. Your label and ingredients remain your responsibility, and so do your AAFCO-profile claims and state registrations.
The split follows who did what. The brand answers for what it markets, registers and labels. The holder answers for how it stored and shipped the sealed product. We don't produce, fill or package the food, so the exposure for manufacturing, labeling and state registration stays with the brand and its named guarantor. We answer for the holding-facility duties and for pulling the affected lot quickly when a recall is called.