One of the most perplexing issues when distributing animal feeds and feed ingredients in the US is determining how to accurately register and license both the guarantor and products, to be in compliance for national distribution. A guarantor, the name of the company listed on the feed label or package, is responsible for complying with all applicable food regulations, which include a variety of registrations. If products are distributed nationally, they must be registered with those state feed regulatory programs that have registration and licensing requirements.
Unfortunately, there is no one-stop shopping for registration, and the first challenge is identifying which states require registration or licensing. Thankfully, the Association of American Feed Control Officials (AAFCO) has helped demystify this process. A visit to the website www.aafco.org “Regulatory” tab, will provide guarantors with a document titled, “State Regulatory Requirement Summary.” This table is updated annually and provides a broad overview of the requirements for each state that requires registration.
This summary is a good start, but the information may be too broad, and additional questions may arise. In that case, click on the interactive map found under the “Regulatory” tab, and search for the contact information for those within each state who handle registration. Don’t hesitate to reach out to each state and ask for additional clarification.
Many states are moving from paper document requirements to an electronic data entry system that guarantors can access. This software is designed to allow each guarantor to enter registration, product, and tonnage information, and to upload labels and pay any required fees online. These systems also allow for direct delivery of notifications, sample and tonnage reports, and registration renewals. Not all states will switch to an on-line access system, but many are in the development process to provide better service to guarantors.
The requirements for registration vary from state to state, but ensuring guarantor and product compliance is key to avoiding enforcement actions for failure to comply with state feed program requirements. Interestingly, although the Food and Drug Administration (FDA) requires registration of facilities that handle food under the Food Safety Modernization Act, the FDA has no requirement for guarantor or product registrations. ToxStrategies consultants can assist with your state or federal registration needs; please contact Candace Doepker, Ph.D., Food and Consumer Products Practice Leader, at (513) 206-9929.