AAFCO label modernization: what the Pet Nutrition Facts box means for your pack
AAFCO’s new model regulations replace the familiar guaranteed analysis with a Pet Nutrition Facts box and move the intended use to the front of the pack. Here is what changes, when, and what it means for your formulation data.
- AAFCO members approved the new model pet food regulations on 31 July 2023.
- Labels gain a Pet Nutrition Facts box with calories per serving, a carbohydrate maximum and dietary fibre in place of crude fibre.
- AAFCO recommends about six years of enforcement discretion; each US state adopts the rules on its own schedule.
- Accurate calorie and carbohydrate figures depend on good analytical data — plan testing before artwork.
01What changed
On 31 July 2023, members of the Association of American Feed Control Officials (AAFCO) approved new Model Pet Food and Specialty Pet Food Regulations, known as Pet Food Label Modernization (PFLM) 1. The project brings pet food labels closer to the format owners know from human food. There are four headline changes 1:
- a Pet Nutrition Facts box replaces the guaranteed analysis;
- an intended-use statement moves to the lower third of the front (principal display) panel;
- the ingredient statement may group vitamins in parentheses and use common names;
- optional, standardised storage and handling statements and icons.
02Inside the Pet Nutrition Facts box
The box is designed to be read like a human nutrition panel 2. It states a household unit — a can, a cup, a treat or a piece — together with its weight in grams, for example “1 cup (8 oz standard measuring cup) = 80 g”. Calories are shown per unit and broken down into calories from protein, fat and carbohydrate. Each nutrient is given both as a minimum or maximum percentage and in grams per serving 2.
| Element | Current label | Under PFLM |
|---|---|---|
| Nutrient panel | Guaranteed analysis (percentages) | Pet Nutrition Facts box, set off with hairlines on a neutral background 2 |
| Calories | Calorie content statement | Calories per household unit, split into protein, fat and carbohydrate 2 |
| Fibre | Crude fibre (max) | Dietary fibre (max) 3 |
| Carbohydrate | Not declared | Total carbohydrate (max) added 3 |
| Intended use | Within the nutritional adequacy area | Short statement in the lower third of the front panel 1 |
| Storage & handling | Free text, if any | Optional standard statements and icons 1 |
03When it applies
AAFCO writes model regulations; US states make them law. AAFCO has recommended that state feed control programs use enforcement discretion for six years, counted from the availability of the printed 2024 Official Publication, and that either the old or the new format is accepted during that period 4. Each state adopts the rules through its own rulemaking, so timing varies. Brands selling nationally should plan for the new format well before the end of the transition rather than waiting for the last state.
04What it means for formulation and testing
The new box puts numbers on the pack that many brands have never had to publish. Three are worth planning early:
- Calories per cup or piece. These depend on the energy value of the recipe and on the real weight of a cup or piece, which varies with kibble density and shape. Measure both on production-representative product.
- Total carbohydrate. A maximum carbohydrate figure needs reliable values for moisture, protein, fat, ash and fibre, because carbohydrate is usually derived from them.
- Dietary fibre. Dietary fibre replaces crude fibre, so the analytical method and the recipe data behind the declaration need reviewing.
Because the box shows grams per serving and calorie sources, errors in recipe data become visible to buyers, retailers and regulators. It is worth verifying formulas by analysing finished product before the new artwork is finalised.
Action checklist
- List the US states you sell into and track each one’s adoption.
- Define the household unit for every SKU and weigh it on production samples.
- Confirm energy calculation method and analytical data for each recipe.
- Move to total dietary fibre data and derive the carbohydrate maximum.
- Draft the intended-use statement and front-panel layout.
- Review ingredient statement wording and parenthetical vitamin grouping.
- Plan artwork changes together with other scheduled pack updates.
The new label is coming state by state. Start with reliable calorie and fibre data — the artwork is the easy part.
05Questions brands ask
Do I have to change my label now?
AAFCO recommends about six years of enforcement discretion from the 2024 Official Publication, and states adopt the rule on their own schedules. Either format is accepted during the transition.
What data do I need for the new box?
Calories per household unit, a dietary fibre value and a carbohydrate maximum — so analysed moisture, protein, fat, ash and fibre values for each recipe.
Sources
- AAFCO (2023). AAFCO membership approves new model pet food and specialty pet food regulations. Source ↗
- AAFCO (2023). PFLM — Pet Nutrition Facts summary (PDF). Source ↗
- AAFCO (2023). PFLM — label comparison worksheet (PDF). Source ↗
- AAFCO (2023). PFLM enforcement recommendation letter (PDF). Source ↗
Evidence reviewed by the Guires Pet Nutrition Lab scientific team. This article is general information for product developers and is not legal or veterinary advice.
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Guires Pet Nutrition Lab. (2026, September 12). AAFCO label modernization: what the Pet Nutrition Facts box means for your pack. Guires Pet Nutrition Lab Insights. https://www.petnutritionlab.com/insights/aafco-label-modernization
Guires Pet Nutrition Lab. “AAFCO label modernization: what the Pet Nutrition Facts box means for your pack.” Guires Pet Nutrition Lab Insights, 12 Sep. 2026, www.petnutritionlab.com/insights/aafco-label-modernization. Accessed [date].
Guires Pet Nutrition Lab (2026) AAFCO label modernization: what the Pet Nutrition Facts box means for your pack. Available at: https://www.petnutritionlab.com/insights/aafco-label-modernization (Accessed: [date accessed]).
Guires Pet Nutrition Lab. “AAFCO label modernization: what the Pet Nutrition Facts box means for your pack.” Guires Pet Nutrition Lab Insights. September 12, 2026. https://www.petnutritionlab.com/insights/aafco-label-modernization.
Guires Pet Nutrition Lab, ‘AAFCO label modernization: what the Pet Nutrition Facts box means for your pack’, Guires Pet Nutrition Lab Insights, 12 September 2026, <https://www.petnutritionlab.com/insights/aafco-label-modernization>, accessed [date accessed].
Guires Pet Nutrition Lab. AAFCO label modernization: what the Pet Nutrition Facts box means for your pack [Internet]. Guires Pet Nutrition Lab Insights; 2026 Sep 12 [cited [date]]. Available from: https://www.petnutritionlab.com/insights/aafco-label-modernization
Guires Pet Nutrition Lab, “AAFCO label modernization: what the Pet Nutrition Facts box means for your pack,” Guires Pet Nutrition Lab Insights, Sep. 12, 2026. [Online]. Available: https://www.petnutritionlab.com/insights/aafco-label-modernization
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This article summarises published evidence for product developers. Cite the original sources above for specific findings, and do not reproduce this article as your own work.
Get your packs ready for the new label
Our Label Modernization Readiness service reviews your recipes, data and draft Pet Nutrition Facts box.