Nearly all the attention on the FDA's newly proposed food ingredient rule has focused on what is in packaged human food. The proposal has a second half that almost no one is discussing, and it governs what goes into dog food, cat food, and the feed eaten by cattle, pigs, and chickens.
The proposed rule was announced by HHS on August 10, 2026, and published in the Federal Register the following day under docket number FDA-2025-N-3262. It would amend two parts of federal regulation: Part 170, which covers substances added to human food, and Part 570, which covers substances added to animal food. Comments are due December 9, 2026.
Both halves target the same thing. Since 1958, a company has been able to conclude that an ingredient is generally recognized as safe and begin selling it without ever telling the FDA. The proposal would require notification.
Seventy-Five Notices Across a Whole Sector
The scale of the gap on the animal side is easier to see than on the human side, because the FDA's own filing numbers are so small.
According to figures cited in the proposed rule, the agency has received more than 1,200 GRAS notices since the program began as a pilot, including over 670 since January 2016. The FDA's Center for Veterinary Medicine, which handles animal food, had filed 75 animal food notices as of March 2025.
Seventy-five notices, for a sector that supplies feed to the entire US livestock industry and food to tens of millions of household dogs and cats.
That number does not represent 75 ingredients entering animal food. It represents the ones anyone told the FDA about. The unknown quantity, on both the animal and human sides, is how many substances went to market based on self-affirmed conclusions that generated no federal record at all.
Feed Additives Do Not Stay in the Feed
The reason this belongs in a health story rather than an agriculture trade publication is that the animal and human food supplies are not separate systems.
Federal regulation already recognizes this. Under the sections of Part 570 governing general recognition of safety in animal food, a conclusion based on common use requires a substantial history of consumption by a significant number of animals of the species being fed. For food-producing animals, it also requires a substantial history of human consumption of the foods derived from those animals.
That second clause is the tell. A substance fed to beef cattle is evaluated partly by what happens to people who eat the beef, which is why the animal half of this proposal is not a separate story from the human half.
The proposed animal food provisions largely mirror those for human food, with a few notable differences, according to a regulatory analysis by Covington and Burling. The animal provisions omit the food contact notification pathway and the threshold-of-regulation exemption, which are specific to human food. For substances intended for food-producing animals, the streamlined submission option would additionally require the quantities of any residues humans may be exposed to in edible animal tissues.
What the Rule Would Not Do
The proposal is being described in some coverage as closing a loophole, and the framing overstates what it accomplishes.
The FDA maintains that it is not proposing a premarket approval requirement because substances may go to market before the agency reviews the notification. The FDA also does not assert that failing to submit a notice would render a food adulterated or otherwise in violation of federal law. Instead, the agency says such a failure would be a factor it considers when prioritizing food substances for post-market review.
That is a transparency- and triage-mechanism rather than a gatekeeping one. It would give the FDA a fuller inventory of what is entering the food supply and a basis for deciding where to look first, which is a real improvement over not knowing. It would not require anyone to wait for a federal decision.
The HHS fact sheet describes the goals in those terms: requiring notification, expanding the existing public inventory of submitted notifications, improving the agency's visibility into ingredients entering the food supply, and enabling greater post-market oversight.
Nothing Changes Yet, and the Timeline Is Long
This is a proposed rule, not a law. The FDA must review public comments and issue a final rule before anything binds a manufacturer.
For substances already on the market under prior self-affirmed conclusions, the proposal establishes a time-limited, streamlined submission pathway—a one-year window—allowing manufacturers to notify the FDA of existing uses while the agency prioritizes post-market safety evaluations.
Inclusion on any resulting FDA inventory would not mean the agency has determined a substance is safe, and the FDA could still require a full GRAS notice or a food additive petition later.
The announcement also does not mean that ingredients now in food or feed have been found unsafe. It means the agency wants a record of them. Pet owners should not reinterpret their dog's food based on a rulemaking notice, and the existing tools remain the same: required ingredient statements on packaged food, the FDA's public inventories of both human and animal GRAS notices, and a veterinarian or physician for questions about a specific animal or person.
Members of the public can submit comments on the docket through the federal rulemaking portal until December 9, 2026.
Key Questions Answered
What is GRAS?
Generally recognized as safe. Since 1958, companies have been able to conclude on their own that an ingredient meets that standard and market it, historically without any obligation to tell the FDA.
What would the proposed rule change?
It would require companies to notify the FDA when they conclude that a substance added to human or animal food is GRAS, unless an exception applies, and would expand the public inventory of those notifications.
Does the proposal apply to pet food and livestock feed?
Yes. It would amend Part 570, which covers substances added to animal food, alongside Part 170 for human food. The animal provisions largely mirror the human ones with a few technical differences.
How many animal food GRAS notices exist?
The FDA's Center for Veterinary Medicine had filed 75 animal food notices as of March 2025, out of more than 1,200 GRAS notices overall since the program began as a pilot.
Would this create premarket approval?
No. The FDA states it is not proposing premarket approval because substances could still go to market before the agency reviews a notification. Failure to notify would be a factor in prioritizing post-market review rather than an automatic violation.
When would any of this take effect?
Not soon. This is a proposed rule. Comments are due December 9, 2026, and the FDA must review them and issue a final rule first. Substances already on the market would have a time-limited streamlined pathway described as a one-year window.
Does this mean current food or feed ingredients are unsafe?
No. The proposal is about creating a federal record of what enters the food supply, not about finding any specific substance.
