For a broader overview of the proposed reform, see REACH24H’s analysis of the FDA GRAS Proposed Rule 2026.
What Would Change for Animal Food GRAS?
Under the current framework, a company may independently conclude that an intended use of an animal food ingredient is Generally Recognized as Safe (GRAS) without submitting a GRAS notice to FDA.
The proposed rule would change this approach. If finalized, companies introducing substances into interstate commerce under the animal food GRAS provision would generally need to notify FDA unless one of the specified exceptions applies. More information on the current animal food GRAS framework is available through the FDA’s GRAS Notification Program for Animal Food.
FDA proposes that a final rule would become effective 60 days after publication, with an 18-month compliance period for the new mandatory notification requirement.
Companies comparing human food and animal food GRAS pathways can also review REACH24H’s analysis of the key differences between FDA GRAS for feed and food.
Why AAFCO SRIS Matters
The Scientific Review of Ingredient Submissions (SRIS) program was established by the Association of American Feed Control Officials (AAFCO) and Kansas State University Olathe after the FDA–AAFCO Memorandum of Understanding expired in October 2024.
SRIS began accepting applications in 2025 for new animal food ingredient definitions and modifications to existing definitions. AAFCO provides further information on the Scientific Review of Ingredient Submissions (SRIS) program.
Under proposed § 570.205(b)(6), however, the GRAS notification exception would apply specifically to ingredients:
listed in and used in accordance with Chapter 6 of the 2024 AAFCO Official Publication; and
not subject to a public FDA statement expressing concern about their GRAS status.
Because FDA’s proposal refers specifically to the 2024 edition, ingredients added to later AAFCO Official Publications through SRIS would not automatically fall within this exception.
This does not mean that an SRIS-reviewed ingredient is prohibited. Rather, companies may need to separately assess whether a GRAS notice or another federal pathway is required.
AFIC May Receive Different Treatment
FDA’s proposal also provides an exception for certain ingredients reviewed through an established FDA animal food ingredient consultation process.
Under proposed § 570.205(b)(5), a GRAS notice would not be required where FDA has reviewed the intended use and publicly indicated that it has no questions or concerns about the safety of the substance for that use.
This may include qualifying outcomes under FDA’s Animal Food Ingredient Consultation (AFIC) process.
The practical distinction is:
Pathway | Proposed Treatment |
|---|---|
2024 AAFCO Official Publication, Chapter 6 | May qualify for an exception |
Qualifying AFIC consultation | May qualify for an exception |
AAFCO SRIS / later AAFCO OP editions | Not automatically covered by the 2024 exception |
Independent GRAS conclusion | Would generally require notification if finalized |
The full proposed rule is available in the Federal Register: Substances Generally Recognized as Safe.
Impact & Actionable Advice
Animal food ingredient suppliers, feed manufacturers and pet food companies should consider several actions:
Review the federal regulatory basis for existing and planned ingredients rather than relying solely on AAFCO status.
Reassess ongoing SRIS projects against the proposed GRAS notification requirements.
Compare GRAS, AFIC and SRIS pathways early, taking into account the ingredient, intended use, safety data and commercialization strategy.
Do not treat the proposal as current law. The existing GRAS framework remains in effect until FDA completes the rulemaking.
Monitor the final rule closely, particularly whether FDA changes the treatment of SRIS or later editions of the AAFCO Official Publication.
For companies developing novel proteins, fermentation-derived ingredients, functional pet food ingredients or other innovative animal food substances, early pathway planning can help avoid duplicated regulatory work.
How REACH24H Can Help
REACH24H supports companies evaluating U.S. market-access pathways for animal food, feed and pet food ingredients, including:
animal food ingredient regulatory pathway assessment;
FDA GRAS notice strategy and dossier preparation;
AAFCO SRIS pathway assessment;
AFIC strategy and technical support;
safety-data gap analysis and toxicological assessment; and
coordination of federal and state-level requirements.
Companies requiring broader support with U.S. GRAS submissions can learn more about REACH24H’s U.S. FDA GRAS Services.
If you are developing an animal food, feed or pet food ingredient for the U.S. market, contact REACH24H to assess whether FDA GRAS notification, AAFCO SRIS, AFIC or another pathway is appropriate for your ingredient and intended use.
