Changes

Products substantiated by the latter two methods may be subject to re-substantiation upon any changes to the formulation or after 5 years on the market. The label for pet foods that fail to meet AAFCO requirements by any of the three standard methods (feeding trial, product family or formulation) and is not prominently identified as a snack, treat, or supplement must bear the statement: This product is intended for intermittent or supplemental feeding only.

Products substantiated by the latter two methods may be subject to re-substantiation upon any changes to the formulation or after 5 years on the market. The label for pet foods that fail to meet AAFCO requirements by any of the three standard methods (feeding trial, product family or formulation) and is not prominently identified as a snack, treat, or supplement must bear the statement: This product is intended for intermittent or supplemental feeding only.

Veterinary therapeutic foods, which are intended for use by or under the supervision or direction of a veterinarian, must be substantiated for nutritional adequacy by one of the above methods or its label must bear the "intermittent or supplemental" statement as required for all dog and cat foods. However, labels for these foods may bear the statement ‘use only as directed by your veterinarian’ in lieu of feeding directions. Technically, veterinary therapeutic foods are drugs as defined by FFDCA, and have not undergone the approval process as required by the law for drugs. However, FDA exercises enforcement discretion in not taking action against these products provided they meet [http://www.fda.gov/downloads/ICECI/ComplianceManuals/CompliancePolicyGuidanceManual/UCM318761.pdf FDA's guidelines].

Veterinary therapeutic foods, which are intended for use by or under the supervision or direction of a veterinarian, must be substantiated for nutritional adequacy by one of the above methods or its label must bear the "intermittent or supplemental" statement as required for all dog and cat foods. However, labels for these foods may bear the statement ‘use only as directed by your veterinarian’ in lieu of feeding directions. Technically, veterinary therapeutic foods are drugs as defined by FFDCA, and have not undergone the approval process as required by the law for drugs. However, FDA exercises enforcement discretion in not taking action against these products provided they meet the [http://www.fda.gov/downloads/ICECI/ComplianceManuals/CompliancePolicyGuidanceManual/UCM318761.pdf FDA's guidelines].

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