The international magazine for the pet food packaging industry
This is because new requirements for packaging design, material use and producer responsibility are also emerging on the other side of the Atlantic. For pet food manufacturers and retailers exporting to these markets in particular, the question is: what rules apply there and what will they have to prepare for from 2025?
A patchwork quilt with a system: the USA
Anyone who wants to bring products to market in the United States is not only confronted with regulations at federal level, but also with a growing catalog of state laws. This applies to packaging materials as well as environmental requirements, recycling targets and labeling obligations.
At federal level, it is particularly the requirements of the Food and Drug Administration (FDA) that regulate the import of pet food. Companies must register there, possibly undergo inspections and prove that their products are safe and correctly labeled. The definition of “safe” in the USA is sometimes narrower than in the EU. It is not just about toxicological safety, but also about correct analytical declarations, traceability and compliance with manufacturing processes. Responsibility lies with the manufacturer, who can be held liable in case of doubt.
In addition, there is the Foreign Supplier Verification Program (FSVP), which obliges US importers to verify the conformity of foreign manufacturers with US law. Anyone exporting must therefore not only keep an eye on their own requirements, but also understand the requirements of their partners on the US side. Documentation requirements, audits and supplier declarations have become the norm for exporters. Those who do not implement these steps conscientiously risk serious consequences: From import delays to contract terminations to legal disputes.
The PURR Act: uniform rules or an industry-driven step backwards?
In January 2025, the “Pet Food Uniform Regulatory Reform Act of 2025” (PURR Act) was introduced in the US Congress. This is intended to replace the fragmented regulation of pet food with centralized supervision under the FDA. The industry, in particular the Pet Food Institute (PFI) lobby group, welcomes the move: uniform labeling rules at last, no multiple inspections in different states. The argument: uniformity creates investment security, strengthens smaller suppliers and facilitates innovation.
However, critics such as the Association of American Feed Control Officials (AAFCO) warn that the PURR Act could undermine established transparency standards. To date, the FDA has hardly been involved in the practical monitoring of animal feed. Many states have developed their own systems, some of which have higher requirements. If these were replaced by a centralized but underfunded authority, consumers and animals would potentially be worse off. Some NGOs even fear deregulation through the back door, particularly with regard to additives and certificates of origin.
California gets serious: SB 54 and the impending polystyrene ban
The western state of California is often regarded as a regulatory pioneer - and as a test market for national developments. With the SB 54 law passed in 2022, California has created a comprehensive framework to combat plastic pollution. Manufacturers are required to demonstrate the recyclability, material use and recyclability of their packaging. The state also requires detailed reports on the materials used, their recycling rates and the use of recyclates. Those who fail to register or disregard the requirements risk severe penalties.
One particularly controversial point: polystyrene - known under the brand name Styrofoam - must achieve a recycling rate of 25 percent by 2025. If this is not achieved, a ban will come into force. In view of the current low recycling rate, this scenario is considered likely. Packaging made from expanded polystyrene would then be de facto banned from the Californian market. For manufacturers, this is not only a technical challenge, but also a strategic one: if they want to continue supplying this huge market, they will have to rethink their material decisions.
EPR is coming: producer responsibility becomes mandatory
In addition to California, Oregon, Colorado and Maine have also passed laws on Extended Producer Responsibility (EPR). Producers (including importers) will have to participate in the financing and organization of collection, sorting and recycling infrastructure from 2025 and 2026 respectively. The details differ: some countries require membership of a so-called Producer Responsibility Organization (PRO), others rely on direct levies. Others link EPR to further obligations such as recycling labeling or education campaigns.
For companies with US-wide sales structures, this means that they have to meet different requirements depending on the target state - and may have to register in several states. If you are not careful here, you risk fines or import bans. At the same time, new market opportunities are emerging: providers of digital tracking and reporting solutions or sustainable packaging alternatives are more in demand than ever.
PFAS, labels, nutritional value tables
Another aspect is ingredient bans. Minnesota, for example, is banning intentionally added PFAS in numerous product categories, including packaging, from 2025. These chemicals, often used in greaseproof materials, are highly persistent and hazardous to health. Other states such as Vermont, Maine and California are also working on similar regulations. The industry is under pressure to find alternatives - and to document this scientifically.
New requirements for label design and transparency are also being introduced in many states. A kind of “nutritional table” for animal feed is intended to help consumers better classify ingredients. Information on storage and intended use is also to become clearer and more standardized. What has long been standard on EU products is now also being introduced in the USA - albeit without central specifications. The result: labels that are permitted in Florida have to be adapted for California. A logistical and graphic tour de force.
Canada: More uniform, but no less demanding
US’ northern neighbor takes a more centralized approach. With the Feeds Regulations, 2024, adopted in July 2024, the Canadian Food Inspection Agency (CFIA) is comprehensively modernizing its regulations. For the first time, risk-based inspection is enshrined in law, which is based on HACCP standards and emphasizes the responsibility of producers.
The new regulations come into force in several stages:
The aim is to increase the safety of animal feed, prevent fraud and harmonize international standards. For European exporters, this means one thing above all: documentation. The requirements for traceability, risk assessment and labeling are increasing significantly. At the same time, Canada is relying on digital platforms to simplify approvals and reports. Those who invest here can benefit from accelerated approval procedures in the long term.
Recycling targets and recyclate quotas
Canada is also following suit in the environmental sector. The government is planning binding minimum quotas for recycled content in packaging:
These regulations are part of the national zero plastic waste strategy. Many details are still under discussion, but the course is clear: Canada is also shifting responsibility for packaging to manufacturers. In practice, this means looking for new suppliers, monitoring material flows and providing proof of quality. Smaller suppliers in particular could reach their limits here.
Trade barriers and strategic pitfalls
For companies exporting pet food to North America, these developments mean one thing above all: complexity. It is not enough to meet the requirements of one country. In the USA, several states often have to be considered individually. Packaging materials that are permitted in Texas may be prohibited in California. A label that is sufficient in Georgia may not meet the requirements of New York.
In Canada, the situation is somewhat clearer, but the requirements there are also high - particularly in terms of product safety and documentation. If you don’t have a robust compliance structure here, you risk more than just administrative work: imports can be blocked, products taken off the shelves or reputational damage caused. International certifications such as GMP+, ISO 22000 or FSC for packaging can make access easier - but they are not a free pass.
Lots of movement, little coordination
Compared to the EU, North America appears fragmented in regulatory terms. While Brussels has created a uniform framework for 27 member states with the PPWR, US regulation follows a two-track approach: national minimum standards combined with state-specific special approaches.
This structure not only makes market access more difficult for foreign suppliers, but also hinders progress in environmental protection. Packaging is a global issue - and yet the USA lacks a binding, comprehensive approach. At least there are numerous pilot projects at regional level, for example for compostable packaging or pay-as-you-throw models. However, it is likely to be a long time before a national system emerges.
Canada is taking a more structured approach, but is relying primarily on industry taking responsibility. In both cases, it is clear that the time is ripe for uniform, internationally compatible standards. Until then, importers need to keep their eyes open, monitor compliance and respond to regional requirements at an early stage. Those who fail to do so will pay the price later - be it with recalls, fines or missed market opportunities.
A market in flux
Regulations in North America are in a state of flux. For pet food manufacturers from Europe, this means that now is the right time to review packaging strategies and product labeling. Those who act early can minimize regulatory risks - and at the same time position themselves as pioneers for sustainable, transparent and legally compliant products. The effort is high. But access to two of the world’s most important markets justifies the investment. And those who learn to navigate the jungle of North American rules in good time will not only have a competitive advantage in the end, but also a better reputation.
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