What Changed in the Commercial Feed and Pet Food Regulations?

As noted in the Director’s Digest, the revised commercial feed and pet food regulations are now in effect. Many of you may want to know what changed without having to sit down and compare the old to the new and we will summarize the major changes in the table below. The regulations for our Feed Program were last updated in 1999 so we were certainly due for a revision. There are no changes in fees as these are set in the law instead of in the regulations.

The American Association of Feed Control Officials (AAFCO) has put forth a model bill and regulations and encourages all states to adopt this to make it easier for businesses to conduct commerce in multiple states. This model bill has been endorsed by the American Feed Industry Association, National Grain and Feed Association, and Pet Food Institute. Part of our update was to make our regulations more in line with this model bill.

Kentucky legislative rules will not allow for referencing the “most recent” edition of a set of guidelines so you must reference a particular year. Our previous regulations reference the 1996 Official Publication (OP) of AAFCO, this has been updated to the 2018 OP for these revised regulations.


Commercial Feed Regulations




12 KAR 2:006


Updated OP Reference.

12 KAR 2:011

Label format

No changes.

12 KAR 2:016

Brand and product Names

Added raw milk reference.

12 KAR 2:017

Product purpose statement

Removed Direct Fed Microbial reference to place elsewhere.

12 KAR 2:018

Guaranteed analysis

Added option for maximum ADF (in place of crude fiber) for multiple species; maximum ADF and NDF required for equine feeds; updated equine animal classes; separate sheep and goat requirements with maximum ADF required for goats; updated OP reference.

12 KAR 2:021

Guarantees (title changed to Expression of guarantees)

Added mineral phosphatic materials; added section on dietary starch, sugars and fructans; added reference to Analytical Variation table to determine violations; Direct Fed Microbial reference moved here.

12 KAR 2:026


Removed Section 8 (Rice Hulls) and Section 9 (Magnesium BV); updated OP reference.

12 KAR 2:031

Directions and precautionary statements for feed containing additives (title changed to Directions for use and precautionary statements).

Added required labeling for feeds containing raw milk.

12 KAR 2:036

Non-protein nitrogen

Added language required on labeling for feeds containing non-protein nitrogen.

12 KAR 2:041

Drug and feed additives

Modified language to match AAFCO model bill; updated OP reference.

12 KAR 2:046

Poisonous or deleterious substances

Added statement about deleterious substances “not limited to” the ones listed.





12 KAR 2:051

Manufacturing conditions

Modified language to match AAFCO model bill including references to FSMA regulations.

12 KAR 2:056

List of manufacturers

Instead of purging files on January 1 of each year, list of manufacturers will be evaluated quarterly and removed as needed

12 KAR 2:061


Updates “Application for Registration of Commercial Feeds” from March 1999 version to 2018 version.

12 KAR 2:066


Updated NRC references to the most current versions.


Pet Food Regulations




12 KAR 3:007

Definitions and term

Added “specialty pet food”, “all life stages”, “family”.

12 KAR 3:012

Uniform labeling format (changed to Label format and labeling)

Multiple changes to match AAFCO model bill including a  table on Minimum Warning Statement Type Size.  Updated OP reference.

12 KAR 3:017

Brand and product names

Multiple changes to match AAFCO model bill including table on type size.

12 KAR 3:022

Guarantees (title changed to Expression of guarantees)

Multiple changes to match AAFCO model bill including table on type size.

12 KAR 3:027


Qualifications for using the terms “meat” or “meat byproducts”; updated OP reference.


12 KAR 3:028

Descriptive terms

New regulation dealing with terms such as “lite”, “less fat”, “reduced carbohydrates”.

12 KAR 3:032

Directions for use (title changed to Feeding directions)

Added sections on labeling products as “complete and balanced”; foods labeled to be fed under veterinary supervision; updated OP reference.

12 KAR 3:037

Additives (title changed to Drugs and feed additives)

Main change was to add the term “specialty pet food” and updated OP reference.

12 KAR 3:039

Nutritional adequacy

New regulation spelling out the intended usages of the pet food such as “all life stages”.

12 KAR 3:042

Statement of caloric content (title changed to Statements of calorie content)

Statement of calorie content is required for all dog and cat snacks, treats, and foods.  Defines how “calorie content” statements should appear.  Updated OP reference.

The intent of these tables is just to provide a quick overview of changes made in the regulations. Pet food regulations have changed the most since the last revision. The new regulations are now available on our website and we encourage you to become familiar with these as soon as possible.