Are Your Pet/Specialty Pet Food Products Exempt from Regulation?

Requirements for Selling Pet/Specialty Pet Foods in Minnesota

There are three basic requirements for making and selling pet/specialty pet foods in Minnesota. Pet/specialty pet food can include treats, chews, and bones. The requirements are:

  1. You must have a Minnesota Commercial Feed License,
  2. You must register your products, or pay tonnage, with the Minnesota Department of Agriculture, and
  3. Your products must be labeled correctly

Conditions for Exempt Pet/Specialty Pet Products in Minnesota

Some chews, bones, and toys are exempt from the Minnesota Commercial Feed regulations. Exemptions are limited to the following when certain conditions are met:exempt pet rawhide pet chews

  • All chews, bones, toys, and exercisers made of animal skin, hide, wood, or man-made material
  • Hooves
  • Ears
  • Animal bones
  • Ligaments
  • Snouts
  • Pizzles or bully sticks

These products may be exempt from the Minnesota Commercial Feed regulations if:

  1. They contain no additional ingredients other than flavoring (smoking is allowed), and
  2. The product is free of pathogens such as Salmonella or other contaminants

If the labeling implies that the product supplies nutrition, the product is NOT exempt. Examples of common labeling claims that indicate nutrition include:

  1. The label or advertising makes any claim that the product is intended for use as an animal food (e.g., “food”, “treat”, “snack”, or similar designation)
  2. The label or advertising refers to the nutritional value of the product:
    • Displaying a guaranteed analysis
    • Nutrient claims such as “high in calcium” or “high in protein”
    • Other food claims such as “digestible” or “great source of energy”
Infographic showing examples of exempt and NOT exempt pet/specialty pet labels, as explained below

In these examples:

  • The "Pig Ear Dog Chew” label listing only the ingredient of pig ear and weight of 10 oz. is exempt since it doesn’t identify the chew as a food, treat, snack, or similar designation; and it doesn’t include nutritional information.
  • The “Pizzle Sticks Dog Treats” label stating, “High in Protein!” along with the ingredient of bovine pizzle and weight of 10 oz. is NOT exempt because it identifies the item as a treat and includes nutritional information.