The AAFCO Human Grade Standard references 21 CFR Part 117 — U.S. federal human food law. This page maps every substantive requirement to its Canadian federal and provincial equivalent, so Canadian brands and manufacturers can document a defensible human grade claim.
The AAFCO Human Grade Guidelines (2022) require that every ingredient and the finished product be stored, handled, processed, and transported in compliance with 21 CFR Part 117 and applicable federal human food laws. Nothing in the standard's language mandates that manufacturing occur within the territorial United States. The FPFA's position — consistent with how the majority of U.S. state feed control officials have already applied the standard — is that the reference to 21 CFR Part 117 establishes the quality of manufacturing practice required, and that Canadian manufacturers operating under equivalent federal and provincial human food laws fully satisfy it.
The six core requirements of the AAFCO standard: (1) all ingredients fit for human consumption and handled under human food conditions; (2) the facility licensed for human food production by an appropriate authority; (3) FDA registrations for both human food and animal food; (4) annual inspection or equivalency audit by an authority with enforcement power; (5) written procedures preserving human grade status through distribution; (6) labels compliant with AAFCO requirements.
The Safe Food for Canadians Act & Regulations (SFCA/SFCR), administered by the CFIA — mandatory HACCP-based preventive control plans, traceability, and licensing for import, export, and interprovincial trade.
In Ontario: the Food Safety and Quality Act, 2001 and O.Reg 31/05 (Meat), administered by OMAFRA/OMAFA — facility licensing, sanitation, process controls, personnel hygiene, temperature management, and traceability. Other provinces maintain analogous frameworks.
FPFA member facilities additionally hold GFSI-benchmarked certification — SQF Edition 9, BRCGS, or FSSC 22000 — internationally recognized as meeting or exceeding 21 CFR Part 117.
Each substantive requirement of 21 CFR Part 117 mapped to its parallel under Canadian law. Provincial citations reference Ontario's framework as a representative example; analogous provisions apply in other provinces.
| 21 CFR Part 117 | Canadian parallel | Canadian requirement |
|---|---|---|
| Subpart A — GeneralFacility registration & applicability | SFCA/SFCR + O.Reg 31/05 | Mandatory facility licensing under the applicable provincial authority (e.g., Freestanding Meat Plant licence in Ontario); SFCR licence for import/export. |
| §117.10Personnel: disease control, cleanliness, training | O.Reg 31/05 Part VII, s.53 | Personnel hygiene requirements: hand washing, clean clothing, health requirements for all personnel handling food products. |
| §117.20Plant & grounds: maintenance, pest control | O.Reg 31/05 s.42, 46–50 | Written maintenance, sanitation, and pest control programs; cleaning with hot water and detergent; potable water rinse and sanitization. |
| §117.35Sanitary operations | O.Reg 31/05 s.47–50 | Written sanitation program; thorough cleaning as often as necessary to maintain a hygienic environment and prevent contamination. |
| §117.37Sanitary facilities: water, plumbing, handwashing | O.Reg 31/05 s.42(a); Building Code Act | Facilities maintained to facilitate hygienic operation; potable water supply required. |
| §117.40Equipment & utensils | O.Reg 31/05 s.46, 50 | Written maintenance program for premises, equipment, and utensils; equipment must facilitate hygienic operation. |
| §117.80Processes & controls | O.Reg 31/05 s.92–97 | Prohibition on non-compliant processing; written recipes; hazard identification and control; monitoring and verification. |
| §117.93Warehousing & distribution | O.Reg 31/05 s.51, 96, 134 | Temperature/humidity controls; handling and storage to prevent contamination; comprehensive transport container standards. |
| Subpart C — Hazard Analysis & Preventive ControlsHACCP-based preventive controls | O.Reg 31/05 s.93 + SFCR Div. 4 | Mandatory hazard identification, control procedures, monitoring, deviation records, corrective actions, verification through sampling and testing; SFCR Preventive Control Plans for import/export. |
| Subpart D — Modified RequirementsQualified facilities / small business | O.Reg 31/05 facility categories | Category-based licensing with requirements scaled to risk level. |
| Subpart G — Supply-Chain ProgramSupplier verification | O.Reg 31/05 s.101 + SFCR import | Strict entry controls for all ingredients; ingredients must come from licensed facilities with inspection legends; SFCR import requirements for foreign ingredients. |
| §117.150Recordkeeping | O.Reg 31/05 s.93(e,g), s.98 | Records of monitoring and deviations kept minimum one year on premises; cooking/fermentation/smoking time and temperature records required. |
The clearest proof that Canadian human food law is equivalent to U.S. federal human food regulation is that the United States itself trusts it to protect American consumers.
USDA-FSIS has formally determined Canada's meat and poultry inspection system equivalent to the U.S. system. Canadian shipments are the only foreign products that don't receive the USDA reinspection mark at U.S. ports of entry — a level of trust no other country receives. Canadian ready-to-eat meat products — the exact category FPFA members manufacture — enter the U.S. market under this framework.
Under the Food Safety Systems Recognition Arrangement, the FDA formally recognizes Canada's food safety system as comparable — only the second country in the world to receive this. Canadian facilities with SFCR licences export processed foods directly to the U.S. for human consumption with no additional U.S. facility audit or 21 CFR Part 117 inspection.
AAFCO's own standard requires an AMS Process Verified Program audit "unless the facility has been inspected for compliance by an agency with enforcement authority... within the last year." Canadian provincial regulators inspect human food facilities routinely, with full statutory power to suspend licences, seize product, and prosecute — squarely satisfying the standard's own exception.
The logical inconsistency: if Canadian provincial inspection were insufficient for a voluntary pet food marketing claim, the U.S. should logically also refuse provincially inspected products for human consumption. It does not — American families eat them every day.
For each element of the AAFCO Human Grade Standard, the corresponding documentation held by an FPFA Certified Human Grade manufacturer — available to state feed control officials and AAFCO representatives on request.
| AAFCO requirement | FPFA-certified manufacturer compliance |
|---|---|
| Ingredients fit for human consumptionStandard 1 | All ingredients sourced from approved human food suppliers; specification sheets and supplier guarantees on file. Under the provincial meat-plant licence, only ingredients meeting human food regulation are permitted in the facility. |
| Human food facility licensingStandard 2 | Provincial Freestanding Meat Plant (or equivalent) licence in the highest applicable category, licensed for cooking and preparation of ready-to-eat meat products for human consumption. |
| FDA facility registrationsStandard 2b | FDA Food Facility Registration (human food) and FDA Animal Food registration, plus applicable U.S. state commercial feed licences. |
| Annual inspection by enforcement authorityStandard 3 | Routine provincial inspections under Food Safety legislation with full enforcement authority — satisfying the "unless" clause. Most recent inspection date maintained on file. |
| Third-party food safety certification | Current GFSI-benchmarked certification — most commonly SQF Edition 9 (Section 8: Manufactured Meats), BRCGS, or FSSC 22000. |
| Written procedures for distributionStandard 4 | Written Food Safety / HACCP Plan consistent with provincial, CFIA, and GFSI requirements; documented, verifiable cold chain SOPs. |
| Ready-to-eat productStandard 4b | Products meet the provincial regulatory definition of ready-to-eat: processed sufficiently to inactivate pathogens, safe for human consumption without further heating. |
| Label complianceStandard 6 | Clearly labeled for intended use as animal food; "human grade" coupled with a statement of intended use (e.g., "human grade dog food"). |
| SFCR import licence | Safe Food for Canadians Licence held where food ingredients are imported — assuring human-consumption quality standards. |
| Export capability | CFIA Pet Food Export Licence maintained where products are exported to the U.S., confirming federal-level authorization. |
Each FPFA-certified manufacturer additionally maintains a Manufacturer Letter of Guarantee formally attesting to compliance with 21 CFR Part 507 (animal food) and 21 CFR Part 117 (human food) manufacturing practices as applicable.
The complete policy position — including the requested AAFCO Board action and the full legal analysis — addressed to the AAFCO Board of Directors and member state feed control officials, May 2026.
This page summarizes the FPFA's policy position for general information. It is not legal advice; brands and manufacturers should confirm requirements with the relevant regulators and their own counsel.
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