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Labels & Ingredients

Which Pet Food Terms Have Legal Definitions (and Which Anyone Can Use)

Updated July 30, 2026

A dog's paws rest beside a bowl heaped with kibble on a wooden floor, viewed from above.
Mathew Coulton / Pexels

By Morgan Reyes

The Short Answer

Three front-of-bag words get treated as one category, "marketing language," and they aren't. Two of them are real, enforceable AAFCO definitions. A third is a word AAFCO has never defined at all.

TermLegal statusWhat it actually requires
"Natural"Defined, permissiveNo chemically synthetic processing or additives, with a carve-out for synthetic vitamins/minerals. Most ingredients already qualify.
"Human grade"Defined, strictThe whole product manufactured in a licensed human-food facility under federal food-safety rules, audited annually.
"Premium," "holistic," "gourmet"UndefinedNothing. Any manufacturer can print any of these on any bag.

The word that sounds softest ("premium") and the word that sounds warmest ("holistic") both carry zero legal weight. The word that sounds like a technicality ("human grade") is the one that actually constrains a manufacturer. Read past the tone of a word to find out which tier it's in.

"Natural" is defined, and the definition barely narrows anything

AAFCO does define "natural," and its own description of that definition is the most useful sentence on this topic.

The definition itself, quoted in full:

"a feed or feed ingredient derived solely from plant, animal or mined sources, either in its unprocessed state or having been subject to physical processing, heat processing, rendering, purification, extraction, hydrolysis, enzymolysis or fermentation, but not having been produced by or subject to a chemically synthetic process and not containing any additives or processing aids that are chemically synthetic except in amounts as might occur in good manufacturing practices."

An exception covers synthetic vitamins, minerals, and trace nutrients (taurine, amino acids) needed to make the food nutritionally complete. Use that exception and the label has to say so, with wording like "natural with added vitamins and minerals."

Here's the sentence that matters more than the definition itself. AAFCO's own page calls "natural" "a liberal term that includes more ingredients than it excludes", and states plainly that most pet food ingredients already qualify, since almost everything is "derived from plant, animal or mined sources" one way or another. A feed ingredient can go through physical processing, heat, rendering, purification, extraction, hydrolysis, enzymolysis, or fermentation, and still clear the bar.

So "natural" is not a loophole. It's a real rule. It's just a rule that was written to permit nearly everything already happening in pet food manufacturing, which is why seeing it on a bag tells you almost nothing about what's actually inside.

"Human grade" is the strict one, and it's not new

This is the one word on this list that genuinely restricts a manufacturer, and it dates to January 2023, not to any 2026 change.

AAFCO announced the human-grade pet food standard on 12 January 2023, with the guidance document and appendices published two weeks later. If a bag carries this claim today, it's following a three-year-old standard, not new news.

What it actually requires, quoted from AAFCO's own standard document:

"The feed term specifies that every ingredient and the resulting product must be stored, handled, processed, and transported in a manner that is consistent and compliant with 21 CFR part 117 and all other applicable federal human food law."

That's the whole product, not one ingredient picked for the marketing copy. The standard goes further than most consumer-facing summaries let on:

  • The facility itself must be licensed and inspected as a human food facility, not just an animal food facility, whenever the final product is "ready-to-eat."
  • A GMP-equivalency audit under 21 CFR Part 117 runs annually, through USDA's Agriculture Marketing Service Process Verified Program, unless another agency already inspected the facility that year.
  • The manufacturer has to keep records proving it, on request: that every ingredient is fit for human consumption, that storage and transport stayed compliant the whole way through, and that the facility holds the right human-food license.
  • A claim of "human grade ingredients" is only allowed if the whole product meets the standard. Naming one human-grade ingredient inside a product that doesn't otherwise qualify isn't a legal use of the term.

One correction worth making explicitly, because two separate 2023 AAFCO actions get conflated constantly. The human-grade standard (January 2023) is not the same action as the Pet Food Label Modernization (AAFCO membership approval 31 July 2023), which replaces the Guaranteed Analysis with a Pet Nutrition Facts box over a transition running to roughly 2030. One is an ingredient/manufacturing standard. The other is a label-format overhaul. They happen to share a year and nothing else.

The words that mean nothing at all

"Premium," "holistic," and "gourmet" carry no legal definition. Not a loose one. None.

AAFCO's own FAQ page says this about "premium," directly and without hedging:

"Unlike natural and organic, 'premium' is a totally unregulated term in feed law. Whereas premium gasoline must meet higher octane standards than regular gasoline, premium pet food doesn't have special requirements that differ from any other pet food."

That's AAFCO picking its own comparison. A gas station has to clear a number to use the word. A pet food bag doesn't clear anything.

"Holistic" is the more telling case, because the evidence here is an absence rather than a quote. The word appears on neither AAFCO's ingredient-definitions page nor its consumer FAQ page (the same two pages that do carry full entries for "natural," "human grade," and "premium"). An association that writes rules for a term publishes a page about it. "Holistic" has none, on either page checked. That silence is the finding: if AAFCO had a rule for it, there would be a page to quote.

"Gourmet" sits in the same undefined tier. None of these three words restricts what a manufacturer can put in the bag, how it's processed, or where it's made. They're free to use, on any food, for any reason.

Worth saying plainly

A front-of-bag word tells you nothing about its own strictness just by how it sounds. "Human grade" sounds like industry jargon and turns out to be the one word backed by facility licensing and an annual audit. "Holistic" sounds like it should mean something caring and comprehensive, and AAFCO has never written a single word about it.

Read the word, then ask which tier it's actually in. Strict-and-defined, permissive-and-defined, or undefined and free to print on anything.

Bottom line: three front-of-bag words get treated as one undifferentiated category, and they aren't. "Natural" is a real AAFCO definition that permits nearly everything already happening in manufacturing. "Human grade" is a real, strict standard requiring a licensed human-food facility and an annual audit, dating to January 2023. "Premium," "holistic," and "gourmet" carry no legal definition at all, and AAFCO's own pages are the proof: one calls "premium" totally unregulated outright, and "holistic" doesn't appear on either page at all.

FAQ

Does "natural" on a pet food bag mean anything?

Yes, and it's genuinely permissive rather than empty. AAFCO's definition excludes chemically synthetic processes and additives (with a synthetic-vitamin/mineral carve-out), but AAFCO's own page calls it "a liberal term that includes more ingredients than it excludes."

Is "human grade" pet food actually regulated, or is it marketing?

Regulated, and strictly. The whole product has to be made in a licensed human-food facility under 21 CFR Part 117, audited annually. See the full requirement above. The standard dates to January 2023.

Is "holistic" a real standard on pet food?

No. The word appears on neither of AAFCO's own consumer-facing definition pages, the same two pages that do define "natural," "human grade," and "premium." No rule, no page.

Is "premium" pet food actually better?

Not by any legal standard. AAFCO's own FAQ calls it "a totally unregulated term in feed law," comparing it unfavorably to premium gasoline, which does have to clear a real bar.

Did the 2023 pet food label changes affect any of these terms?

No. The human-grade standard (January 2023) and the Pet Food Label Modernization (approved 31 July 2023, the Guaranteed Analysis becoming a Pet Nutrition Facts box) are two separate AAFCO actions that happen to share a year. Neither touches "natural," "premium," or "holistic."

Keep reading

A Note on Scope

This guide explains labeling terminology and consumer-protection rules. It is not veterinary advice, makes no health or nutrition claim about any product, and does not recommend a brand.

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