There’s No Such Thing as “Pet Food Grade” Meat — Legally, It’s Either Human Food or It’s Condemned
Most pet owners assume there’s a middle category of meat — not quite good enough for people, but a legitimate, purpose-built “pet food grade.” Under federal law, that category doesn’t exist.
Edible or inedible: there is no third option
USDA regulations recognize exactly two classifications for meat and poultry:
- Edible — intended for use as human food.
- Inedible — adulterated, uninspected, or not intended for use as human food.
That’s it. Anything not passed by a USDA inspector for human consumption is legally inedible — full stop. There’s no regulatory category for “feed grade” or “pet food grade” raw material. If it isn’t edible, it’s inedible, and it’s treated the same as condemned product: material a USDA inspector rejected outright for disease, contamination, or other cause. (Source: 9 CFR 381.1, definitions — eCFR — Primary)
Denaturing is what happens after that classification — not before
Here’s where an earlier version of this piece got the sequence backwards: denaturing isn’t the reason meat is condemned or inedible. It’s what USDA requires once meat has already been classified as inedible, so it can never re-enter the human food supply.
Federal law prohibits any adulterated, uninspected, or condemned carcass, part, or meat food product from being shipped in commerce unless it’s first denatured — meaning treated with an agent that changes its color, odor, or taste so it can’t be mistaken for something a human would eat. (Source: 9 CFR 325.11(a) — eCFR — Primary) The denaturing agent has to be mixed thoroughly enough into the material that it can’t be washed or soaked back out. (Source: 9 CFR 325.13(a) — eCFR — Primary)
The approved denaturants include a genuinely startling list: crude carbolic acid, cresylic disinfectant, kerosene or used crankcase oil, FD&C dye formulations mixed with citronella oil, powdered charcoal, and a handful of other proprietary agents approved case-by-case by FSIS. (Source: 9 CFR 325.13(a)(1) — eCFR — Primary) Inedible rendered animal fat gets a similar treatment — denatured with fuel oil, brucine, or charcoal, in a concentration meant to permanently mark it as inedible. (Source: 9 CFR 325.13(b) — eCFR — Primary)
The narrow exception
There is one path around denaturing: an establishment with its own on-site rendering (“tanking”) facility can move undenatured inedible material internally, because it never leaves the plant to enter commerce. Vertically integrated processors with in-house rendering capacity are positioned to do this. (Source: 9 CFR 325.11(b)-(c) — eCFR — Primary) FSIS also permits limited, permit-based movement of undenatured inedible product between establishments under specific conditions — this is the exception, not the rule, and requires a numbered permit from FSIS. (Source: 9 CFR 325.11(e) — eCFR — Primary)
The bottom line
The absence of a middle “feed grade” category is the load-bearing fact here. It means that under federal law, pet food ingredients sourced as inedible material are, by definition, condemned material — and the denaturing requirement exists solely to keep that condemned material out of the human food chain, not to make it more or less suitable for animals.
Sources
- 9 CFR 325.11 — Inedible articles: denaturing and other means of identification; exceptions — eCFR (Primary) — https://www.ecfr.gov/current/title-9/chapter-III/subchapter-A/part-325/section-325.11
- 9 CFR 325.13 — Denaturing procedures — eCFR (Primary) — https://www.ecfr.gov/current/title-9/chapter-III/subchapter-A/part-325/section-325.13
- 9 CFR Part 314 — Handling and Disposal of Condemned or Other Inedible Products at Official Establishments — eCFR (Primary) — https://www.ecfr.gov/current/title-9/chapter-III/subchapter-A/part-314
- 9 CFR Part 381 (definitions, “Edible”/”Inedible”) — eCFR (Primary) — https://www.ecfr.gov/current/title-9/chapter-III/subchapter-A/part-381
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Tags: condemned meat, denaturing, pet food ingredients, pet food safety, rendering, rendering industry, USDA, USDA regulations
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16 Comments
Louise Hollins
Are all pet foods garbage then?
Michele
Do you know of any dry dog food that is ACTUALLY human grade? I know the term “human grade” itself can ne tricky. Does a dry dog food even exist that DOES NOT have sll the disgusting stuff in it? Please let us know as soon ss you can. I have two big dogs and two small dogs that I make homemade food for which I give to them in the morning and then they always have access to dry dog food they can eat whenever they want. I give them the Racel Ray Nutrish zero grain turkey and potato kind. After reading your posts, I don’t want to do that anymore. PLEASE tell me – us – what kind of GOOD dry dog food we can feed our dogs. I’m desperate! I already spend so much time in the kitchen making their homemade food in bulk to last one week to give tjem in the morning and I just don’t have the extra time to feed them ONLY my homemade stuff – I would never get out of the kitchen! Thank you!!!!!!!!!
Michele
I think you’re amazing. God bless you – and I mean that. Keep getting the word out – our pets can’t speak for themselves. WE are their voice. THANK YOU for telling us about Honest Kitchen and Frenchies, Thank you for all you do!!!
barbara m.
Does the assembly line worker who is working furiously to cut and separate the inedible from the edible, err on the side of cutting LESS of the inedible material off – or MORE, (such as what surgeons do when cutting out a tumor)? It sounds as though the speed of the line makes it almost impossible to make these rapid decisions, so that the inedible is probably mixed up with the edible. Then, what happens to a supposedly edible chicken with inedible things still clinging onto it? Is it inspected again? Or Is it then sold for human consumption?
It brings to mind the I Love Lucy episode in the chocolate factory, but this isn’t funny.
Thanks for your hard work, and looking forward to another of your “gross-me-out’ posts.
Peter
Yes, “looking forward to another one of your ‘gross me out’ posts…” made me laugh. They used to call what you do “muckraking” before its modern term as “investigative journalism.” I am beginning to think that you need to find a way to integrate a virtual reality into the site… we need a barf bag at the bottom of almost every page… perhaps it could appear as a holograph if your readers wore 3-D glasses… it would help us endure this stuff!
Ann*
Is there any way to identify the type of denaturant used by a specific manufacturer and link that to the brand names of the pet foods? This article makes me wonder if this is why pet feed like Beneful is full of the food dye colored pieces; not just to appeal to the pet owner, but to also apply a denaturant.
Are you able to identify the two companies making human edible pet food?
Tracy Pitre
A wise boss once told me, “Don’t come to me with problems, come to me with solutions.”
Carlos
Solution: Stop buying that crap and cook for your pet.
Steve Singer
I Love you……..keep up the good work. You are truly a enlightened beautiful person amidst this horrible subject matter.
Keep on punching Mollie!