Label exceptions
What does the snack or treat label rule excuse?
Verified September 7, 2026. Figures quoted from the statute, rule, fee page or form.
The one concession the model pet food label makes to treats is small and precise. A dog or cat food clearly identified on the principal display panel as a snack or treat does not need a nutritional adequacy statement, because it is not claimed to be a complete diet. In the older model text that is the whole exception. Everything else on the label stays, and a treat that is not labeled complete and balanced owes no feeding directions for a separate reason.
The two editions, and where the word treat goes
Under the older model regulations the exception attaches to the species designation on the front panel: the words Dog Treat, or Dog Snack, put there conspicuously, are what trigger it. Under the 2024 edition the front panel carries an intended use statement instead, and a treat is labeled with the words Species Treat, so the same fact is expressed as a required statement rather than an exception.
Feeding directions follow the adequacy statement. Both editions require directions on a dog or cat food only when it is labeled as complete and balanced, so a treat that makes no such claim needs none. Several verified states add that a treat still requires a guaranteed analysis, and none of them excuses the ingredient statement, the quantity statement or the name and address.
What the verified states do with it
Most reprint the exception in their own rules, and the table prints each state's wording. One state requires no nutritional adequacy statement on any pet food, so it has nothing to carve a treat out of, and one state's exemptions section is not in the text we read, so its treat position is printed as unknown. One state's brochure asks treat makers to include feeding instructions anyway, which the state page flags as guidance beyond the rule.
What a treat is excused from, state by state
| State | What the state says | Cite |
|---|---|---|
| Texas | DependsA dog or cat food prominently identified as a snack or treat on the principal display panel, as part of the designation required by 4 TAC 63.2(k), needs no statement of nutritional adequacy or purpose (4 TAC 63.2(o)); nothing else is waived, and feeding directions are in any case required only for a dog or cat food labeled complete and balanced (4 TAC 63.2(q)) | 4 TAC §63.2(o) (Label Format and Labeling) |
| Florida | NoneNo Florida label rule carves a treat out of any label item; the only treat exemptions in the chapter are from nutrient sampling and from mycotoxin sampling, which are compliance duties and not label items | Fla. Admin. Code 5E-3.003(4)(b)1.d. |
| Ohio | Not statedNo treat carve-out appears in ORC 923.43 or in any of the seven rules of Ohio Admin. Code ch. 901:5-7; the model snack-or-treat carve-out from the nutritional adequacy statement that the other states in this block carry sits in the AAFCO Official Publication chapters 4 to 6 adopted by 901:5-7-01(A)(1), and that publication is not in the snapshot; separately, ODA guidance says chews, bones, toys, hooves, ears, animal bones, ligaments, snouts and pizzles are not covered by the law at all | ODA "What to Look for on a Pet Food or Treat Label", Exemptions section, page dated March 09, 2026 (agency guidance, not law) |
| Illinois | DependsA dog or cat food prominently identified as a snack or treat, as part of the designation required on the principal display panel by 8 Ill. Adm. Code 200.130(k), needs no statement of nutritional adequacy (200.130(o)); nothing else is waived | 8 Ill. Adm. Code 200.130(o) (Label Format and Labeling), Subpart B: Pet Food |
| Michigan | NoneNeither MCL 287.525 nor Regulation No. 635 carves a treat out of any label item, and Michigan requires no nutritional adequacy statement for a treat carve-out to attach to; MDARD guidance states only that treats require a guaranteed analysis and are not intended to be nutritionally complete | MDARD Pet Food and Treats page, "What's the difference between pet treats and pet food?" |
| Iowa | DependsA dog or cat food prominently identified as a snack or treat, as part of the designation required on the principal display panel by 21.42.2(10), needs no statement of nutritional adequacy or purpose (21.42.2(14)) and, not being labeled complete and balanced, owes no feeding directions either (21.42.2(16)); the guaranteed analysis, the ingredient statement, the quantity statement, the name and address, the species designation and the small-package registration all still apply | Iowa Admin. Code 21.42.2(198), subrule 42.2(14) (Label format and labeling) |
| Missouri | DependsA dog or cat food prominently identified as a snack or treat, as part of the designation required on the principal display panel by 2 CSR 70-31.020(11), needs no AAFCO nutritional adequacy statement (2 CSR 70-31.020(15)) and, not being labeled complete and balanced, owes no feeding directions either (2 CSR 70-31.020(17)); separately, MDA treats rawhides and bones as outside the state labeling requirements altogether unless the label or advertising lists feed ingredients or claims nutritional value | 2 CSR 70-31.020(15) (Pet Food Label Format and Labeling), first physical line of the three-column reprint |
| Indiana | DependsA dog or cat food clearly and conspicuously identified on the principal display panel as a snack or treat needs no statement of nutritional adequacy or purpose (IC 15-19-7-25.7(c)) and, not being labeled complete and balanced, owes no feeding directions either (IC 15-19-7-25.8(a)); nothing else is waived, and OISC requires the intended use, Treat, Snack or Supplement, on the front of the label | IC 15-19-7-25.7(c) |
| California | Not stated17 CCR 19025 and Cal. Health & Safety Code Article 5 were both read in full and neither carves treats or snacks out of any label item, and California imposes no nutritional adequacy or complete and balanced statement for a treat carve-out to attach to; but the section that would carry exemptions, 17 CCR 19015 Exemptions, is not in the snapshot | Cal. Health & Safety Code Sec. 113095 (Misbranding), the delegation of exemptions to department regulation |
| Georgia | DependsA dog or cat food prominently identified as a snack or treat, as part of the designation required on the principal display panel, needs no statement of nutritional adequacy (Ga. Comp. R. & Regs. r. 40-5-8-.02(15)) and, not being labeled complete and balanced, owes no feeding directions by rule either (r. 40-5-8-.02(17)); the GDA brochure separately instructs treat makers to include feeding instructions, which is agency guidance rather than the rule | Ga. Comp. R. & Regs. r. 40-5-8-.02(15) |
The guaranteed analysis a treat still owes
| State | What the state says | Cite |
|---|---|---|
| Texas | YesA guaranteed analysis of nutrients is required on every commercial feed label (Tex. Agric. Code 141.051(a)(4)); on a pet food label the guarantees run in the fixed order crude protein minimum, crude fat minimum, crude fiber maximum, moisture maximum, with additional guarantees following moisture (4 TAC 63.2(c)) | Tex. Agric. Code §141.051(a)(4) (Labeling of Commercial Feed) |
| Florida | YesMinimum percentage of crude protein, minimum percentage of crude fat and maximum percentage of crude fiber, plus mineral guarantees when more than 10 percent mineral ingredients are present; no treat exception | Fla. Stat. 580.051(1)(e)1. |
| Ohio | YesA guaranteed analysis is required on every commercial feed label, stated in terms the director determines by rule; the source division is ORC 923.43(A)(4) in its July 27, 1990 form, which House Bill 433 amends effective October 6, 2026, and the amended text is not in the snapshot | Ohio Rev. Code § 923.43(A)(4) |
| Illinois | YesCrude protein minimum percent, crude fat minimum percent, crude fiber maximum percent, moisture maximum percent, in that order, with additional guarantees following moisture; no treat exception | 8 Ill. Adm. Code 200.130(c) (Label Format and Labeling), Subpart B: Pet Food |
| Michigan | YesCrude protein minimum, crude fat minimum, crude fiber maximum, moisture maximum, in that order, with additional guarantees following moisture; treats are not excused, and MDARD states that treats require a guaranteed analysis | Mich. Admin. Code R 285.635.3(c) (Pet food label information) |
| Iowa | YesA guaranteed analysis is required on every commercial feed label (Iowa Code 198.5(1)(c), Iowa Admin. Code 21.41.2 item 4 with 41.3(4)); on a pet food label the guarantees run in the order crude protein minimum, crude fat minimum, crude fiber maximum, moisture maximum, with additional guarantees following moisture (21.42.2(2)) | Iowa Admin. Code r. 21.41.2(198) (Label format), item 4, the provision that imposes the guaranteed analysis |
| Missouri | YesA guaranteed analysis is required on every commercial feed label (Mo. Rev. Stat. 266.170(1)(b)); on a pet food label the guarantees run in the order crude protein minimum, crude fat minimum, crude fiber maximum, moisture maximum (2 CSR 70-31.020(3)) | Mo. Rev. Stat. Sec. 266.170(1)(b) (Labels) |
| Indiana | YesA pet food or specialty pet food label must list minimum crude protein, minimum crude fat, maximum crude fat where required by IC 15-19-7-28.1, maximum crude fiber, maximum moisture, with additional guarantees following moisture | IC 15-19-7-29.5(a)(1)(A)-(F) (Listing of guaranteed analysis) |
| California | YesCrude protein minimum, crude fat minimum, crude fiber maximum and moisture maximum, with additional guarantees following crude fiber | Cal. Code Regs. tit. 17, § 19025(b) (Labeling and Restrictions), guaranteed analysis table |
| Georgia | YesCrude protein minimum percentage, crude fat minimum percentage, crude fiber maximum percentage and moisture maximum percentage, in that order, on the pet food label | Ga. Comp. R. & Regs. r. 40-5-8-.02(3)(a)-(d) |
The model text behind the rule
Dog and cat food labels need a nutritional adequacy statement except when identified on the principal display panel as snack, treat or supplement.
Dog and cat food labels shall include a statement of nutritional adequacy or purpose of the product except when the dog or cat food is clearly and conspicuously identified on the principal display panel as a “snack”, “treat” or “supplement.”
Feeding directions are required for dog/cat food including snacks or treats only when labeled as complete and balanced; minimum wording 'Feed (weight/unit of product) per (weight only) of dog (or cat)' plus frequency.
Dog or cat food, including snacks or treats, labeled as complete and balanced for any or all life stages, as provided in .08.C.(a) except those pet foods labeled in accordance with .08.D shall list feeding directions on the product label. [...] Feeding directions shall, at a minimum state, “Feed (weight/unit of product) per (weight only) of dog (or cat)”.
Under PF4(a)(1)D, a treat is labeled with the intended use statement '[Species] Treat' on the principal display panel.
D. “[Species] Treat” – for food products for pets or specialty pets, provided occasionally for enjoyment, training, entertainment, or other purposes, and not generally intended or represented to be a complete food or nutritional supplement;
PF8(b) requires feeding directions on dog or cat food, including treats, only when labeled as complete and balanced under PF4(b) or (c).
Dog or cat food, including treats and food mixers, labeled as complete and balanced for any or all life stages as provided in Regulation PF4(b) or PF4(c), except those pet foods labeled in accordance with Regulation PF4(d), shall list feeding directions on the product label.
Verified states on this site
This guide prints only what the verified state records support. More states are added a block at a time as they clear verification.
Questions people actually type
Does a treat need a guaranteed analysis?
Yes, in every verified state that requires one on pet food, and the snack or treat exception does not touch it. The guarantees run in the fixed order the state rule prints, usually crude protein minimum, crude fat minimum, crude fiber maximum and moisture maximum. The state label page quotes the order and the treat exception side by side.
Where exactly does the word treat go?
On the principal display panel, the front of the bag, as part of the species designation under the older text or as the intended use statement under the 2024 text. Burying it on the back does not trigger the exception. The words most states quote are prominently or clearly and conspicuously identified as a snack or treat.
Can I write complete and balanced on a treat?
Only if the product meets a nutrient profile or passes a feeding trial that supports the claim, and then it is not a treat for label purposes: the nutritional adequacy statement and feeding directions come back. Several state rules bar an unqualified complete or balanced claim unless the product meets a recognized standard, and the state pages quote them.
Keep reading
DogTreatLicense is an informational reference about state commercial feed laws as they apply to people who make and sell pet treats in the United States. It reprints instrument names, fees, thresholds, label items and citations from state statutes, rules, fee schedules and agency forms, together with the date each state was last verified. Nothing on this site is legal advice, and fees and rules change. Confirm with the state feed control office before you register or sell.
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