Top Take-Aways:
Hemp is not a source of cannabinoids, it is a source of nutrition
Hemp in any form has not been submitted to AAFCO or the FDA for approval for use in dog or cat foods or treats
Once all of the necessary safety data has been collected and a dossier completed, it can take several years for the ingredient to be approved
Because dogs and cats may eat the same food for many years, long-term studies likely will be required for any hemp ingredient to be approved (think 10+ year study)
Today I listened to a 4 hour webinar covering the topic of hemp in animal food. When the 2018 farm bill passed, many people assumed that hemp automatically would be allowed to be used as an animal food ingredient. You are likely aware of numerous products for pets in the market that contain hemp based ingredients. Most of these are labeled as animal remedies or dosage form products, not as foods. The reason for this is that hemp in any form is not currently allowed in ANY food product designed to be consumed by any animal species.
The only ingredient that has been submitted for an ingredient definition at this time is hempseed meal or hempseed cake meal. This ingredient was sent from the AAFCO investigator to the FDA for their review back in February of 2021. Yes, 2021, that is not a typo. The FDA has asked for additional data and continues to review. There is not an estimated timeline at this point for this ingredient to gain approval. And when it does, it will be approved ONLY for use in laying hens, no other species.
To gain approval for hemp based ingredients in foods for production animals, there must be adequate data that the meat, milk, eggs, etc do not contain cannabinoid residues in addition to not having any adverse impact on the animals themselves. Read more below about the challenges of adequately identifying residue levels.
There is a lack of validated testing methods to accurately measure residual cannabinoids in the ingredient itself or the finished product. As a crop, the limit for THC has been set at 0.3% or 3000 parts per million (ppm). ASTM International (previously known as American Society for Testing and Materials) has established a limit of THC in foods for animals at 20 ppm, but there are limitations in being able to accurately quantify levels this low with existing testing methods. Hemp is not meant to be a source of cannabinoids, but rather a source of nutrition, so cannabinoids are considered to be contaminants. At this time, the FDA does not have enough data to set their own limit of THC in foods and it is unclear whether or not they will adopt the 20 ppm limit set by ASTM.
So what are the barriers for this popular ingredient to gain approval to be included in foods for dogs and cats? Research, research, research. Because dogs and cats may eat the same food for a large portion of their lives, the burden to prove safety of foods containing hemp ingredients over the long-term is great. Safety data must come from studies in the species for which the product is intended as well as from studies of the product in the form that is looking to be approved. As an example, a safety study in mice being fed hempseed oil could not be used as data to support safety in dogs or cats or even for mice being fed hempseed meal. Focusing on one particular form of the ingredient and one specific species is the easiest way to get started. A recent example is black soldier fly larvae, which now has a tentative definition passed by AAFCO membership that includes adult dogs. Previously, the official definition included salmonid, poultry and swine feed but more data was submitted to support the safe use in foods for adult dogs. That being said, once hempseed meal is approved for use in food for laying hens, other species may be subsequently added to the same definition as more data is submitted.
Recently, Idaho sent a notification to any firm with registered animal food products in their state. This letter indicated that beginning November 1st of this year, Idaho regulators will begin seeking out animal foods, treats and remedy products in stores and issue stop sale orders and potential additional enforcement actions. These products are NOT allowed to be sold in Idaho and a decision was made to begin enforcement. It will be interesting to see if additional states begin to take similar regulatory action.
All in all, there is great interest amongst numerous parties involved in the industry to move hemp forward as an approved animal food ingredient. The process will take some time, likely with approvals trickling in over the next few years. At this point in time, hemp should not be used in ANY animal food products, including those formulated for dogs and cats