Importing Dog Treats into the US: FDA, FSVP, Prior Notice and APHIS

To import dog treats into the US, the foreign factory must hold a current FDA food facility registration, the US importer must run a Foreign Supplier Verification Program (FSVP), and every shipment needs FDA Prior Notice before it arrives. Treats that contain animal-origin ingredients, such as chicken or duck jerky from China, also have to meet USDA APHIS Veterinary Services rules, which usually means a VS import permit and an official veterinary certificate, and the label has to meet FDA and state feed law.

Who Regulates Imported Pet Treats in the US

Three layers of regulation apply to a pallet of dried duck treats arriving at Long Beach or Newark:

• FDA Center for Veterinary Medicine (CVM). Pet food and treats are “food” under the Federal Food, Drug, and Cosmetic Act. FDA’s rules cover facility registration, food safety (FSMA), Prior Notice and federal labeling under 21 CFR 501. FDA’s own summary is on its Importing Animal Food page.
• USDA APHIS Veterinary Services. APHIS is concerned with animal disease, not nutrition. If a treat contains meat, poultry, dairy or other animal-origin material from a country with livestock or poultry diseases foreign to the US, APHIS import rules apply.
• State feed control officials. Most states require pet food and treat products to be registered or licensed before sale, usually based on AAFCO model regulations. This happens after import but before retail, so plan for it early.

U.S. Customs and Border Protection (CBP) handles the entry itself and enforces these agencies’ holds at the port.

How to Import Dog Treats into the US: The Five Steps

Step 1: Foreign Facility Registration and a US Agent

Under 21 CFR 1.225, any domestic or foreign facility that manufactures, processes, packs or holds food for consumption in the US has to register with FDA. This includes animal food. One exemption matters for importers: a foreign facility doesn’t have to register if another foreign facility further processes or packages its product. That exemption doesn’t apply if the second facility only adds labels or does something similarly de minimis. In practice, the factory that dries and packs your treats is the one that has to be registered.

A foreign registration must include:

• The name, address, phone and email of a US agent who lives in or keeps a place of business in the US.
• A Unique Facility Identifier. FDA currently accepts the DUNS number.
• The food product categories and activity types, plus an assurance that FDA may inspect the facility.

Registrations must be renewed every other year between October 1 and December 31 of even-numbered years. Because 2026 is a renewal year, ask any supplier you are onboarding now to confirm the renewal once the window closes. FDA doesn’t issue registration “certificates,” and registration is not FDA approval. Be wary of any supplier that presents a third-party “FDA certificate” as proof of approval.

Registration also triggers the FSMA rule for Current Good Manufacturing Practice and Preventive Controls for Animal Food (21 CFR 507). Unless they qualify for an exemption, registered facilities, foreign or domestic, need animal-food CGMPs and a written food safety plan. The plan covers the hazard analysis, the preventive controls, and monitoring, corrective action and verification procedures, and it is overseen by a preventive controls qualified individual (PCQI). For a dried meat treat, typical hazards include Salmonella (controlled by the drying and heat step), chemical residues in the raw meat, and foreign material. Ask to see how the plan handles each of them.

Step 2: FSVP, the Importer’s Responsibility

FSVP is where many first-time treat brands are caught out. Under FDA’s FSVP rule, the “importer” is the US owner or consignee of the food at the time of entry. If there is no US owner or consignee, it is the foreign owner’s US agent or representative. Your freight forwarder isn’t the FSVP importer, and neither is your Chinese factory. In most private-label deals, the FSVP importer is your company.

The core FSVP obligations for animal food are:

1. Hazard analysis. Identify the known or reasonably foreseeable biological, chemical and physical hazards for each treat type.
2. Evaluate the food and the supplier. Consider the supplier’s food safety procedures, processes and practices, applicable FDA regulations, and the supplier’s compliance history, including warning letters and import alerts.
3. Supplier verification. Based on that risk evaluation, verify the supplier through on-site audits, sampling and testing, or reviewing the supplier’s food safety records.
4. Corrective actions when a supplier falls short.
5. Reevaluation at least every three years, or sooner when new information comes up.
6. Importer identification at entry. Your name, email and DUNS number go on each entry line.

A “qualified individual” must carry out these activities, and the records must be kept. There are modified requirements for very small importers (for animal food, under $2.5 million in annual sales) and for some small suppliers, but they still involve paperwork. A third-party audit report and the manufacturer’s own certifications are useful inputs to your FSVP. At our Qingdao plant, the BRCGS Food Safety Issue 9 audit report (certificate 0244974, issued by Intertek), the HACCP plan and batch lab records are what we share for this purpose. More on how to read those documents is in Are Dog Treats Made in China Safe?

Step 3: Prior Notice for Every Shipment

Prior Notice applies to every commercial shipment of food, including pet treats. It is usually filed by your customs broker through ABI/ACE with the entry, or submitted directly through FDA’s Prior Notice System Interface (PNSI). Under 21 CFR 1.279, FDA must have confirmed the notice no less than:

• 8 hours before arrival by water
• 4 hours before arrival by air or rail
• 2 hours before arrival by road

Prior Notice can be submitted up to 30 days ahead through ABI/ACE, or 15 days ahead through PNSI. International mail shipments, such as samples, need it before the parcel is sent. The notice must identify the manufacturer and its FDA registration number, the product, quantity, shipper, country of production and expected arrival. A missing or inaccurate registration number is one of the most common reasons treats are refused or held. Give your broker the exact name, address and registration number that the factory holds, character for character.

Step 4: USDA APHIS Rules for Animal-Origin Treats

This step is the most specific to meat and poultry treats, and it is the one that most often changes. Check it again before every new product.

FDA’s import guidance states that a USDA APHIS Veterinary Services permit is required to import animal food that contains animal-origin material from countries with livestock diseases exotic to the US. For poultry (chicken and duck), the governing federal rule is 9 CFR 94.6, which covers poultry products from regions where APHIS considers Newcastle disease or highly pathogenic avian influenza (HPAI) to exist. APHIS does not recognize China as free of these diseases. At the time of writing, the regulation allows such poultry products in on one of these bases:

• They are packed in hermetically sealed containers and cooked by a commercial method after packing so they are shelf-stable without refrigeration. This is a canned or retort process, and most dried treats don’t qualify.
• They come with a certificate signed by a full-time, salaried veterinarian of the exporting country’s animal health authority, stating the product was cooked throughout to a minimum internal temperature of 74 °C (165 °F).
• They are imported under a VS import permit issued when APHIS decides the importation doesn’t pose a disease risk. The permit sets its own conditions.

In practice, US importers of poultry-based jerky and wrapped treats from China apply for a VS import permit through APHIS eFile (form VS 16-3). The permit states the certification, processing and labeling conditions, and the Chinese official veterinary health certificate has to match them word for word. Before you commit to a SKU, run it through the APHIS VS Permitting Assistant. Then ask your broker and the manufacturer whether they have recently shipped that exact product type under a permit.

Other ingredients follow different rules:

• Pork and ruminant ingredients (beef, lamb, goat milk) from China fall under separate APHIS disease rules, such as those for African swine fever and foot-and-mouth disease. They can be far harder or impossible to import. Check each one individually.
• Rawhide. APHIS guidelines exempt only plain rawhide that hasn’t been ground, flavored, basted, colored or otherwise processed. A duck-wrapped rawhide stick is processed, so don’t assume the plain-rawhide exemption covers it.
• Plant-only biscuits may avoid APHIS entirely. Dairy, egg yolk or meat broth in the recipe changes that.

A lower-risk way to launch is to start with single-protein poultry items made to a documented cook step, such as a whole duck fillet, and add multi-species or rawhide combinations once your permit route is proven.

Step 5: Labeling Before You Print

An imported treat must be labeled for US sale when it enters, or be relabeled under a documented plan. Federal rules in 21 CFR 501 cover the statement of identity, net quantity, ingredient list and the manufacturer or distributor statement. State feed laws add the guaranteed analysis, species designation and calorie statement. CBP also requires country-of-origin marking (“Made in China”). We cover each element, including the 95%/25%/3% naming rules, in Dog Treat Label Requirements: AAFCO, FDA and What Must Be on the Pack.

CBP Entry: What Your Customs Broker Files

For ocean freight, your broker will typically handle:

• The Importer Security Filing (ISF, “10+2”), due before the container is loaded at the origin port
• A continuous or single-entry customs bond
• The entry and entry summary with the HTS classification. Retail-packed dog and cat food is generally classified under heading 2309.10; confirm the full code and any additional duties on Chinese-origin goods with your broker, since tariffs on China have changed often.
• FDA data elements (Prior Notice, manufacturer registration, FSVP importer DUNS) and the APHIS permit and certificate for animal-origin goods

FDA may release the shipment, request examination or sampling, or detain it. Build a sampling hold into your first-shipment timeline.

Documents Your Manufacturer Should Provide

SAGEIC exports from Qingdao to the US, Europe, Japan, Korea and Southeast Asia and is registered with China Customs for export. Our MES/ERP/WMS system traces every carton back to its raw-material batch, which helps when a permit or an FSVP review asks where a lot came from. For the rest of the supplier vetting process, see How to Choose a Dog Treat Manufacturer in China.

Common Reasons Shipments Get Held

• Registration mismatch. The factory name or address on Prior Notice differs from the FDA registration, or the registration lapsed after the renewal window.
• No FSVP importer identified, or a DUNS number that doesn’t match the importer of record.
• APHIS paperwork gaps. There is no permit, the permit doesn’t cover the ingredient (a duck product that also contains rawhide or goat milk, for example), or the certificate wording doesn’t match the permit.
• Label problems. Drug-type claims, a missing manufacturer or distributor statement, or undeclared ingredients.
• Lab findings. Salmonella or residue results that trigger detention or placement on an import alert.

FAQ

Does FDA approve dog treats before they are imported?

No. FDA doesn’t pre-approve pet food or treats, or their labels. It requires facility registration, FSMA compliance, Prior Notice and truthful labeling, and it can detain or refuse products at the border. Any claim that a treat is “FDA approved” is misleading.

Who files FSVP, the factory or the importer?

The US importer. FSVP places the obligation on the US owner or consignee at entry. The factory supports it by supplying audit reports, certificates, test results and process records.

Do chicken or duck treats from China need a USDA permit?

In most cases, poultry-origin treats from China have to meet 9 CFR 94.6. For dried treats, that usually means a VS import permit and an official veterinary certificate. Check your specific product with the APHIS VS Permitting Assistant and your customs broker, because requirements change with disease status.

Do samples need Prior Notice?

Yes. Food samples sent by courier or international mail still require Prior Notice, and animal-origin samples may still fall under APHIS rules. Ask your manufacturer to send samples through a courier with experience handling FDA-regulated goods.

How often do these rules change?

Often enough to recheck every order. Registration renewals come every two years, APHIS disease-status lists change with outbreaks, and tariff rates on Chinese goods have shifted several times. This article is general guidance, not legal advice. Verify with FDA, APHIS and your customs broker before each new product or lane.

Importing dog treats into the US comes down to three things: the right registration, a working FSVP and complete APHIS paperwork. For help planning your first private-label run, see our OEM/ODM service and quality system.