Raw Fresh or Frozen Pet Food Manufacturing

Acronyms used:

  • CCR - California Code of Regulations
  • CDFA - California Department of Food & Agriculture
  • CDPH - California Department of Public Health
  • MPES - CDFA's Meat, Poultry & Egg Safety department
  • USDA - United States Department of Agriculture


Raw fresh or frozen meat pet food is regulated by the Meat, Poultry & Egg Safety branch of California Department of Food & Agriculture. Covered here are:

  • General Information and Requirements
  • Labeling Requirements
  • Places to Make, Sell and Purchase

General Information and Requirements

The following are requirements for making pet food using raw fresh or frozen meat.

  • Must be made in a facility that meets California Department of Agriculture (CDFA) regulatory requirements (a home kitchen cannot meet the requirements). CDFA does not require the location be a commercial kitchen but it must meet CDFA requirements that are almost the same as a commercial kitchen. Note: commercial food kitchens are regulated by California Department of Public Health (CDPH).
  • Bottom line: Explain and show the Meat, Poultry and Egg Safety Branch (MPES) inspector your pet food process and where you are going to make it. (Submit form 79-025 Request for Survey for Meat and Poultry Inspection to initiate this action) 
  • Application to Operate a Pet Food Establishment used for slaughter, import and/or processing facilities. Fee $100 renewed annually.
  • Any parts or pieces from USDA inspected slaughterhouse or from a MPES licensed Pet Food Slaughterhouse may be used to manufacture pet food.  
  • Finished pet food products must be de-natured (e.g. addition of charcoal, ash) or de-characterized (e.g. addition of ground bone):
    • Must include enough to make it unfit for human consumption. 
    • Bone fragments must be between be 1/8-1/4 inch. 
  • Inedible and condemned product from a CDFA licensed Custom Livestock Slaughterhouses and USDA Custom Exempt “Cut and Wrap” facilities is NOT ALLOWED to be used to manufacture pet food. 
  • Licensed CDFA licensed sites are inspected by MPES personnel throughout the year.


Labels are approved by MPES, and must include:

    1. The common or usual name of the edible product
    2. The name and address of the packer or distributor, and when the name of the distributor is shown, it shall be qualified by such terms as “packed for,” “distributed by,” or “distributors;”
    3. A statement of the net weight of the product
    4. The establishment number of the establishment in which the product was processed in conjunction with the words “Processed in Establishment No.”
    5. A statement of ingredients if the edible product is made up of two or more ingredients. Such ingredients shall be listed by their common or usual names in the order of descending proportion
    6. The words “Not For Human Food” or other wording required by the Secretary.
    7. Ingredients in descending order of predominance (e.g. USDA beef, xx mineral, xx vitamin, xx vegetables, xx grain)
    8. Safe handling statement (e.g. Perishable, keep refrigerated or frozen)
    9. Any additional information (e.g. grass fed, cage free)is optional
    10. Claims must have supporting documentation (e.g. organic) 

Label requirements in CA Code of Regulations.

Places to Make, Sell and Purchase

The following outlines the places fresh raw and frozen meat pet foods may be made, sold, or purchased and the inspection levels required. Summarized in a table below.

USDA Inspected Facilities

  • USDA inspected slaughterhouse: direct purchase. De-natured or de-characterization is not required before leaving the slaughterhouse but products to be used for pet food must be properly labeled or shipped under seal.

CDPH Licensed Food Facilities

  • Butcher shops, can use scraps from USDA inspected products to make pet food at their facility (e.g. grocery store, restaurant). Pet food manufactured must be de-natured or de-characterized. Must be sold from premises of manufacture, no distribution of the pet food is allowed. A Pet Food License from CDFA is not required.

CDFA Licensed Facilities

  • Meat Processing Establishment (MPE): May use or sell meat products for use in pet food that are from USDA inspected establishments.
    An MPE may make pet food and the pet food they may need to be licensed as a MPES Pet Food Processor
    See: CCR 1180.46. Licensing Provisions
    e.g. -- A retail store may use its generated scraps from processing USDA Inspected meat or poultry product to produce raw pet food and sold from the same locations does not need a license from MPES
  • Custom Livestock Slaughterhouse (CLS): facilities would have to become a CDFA licensed Pet Food Slaughterer in order to use or sell meat or meat scraps for pet food.
    They must also become a CDFA (or CDPH*) licensed Pet Food Processor in order to make pet food.
    • There are currently three CDFA licensed Pet Food Slaughterers.


  • Mobile Slaughter Operator (MSO): could become a state licensed Pet Food Slaughterer if all regulatory requirements for such an operation are met.
    • MSO's are exempt from CDFA MPES inspection,
    • Those that slaughter cattle must register with Bureau of Livestock ID.

Summary Table of Places to Make, Sell or Purchase

Licensed facility type   ⇓⇓⇓

Places to make Fresh/Frozen Meat Pet Food

Places to sell or purchase meat for use in pet food ♦


CDFA Pet Food Facility license required


Meat must be denatured or recharacterized

USDA inspected





CDPH Food Facility





CDFA Meat Processing Establishment





CDFA Pet Food Processor





CDFA Pet Food Slaughterer





* from USDA inspected meat only.

♦ for use in CDFA and CDPH licensed pet food manufacturing.

+Depending on compliance with the retail store exemption


The information presented on this page is a collaboration with CDFA, MPES and was published July 2017. Contact MPES at 916-900-5022 or the inspectors at 209-649-3682 or 209-403-2481.