Q: May feed manufacturers dilute and inventory VFD feeds?
A: Yes. Feed manufacturers holding a feed mill license may inventory and dilute VFD products. A distributor or retailer that does not hold a feed mill license may inventory and dilute Type B and Type C feeds. Except for some special paperwork requirements to manufacture and sell, a VFD feed is no different than manufacturing and selling any medicated feed containing a Category II animal drug.
Q: Are there any special paperwork requirements for VFD feeds?
A: Yes. There are three types. First, the person or firm (whether or not a licensed feed mill) supplying a VFD feed to a producer must receive and retain a copy of the signed VFD form issued by a producer's veterinarian. Second, licensed feed manufacturers and distributors that ship a VFD feed to a downstream distributor or retailer for inventory must receive and retain a copy of a written acknowledgment stating that the VFD feed will be further distributed only in accordance with FDA requirements. Third, all distributors and retailers that do not hold a feed mill license must, within 30 days, notify FDA of their initial VFD feed shipment.
Q: Is there any special labeling for VFD feeds?
A: Type A medicated article labels will be approved by the FDA and will be applied by the VFD drug manufacturer. Labels for Type B and C feeds will also be approved for each VFD product. Manufacturers of Type B and C feeds should label the feeds in accordance with the approved labels which may be obtained from the product sponsor. These labels will contain a cautionary statement about VFD and feeding.
Q: Are there special requirements for returning feed containing VFD drugs?
Q: Will the introduction of VFD feeds result in changes in FDA/state inspection of my business?
A: For feed manufacturers and distributors, FDA/state inspectors likely will ask to see written acknowledgments from downstream distributors and retailers to whom you supplied VFD feeds. Dealers or manufacturers who delivered VFD feeds to producers may also be asked to allow the inspector to examine files of the VFD forms that were issued by the producers' veterinarians.
Q: May I advertise VFD feeds?
A: Yes. However, all promotional labeling and advertising for a VFD drug or feed must include the FDA-required cautionary statement.
Q: So, what's the bottom line?
A: Manufacturing of VFD feeds is no different than manufacturing other medicated feeds containing Category II animal drugs. However, a lawful VFD form is required to distribute VFD feeds to a producer.
2014 American Veterinary Medical Association