Over the last two years, the organization and its legal counsel wrote the Animal Health Supplement Act of 2026 to establish a formal regulatory framework that would be implemented by the U.S. Food and Drug Administration (FDA). The NASC says that framework would create economic benefits by codifying the certainty needed for increased industry investment in research and development, manufacturing capacity and job creation.
“This is a very heavy lift when you create a whole new administrative process, a regulatory scheme, especially when it’s not really in the statutes,” said Todd Harrison, partner at the Venable law firm, who wrote significant portions of the Act.
Speaking last month at the NASC annual conference, he noted that the most important part of the bill is that it “really keeps the essence of what NASC has done.”
Over its 25-year history, NASC has worked cooperatively with the FDA and state regulators to create co-regulation of supplements, developing and enforcing uniform standards for animal health supplements instead of waiting on standalone government legislation.
That has created voluntary compliance system, but it remains subject to a patchwork of state laws combined with “the unpredictability associated with FDA enforcement discretion” which creates “significant uncertainty among manufacturers and, in turn, constrains growth and posses risk to the industry,” according to a NASC document.
Among its provisions, the Act would:
Leverage the existing NASC voluntary compliance infrastructure
Formalize the role that the FDA Center for Veterinary Medicine plays in animal health and nutritional supplement safety
Include formal Good Manufacturing Practice (GMP) regulations modeled after NASC’s existing requirements
Focus on supplements provided to dogs, cats and horses (livestock would not be included)
Mandate clear product labeling, proper instructions for administration, safety warnings
Include federal preemption which “ensures consistent standards nationwide while preventing conflicting state requirements that can confuse consumers and burden product suppliers
Grandfather all animal health ingredients currently on the market
Establish for new ingredients a reasonable safety notification process similar to that used for human dietary supplements
Require post-market product listing and company registration with the FDA
Congressional approval?
The Act excludes drugs and biologics and prohibits disease claims and would also address “hybrid” products, which are adulterated and misbranded animal feed/food supplements.
“NASC essentially established a de facto regulatory program,” said Bill Bookout, co-founder and president of NASC. “We have tremendous grassroots support. We have the majority of the industry that is already following the recommendations that the bill includes. It’s all framed around what NASC does.”
Despite industry support and years of planning, NASC’s ability to get the legislation through Congress may be difficult due to the upcoming midterm elections. Congress will have to go out of session for campaigns, truncating the legislative session this year.
“If the bill is introduced in one Congress and isn’t enacted into law, then it has to be reintroduced in the next Congress to start all over,” said Will Nordwind, partner at Venable. “However, you can and should, as a result of that, lay a foundation in one Congress, build momentum to turn the corner to the next Congress with a little bit of speed—and that’s kind of what we’re banking on at the moment.”
Nordwind said the good news is that the legislation is well-drafted.
“We’re doing all that hard work because if we didn’t do it, Congress would have to, and it would take them a long time,” he added.
NASC and the Venable attorneys are targeting members of the House Committee on Energy and Commerce and the Senate Committee on Health Education, Labor and Pensions (HELP) for their support because those committees would have jurisdiction over the Act.
Market headwinds
The Animal Health Supplement Act comes at a time when supplement sales are growing but not as robustly as they had during the COVID-19 pandemic. Although the global pet supplement market size was estimated at $2.76 billion in 2025 and is expected to reach $4.65 billion by 2033, pet supplement sales growth fell to under 5% in 2024 and under 3% in 2025, according to industry market research organization the Freedonia Group.
“What’s behind that is that we see a downshift in dog acquisitions and dog ownership,” said Shannon Landry, research director at Packaged Facts Pet. “Everybody talked about the big pandemic bump, where there was an increase in spending on pets, but older pet owners are aging out of dog ownership because they physically can’t handle it anymore.”
The decline in dog ownership does not mean consumers are not getting companion animals. The same older adult group Landry mentioned may opt for a cat instead, she said, as they are easier to transport when a household downsizes. Additionally, the number of homeowners has declined in the United States, and cats are more likely to be accepted in rental units, Landry added.
“Younger potential dog owners aren’t able to afford housing that will allow them to accommodate a dog,” she said.
Lauren DeVestern, managing director and partner at LEK Consulting, noted that the concern of decreased dog ownership may be overstated.
“We estimate that about 35 to 40 million pets were adopted during COVID,” she said. “These pets are starting to enter the later years of life…once they’re over six or seven years old, spend on supplement starts to go up pretty significantly, typically for dogs. We call it the silver tsunami of COVID pets, the aging COVID pets that are headed our way.”
DeVestern noted that the animal supplement industry continues to experience healthy volume and price growth and has not faced the same level of inflation pressures in many other categories.
“There is still a lot of innovation and product proliferation happening, which also spreads demand,” she said. “Awareness has grown, comfort has grown.”
DeVestern’s firm monitors Google search trends and pet supplement-related keywords, which indicate a steady increase in search activity for companion animal supplements over the past three years.
Consumer interest may pique investor interest, but investors typically want additional data before making funding decisions.
“The investor community does have a bit of a snake oil concern—’does this stuff really work?’ You do get that question a lot, she said, but note that clinical studies will increase investor confidence, which should ultimately driver greater consumer confidence over time.