Hawaii pet food registration
- HRS section 144-2 (as amended by Act 17, 2023) defines 'feed' as edible materials consumed by animals 'other than dogs, cats, or other domestic pets' - dog and cat food is not merely fee-exempt, it is outside the Hawaii Commercial Feed Law entirely, so there is no registration, label review, tonnage or inspection fee.
- The Hawaii Department of Agriculture's own Form FS-2 (Application for Registration of Commercial Feeds) says: 'Feeds for dogs, cats and other domestic pets are exempt from registration.'
- AAFCO's Hawaii page still shows the livestock-feed program ($30 per brand, permanent) without noting the exclusion; the statute and the state form control.
What still applies to you in Hawaii
Pet food needs no FDA pre-market approval, but it must be safe to eat, produced under sanitary conditions, free of harmful substances and truthfully labeled; otherwise it is 'adulterated' or 'misbranded' (FD&C Act sections 402 and 403 cover food for animals). source
Any facility that manufactures, processes, packs or holds animal food must register with FDA. A private residence, a retail food establishment and a farm are not 'facilities' (21 CFR 1.227). If a co-packer makes your treats, the co-packer registers its plant. source
Under $2.5 million (inflation-adjusted; about $3.43M for 2023-2025) in average annual animal-food sales makes you a 'qualified facility': no written hazard analysis or preventive controls, but animal-food Current Good Manufacturing Practices (subpart B) still apply and the qualified-facility attestation (Form FDA 3942b) is filed with each registration renewal. source
Federal rules require product identity, net quantity, manufacturer/distributor name and address and an ingredient list by weight. Hawaii retailers and the mainland states you ship to expect the eight AAFCO elements: product name, intended species, quantity statement, guaranteed analysis, ingredient statement, nutritional adequacy statement (treats: 'intermittent or supplemental feeding only'), feeding directions if required, and name/address. source
The exclusion is for dogs, cats and 'other domestic pets'. Horse, poultry or livestock treats are 'feed' under HRS 144-3 and need FS-2 registration (permanent until withdrawn, two labels per product, signed by the registrant, check payable to 'Hawaii Department of Agriculture', mailed to the Fiscal Office, 1428 South King Street, Honolulu, HI 96814). Whether rabbit or bird treats count as 'other domestic pets' is an open question for the Feed Unit Specialist (808-832-0709). source
DOH permits food establishments that prepare food for people. If you bake in a Hawaii commercial or shared kitchen, that kitchen's DOH food establishment permit governs the premises; DOH issues no pet-food permit. Mainland makers shipping into Hawaii have nothing to file with DOH. source
Hawaii taxes gross receipts rather than charging a sales tax. A seller with Hawaii nexus (a Hawaii location, or remote sales above the state's economic-nexus threshold) registers for a GET license with the Department of Taxation. Ask your accountant; it is unrelated to pet-food law but is the one Hawaii filing small brands most often miss. source
Hawaii reads nothing, but California, Washington and the other states you ship to register products and check labels against the AAFCO Model Regulations. One label that passes them passes Hawaii automatically; our label check applies the same elements to every SKU. source
Keep this page with your records and answer: 'Hawaii excludes dog and cat food from its Commercial Feed Law (HRS 144-2, amended 2023; HDOA Form FS-2 instructions); federal FDA requirements apply.' We date-stamp this guide each season. source
We watch for changes
- We re-read HRS 144-2 / 144-3 and the HDOA Commodities Branch pages each season; a statute change bringing pet food back into 'feed' would add Hawaii to your packet automatically.
- Open item: whether HAR chapter 4-45 (the administrative rules) was updated after the 2023 statute change, and whether 'other domestic pets' covers rabbit and bird treats - we will update this page when the Feed Unit answers.
- If you add a non-dog/cat species to your line or start producing in Hawaii, tell us - FS-2 registration or a DOH kitchen permit then applies.
- Dog and cat food is outside the Hawaii feed law entirely since the 2023 amendment to HRS § 144-2 (Act 17, 2023) — not merely fee-exempt; no registration, label review or tonnage.
- Treats for other species (rabbit, bird, horse) still need FS-2 registration at $30/brand, permanent, two labels per feed, mailed with check.
- Pet food sold in Hawaii is still subject to general DOH food/consumer law and FDA labeling — out of scope for this program.
Sources: HRS § 144-2 Definitions · HRS § 144-3 Registration · Form FS-2 Application for Registration of Commercial Feeds · Hawaii — AAFCO. Verified 2026-10-08. Not legal advice; confirm with the state before paying.