The Veterinary Feed Directive (VFD): what mills, distributors, and producers must do

A Veterinary Feed Directive (VFD) drug is a medicated feed additive that can only be used in or on animal feed under the professional supervision of a licensed veterinarian. Since the FDA's 2015 VFD rule and the 2017 transition of medically important antimicrobials out of over-the-counter status, most antimicrobials used in feed are VFD drugs. The governing regulation is 21 CFR 558.6.

The three parties

The veterinarian issues the VFD within a valid veterinarian-client-patient relationship, specifying the drug, level, duration, expiry, and the approximate number of animals. Extra-label use of medicated feed is prohibited.

The distributor (including any feed mill that sells VFD feed) may only fill a VFD that contains all the information the regulation requires, and must:

• notify the FDA before distributing VFD feed for the first time (a one-time notification to the Center for Veterinary Medicine)
• keep records of receipt and distribution of all VFD feed for two years
• when shipping VFD feed to another distributor, first obtain a written acknowledgment letter from the receiving distributor, and retain it for two years
• if the distributor also manufactures the VFD feed, keep manufacturing records for one year under 21 CFR part 225

The producer (client) may only feed VFD feed to the animals identified in the directive, must not feed it beyond the VFD's expiration date, and must keep the VFD available for inspection for two years.

Practical points for mills and retailers

1. If you stock or blend any VFD product, file the distributor notification before the first sale, and keep proof.
2. Build the two-year record retention into your ERP or filing system: date, drug, quantity, consignee, and the VFD itself.
3. Distributor-to-distributor transfers without an acknowledgment letter are a common inspection finding. Get the letter before the load ships.
4. Check each VFD is complete and unexpired before filling it. An incomplete VFD cannot lawfully be filled.

Sources

• FDA: Veterinary Feed Directive (VFD)
• FDA: VFD requirements for distributors who manufacture VFD feed
• FDA: VFD requirements for distributors who do not manufacture VFD feed
• FDA: VFD producer requirements
• eCFR: 21 CFR 558.6

This guide is general information for industry professionals, not legal advice. Confirm current requirements with the FDA.