· Notes for owners
Pet food brands USA: the shipping rule and how to keep it
What the FTC's mail, internet or telephone order rule requires of a pet food brand, and a short ordered list for making shipping promises it can keep.
On October 6, 2026, the FTC announced it is sending more than $100,000 in redress payments to consumers it says were deceived by the online marketplace GOAT. The settlement resolves FTC allegations that the company did not honor its refund policies and violated a rule requiring reasonable shipping practices.
What does the federal shipping rule require of a pet food brand?
A pet food brand has its own version of GOAT's problem. The site advertises fast shipping, or autoship names a delivery date. The order runs late, and nobody tells the customer or offers to cancel and refund. Among the 451 dog and cat food manufacturers with paid employees nationwide in 2023 (County Business Patterns), any that sells direct online makes this decision each time it writes a delivery promise on a page.
The rule is the Mail, Internet or Telephone Order Merchandise Rule, 16 CFR Part 435. In plain terms:
- A seller soliciting orders by internet must have a reasonable basis to expect it can ship.
- If no time is stated, the seller must ship within thirty days after a properly completed order.
- The rule covers sales ordered by mail, internet or telephone, regardless of payment method.
The rule sets thirty days only as the fallback when no time is stated. A brand that states a time has made a promise it needs a reasonable basis to keep.
The FTC's complaint against GOAT shows what it alleges a breach looks like. The FTC alleged that GOAT failed to mail some priority processing orders as fast as promised. It also alleged that GOAT did not offer buyers the option of agreeing to the delay or cancelling the order and receiving a prompt refund, as the rule requires.
The FTC made a second allegation. GOAT offered a "Buyer Protection" policy but did not put a system in place to honor it. It promised full refunds, yet frequently denied requests, gave partial refunds or issued in-store credits.
What the Census figures say about this trade
The federal figures describe the trade's payroll and receipts. Among dog and cat food manufacturers owned by firms with fewer than 500 employees, annual payroll was $1,561,812 per establishment in 2022. Receipts were $19,424,086 per firm in 2022. Both figures come from the Census Bureau's Statistics of U.S. Businesses.
A shipping promise is a policy applied to every order, not a one-off. If the policy has a gap, the gap repeats. Those figures describe manufacturers as a group. They say nothing about how any single brand ships.
A shipping promise the business can keep, in order
This list can go to whoever runs the website, email and order system.
- List every delivery promise. Check product pages, checkout, ads, order confirmations and autoship emails. Write down each time or date they state.
- Match each promise to real ship times. Use what the warehouse or supplier actually does. Keep only promises with a reasonable basis behind them.
- Know the thirty-day default. Where a page states no time, the rule's fallback is thirty days after a properly completed order; where a page states one, that stated time governs.
- Trigger a notice when an order will miss its date. The message should offer two choices: agree to the delay, or cancel and get a prompt refund. The order system should send it, not someone's memory.
- Make the refund path work end to end. A refund policy counts only if someone can actually issue the refund. One of the FTC's allegations against GOAT concerned exactly that gap: a refund policy with no system to honor it.
Step four is the one most worth building into software. It needs the promised date, the real status of the order and a way to send the notice and record the customer's answer. Those pieces have to be connected for the notice to fire.
That figure describes manufacturers as a group, not any one brand, and an automatic notice still does more than a policy someone has to remember to apply.
The trap
The trap is promising delivery dates a supplier cannot meet. Shopify's explainer notes that a dropshipping store relies on suppliers for fulfilment. It also notes the store still handles customer service issues outside its direct control, such as shipment delays, delivery problems and product defects. The seller makes the promise and the customer holds the seller to it, whoever packs the box. For a pet food brand that sells through a co-packer or outside warehouse, the same holds. The rule's test is a reasonable basis to expect it can ship. A date copied from a supplier's best case is a weak basis.
A smaller trap sits nearby for autoship. One published figure puts median first-attempt payment success at 86.0 percent. It comes from 100+ accounts of one retention agency over eight months of 2026. It is one agency's data, not a market benchmark, so it should not be used to judge a brand's own billing.
Where to start
We act as the technology department for pet food brands: we map the workflow, build the software that fits it, and run it. Book a discovery call and we map the workflow as it runs today, find where it leaks, and name the step the technology takes over.