Pet Food - Labeling and Regulation

Labeling and Regulation

In the United States, all pet food is regulated by the Food and Drug Administration (FDA), the United States Department of Agriculture (USDA), and the Federal Trade Commission (FTC). It is further regulated at the state level. The Association of American Feed Control Officials (AAFCO) establishes standards on which states base their feed laws and regulations, but itself has no regulatory authority.

Dog and cat foods labeled as "complete and balanced" must meet standards established by the AAFCO either by meeting a nutrient profile or by passing a feeding trial. Cat and dog food nutrient profiles were last updated by the AAFCO's Feline Nutrition Expert Subcommittee (1991–1992) and the Canine Nutrition Expert Subcommittee (1990–1991), respectively. The updated profiles replaced the previous recommendations set by the National Research Council (NRC). The NRC published new recommendations in 2006; AAFCO is currently (2010) in the process of updating the nutrient profiles.

Products found to be "complete and balanced" by feeding trials bear the label statement "animal feeding tests using AAFCO procedures substantiate that (name of product) provides complete and balanced nutrition." The protocol requires six of eight animals complete a 26-week feeding trial without showing clinical or pathological signs of nutritional deficiency or excess. The cats' or dogs' general health is evaluated by a veterinarian before and after the test. Four blood values (hemoglobin, packed cell volume, serum alkaline phosphatase and serum albumin) are measured after the trial, and the average values of the test subjects must meet minimum levels. No animal is allowed to lose more than 15% of its starting weight.

Products formulated with ingredients to meet the established nutrient profile would include the following statement, "(Name of product) is formulated to meet the nutritional levels established by the AAFCO Cat/Dog Food Nutrient Profiles." There are two separate nutrient profiles - one for "growth and reproduction" and one for "adult maintenance". The nutritional adequacy statement would include information on the life stage(s) for which the product is suitable. A product labeled as "for all life stages" must meet the more stringent nutrient profile for "growth and reproduction". Products labeled as "intended for intermittent or supplemental feeding" do not need to meet either profile.

The "Family Rule" allows a manufacturer to have a product that is "nutritionally similar" to another product in the same "family" to adopt the latter's "complete and balanced" statement without itself undergoing any feeding tests. The "similar" food must be of the same processing type; contain the same moisture content; bear a statement of nutritional adequacy for the same or less demanding life stage as the lead product; contain a dry matter, metabolizable energy (ME) content within 7.5% of the lead product's dry matter; meet the same levels of crude protein, calcium, phosphorus, zinc, lysine, thiamine (and for cat foods, potassium and taurine) as the lead food; and meet or exceed the nutrient levels and ratios of the lead family product or the AAFCO nutrient profiles, whichever is lower. The label statement on the similar food can be the same as the lead product if the ME is substantiated by the 10-day ME feeding study.

Critics of the AAFCO standards argue that such requirements are too lax. Generational studies conducted by researchers at University of California, Davis have shown some foods that pass AAFCO's feeding trials are still not suitable for long-term use and estimated that of 100 foods that pass the nutritional analysis, 10 to 20 would not pass the feeding trials. Although maximum levels of intake of some nutrients have been established because of concerns with overnutrition, many still lack a maximum allowed level and some contains large disparity between maximum and minimum values. The NRC accepts that despite ongoing research, large gaps still exist in the knowledge of quantitative nutritional information for specific nutrients. Some professionals acknowledge the possibilities of phytochemicals and other vital nutrients that have yet to be recognized as essential by nutritional science. With such broad guidelines and loose feeding trial standards, critics argue that the term "complete and balanced" is inaccurate and even deceptive. An AAFCO panel expert has stated that "although the AAFCO profiles are better than nothing, they provide false securities."James G. Morris and Quinton R. Rogers Assessment of the Nutritional Adequacy of Pet Foods through the Life Cycle. J. Nutr. 124: 2520S-2534S, 1994.

Certain manufacturers label their products with terms such as premium, ultra premium, and holistic. Such terms currently have no official definitions. The AAFCO is currently considering defining some of the terms. However, the terms "natural" and "organic" do have definitions; e.g., organic products must meet the same USDA regulations as for organic human food.

In Canada products that pass the Canadian Veterinary Medical Association (CVMA) Pet Food Certification Program, which involves a feeding trial, carries a CVMA label on their packaging. Participation in the program is voluntary. There are no government regulation of pet food in the Canadian marketplace. The CVMA Program was discontinued at the end of 2007.

In the European Union, pet food is regulated by the same harmonized standards across the EU, via the Feeding Stuffs Act.

All ingredients used for pet food has to be fit for human consumption according to EU requirements. But regulations require that pet food that contains by-products be labeled as "Not for human consumption" even though such by-products have to be derived from animals declared fit for human consumption. Raw pet food has to be labeled "Pet food only".

Products meant for daily feeding are labeled "Complete feedingstuff" or "complete petfood" or other EU languages equivalent. Products meant for intermittent feeding are labeled "Complementary feedingstuff or "complementary petfood" while products with an ash content of over 40% are labeled "Mineral Feedingstuff". Ingredients are listed in descending order by weight.