Labeling and regulation

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United States[edit]

In the United States and its associated territories, 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.[22] State Department of Agriculture officials, major feed manufacturers, and ingredient suppliers form the Association of American Feed Control Officials (AAFCO), a non-government agency that establishes guidelines and standards on feed laws and regulations. Although government officials do comprise a large portion of AAFCO, it has no regulatory authority and acts simply as an advisory body, working closely with the FDA to develop standards that food consumed by animals must meet. AAFCO leaves the responsibility of regulating these standards to the individual states. Most states have adopted the guidelines set forth by AAFCO.[23]

AAFCO requires that all pet food products sold in the United States have labels that contain eight components:

  1. Brand and Product Name: These rules address the use of ingredient names in the product name. How ingredients may be included in the product name depends on the percentage of that ingredient in the product, and the use of certain descriptors. For example, there are different rules for "Beef Dog Food", "Beef Recipe Dog Food", "Dog Food with Beef" and "Beef Flavor Dog Food".
  2. Name of Species for which the pet food is intended: This must be conspicuously designated in words on the principal display panel, but may be included in the product name, such as "Beef Dog Food" or "Salmon Treats for Cats".
  3. Quantity Statement: This is the net weight or net volume, and it must be expressed in the correct units and placed on the lower third of the principal display panel.
  4. Guaranteed Analysis: This lists the percentage of each of the nutrients in the food. The minimum percent of crude protein and crude fat, the maximum percent of crude fiber, and moisture are always required. Note that "crude" refers to the analysis method, rather than the quality of the nutrient.
  5. Ingredient Statement: Ingredients must be listed in order of predominance by weight, on an "as formulated basis". The ingredient that makes up the highest percentage of the total weight as it goes into the product is listed first.
  6. Nutritional Adequacy Statement: This is a statement that indicates the food is complete and balanced for a particular life stage, such as growth, reproduction, adult maintenance or a combination of these, or intended for intermittent or supplemental feeding only. AAFCO makes rules for nutrient levels required for such a statement. Products conspicuously identified on the principal display panel as a snack, treat, or supplement are exempt.
  7. Feeding Directions: All pet foods labeled as complete and balanced for any or all life stages must include feeding directions that, at a minimum, state "Feed (amount of product) per (weight) of dog/cat". Feeding frequency must also be stated. Feeding directions are optional for treats, as long as they are labeled as snacks or treats.
  8. Name and address of manufacturer or distributor: This names the pet food company as guarantor of the product and gives the company's location. If the company uses a separate manufacturer for actual production or distribution, the label must show that relationship by using the words "Manufactured for" or "Distributed by".[24]

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 established by the AAFCO's Feline Nutrition Expert Subcommittee (1991–1992) and the Canine Nutrition Expert Subcommittee (1990–1991), respectively. The nutrient profiles were updated in 2016.[25]

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.[24]

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.[26] 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."[27]

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.

Canada[edit]

In Canada, products that pass the Canadian Veterinary Medical Association (CVMA) Pet Food Certification Program, which involves a feeding trial, carry a CVMA label on their packaging. Participation in the program is voluntary. The program was discontinued at the end of 2007.[28] There is no government regulation of pet food manufactured in Canada. However, imported pet food does receive stringent oversight.[29]

European Union[edit]

In the European Union, pet food is regulated by the same harmonized standards across the EU, via the Feeding Stuffs Act.[30]

All ingredients used for pet food have 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".[31]

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 pet food" while products with an ash content of over 40% are labeled "mineral feedingstuff". Ingredients are listed in descending order by weight.[32]

With the released Commission Regulation (EU) No 107/2013, the European Union has set new maximum levels for melamine in canned pet food. According to results of an in-depth research of the 2007 pet food crisis, melamine used in coatings for pet food cans can migrate into the food. Therefore, the regular melamine migration limit (SML) of 2.5 mg/kg for food and feed has been expanded to pet food. This limit is valid for canned wet pet food on an ‘as sold’ basis.[33]

The European Union does not use a unified nutrient requirement.[34] A manufacturer committee called FEDIAF (European Pet Food Industry Federation) makes recommendations for cats and dogs that members follow.[35]