Pet Food Regulations

AAFCO Meeting Minutes

For those that wish to learn more how the pet food regulation process works – here are the official Minutes from the most recent (January 2014) AAFCO meeting.

First – the Minutes from the Pet Food Committee meeting.  Click Here to read.

Of interest to pet food consumers was the discussion on providing carbohydrate statements on pet food labels.  On page 2 you’ll find what was discussed.  For pet foods to be required to declare the percentage of carbohydrates on the label, regulators must have a method to prove or disprove these carbohydrate statements are accurate.  That’s the concern and that was the discussion in January – how to measure the carbohydrate content of pet foods.

On page 3 you’ll find the minutes explaining a presentation/discussion provided by Dr. Bill Burkholder of FDA.  Dr. Burkholder was not pleased that some pet foods/animal foods are listing ingredients by use of parenthesis.  Examples he gave “protein products (chicken, beef, etc.)”.  This type of ingredient listing do not conform to regulations and Dr. Burkholder made it clear he wanted manufacturers to stop this immediately.

On page 4 continuing on to page 5 is minutes from the meeting regarding the long awaited update on nutrient profiles for dog foods and cat foods.  The hang up for quite some time has been the calcium maximum for growth of large size dogs (large dog puppy food).  I found it absurd in person and even more so in print when industry complained the cost to industry would be “more than 36 million dollars) to reformulate large breed puppy foods from 2.5% maximum calcium to 1.8% calcium.

Within this discussion is also the following statement from industry: “There is also concern about the availability of appropriate protein sources needed to meet the lower maximum calcium value of 1.8%.”  What this ‘concern’ is – commonly used sources of protein in many pet foods contain high amounts of bone (many are little more than skin and bone – very little meat).  High amounts of bone used in a pet food increases the calcium (and ash) content of a pet food.  That’s some manufacturers concern…that they are currently sourcing almost entirely skin and bones as their protein source…and with required lower calcium looming – some manufacturers will be forced to source meat (instead of skin and bone) in their pet foods.

And during that same discussion (end of page 5) the minutes show that I tried – but failed – to get the committee to give consideration to the nutrient content of whole foods in the new nutrient profiles for cats and dogs.  It is unrealistic – to me – that all pet food be held to the same nutrient profiles.  The nutrient profiles all pet foods (kibble, can, raw, lightly cooked) are held to are currently based on science from the 1980’s.  These revisions that FDA and AAFCO continue to debate on are based on updated science published in 2006.  Which itself is 8 years old science.

Next – the minutes from the Ingredient Definitions Committee meeting.  Click Here to read.

On page 4 pet food consumers will find the definitions of pea flour, pea protein, pea starch, and pea fiber (listed as pulse) that were approved at the January meeting.  Please know that some manufacturers have been using these ingredients in their formulas before they were legally defined in the AAFCO Official Publication (OP).  In other words – these ingredients remain illegal until they are included in the OP (expected in January 2015).  No pet food manufacturer should be using these ingredients until they have a legal definition and are included in the AAFCO OP.

As you’ll see by reading the minutes of these two meetings – the regulatory process is a challenge.  There are so many things to consider with pet food/animal feed and so little time to give these considerations proper attention.  Each committee meeting lasts only a couple of hours and occurs only twice a year.


Wishing you and your pet(s) the best,

Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
Association for Truth in Pet Food

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April 15, 2014

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  1. Dianne says:

    Is it also possible that since there is such a variation in ingredients from one batch to another, if the ingredients are sourced from multiple places and if different proportions of the parenthesized items are used, that it would mean doing a nutritional analysis of each batch and printing new labels. Could this be part of the reason that they do not want to produce more meaningful labels?

  2. ellie says:

    This is very good information although very infuriating. This multi-billion dollar industry is concerned about having to reformulate an already poor quality product in order to meet the very minimum of requirements.
    I wish Americans would wake up to what is going on in the pet food industry as well as the human food industry.

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Susan Thixton's author is a founding partner of the international pet food consumer association - Association for Truth in Pet Food. Through our consumer association, Susan has advisory position to AAFCO's Pet Food Committee and Ingredient Definitions Committee.