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Pet Food Regulations

Complete and Balanced Failure

The dog foods linked to nutritionally based DCM were labeled as “Complete and Balanced” pet foods. But, those Complete and Balanced foods failed thousands of dogs. Who should be held responsible for the nutritional failure of these Complete and Balanced dog foods?

The dog foods linked to nutritionally based DCM were labeled as “Complete and Balanced” pet foods. But, those Complete and Balanced foods failed thousands of dogs. Who should be held responsible for the nutritional failure of these Complete and Balanced dog foods?

Right now (August 2018) – multiple ‘Complete and Balanced’ dog foods brands are linked diet related taurine deficient dilated cardiomyopathy (DCM) in possibly thousands of dogs. There are more than 8,000 pet owner members of the two Taurine Deficiency Dilated Cardiomyopathy groups on Facebook. Right now (August 2018), thousands of pet owners are questioning why the ‘Complete and Balanced’ claim on their pet food label failed their dog.

What does ‘Complete and Balanced’ mean on your pet food label?

The FDA states (bold added) “You can determine if a pet food meets your pet’s nutritional needs by looking at the nutritional adequacy statement on the label. If this statement includes the phrase “complete and balanced,” then the product is intended to be fed as a pet’s sole diet and is nutritionally balanced.

What are the consequences if the pet food is not ‘Complete and Balanced’?

Dr. Karen Becker states: “In my practice I see a growing number of patients with skeletal issues, organ degeneration and endocrine abnormalities as a result of dietary deficiencies of essential fatty acids, calcium, trace minerals and other nutrients. Well-meaning pet parents are trying to feed species-appropriate food to their dogs and cats, but what they’re missing is the need for nutritional balance.”

How is a pet food defined to be a ‘Complete and Balanced’ pet food?

Quoting FDA:

To have “complete and balanced” in the nutritional adequacy statement, a dog or cat food must either:

  • Meet one of the Dog or Cat Food Nutrient Profiles established by the Association of American Feed Control Officials (AAFCO); or
  • Pass a feeding trial using AAFCO procedures.

For a product to meet one of the AAFCO nutrient profiles, it must contain every nutrient listed in the profile at the recommended level.

When you see a reference to either an AAFCO nutrient profile or a feeding trial using AAFCO procedures on a pet food label, you’re better assured that the “complete and balanced” claim is valid. Endorsements and seals of approval from other organizations are not assurances of nutritional adequacy and may be misleading.

In other words – AAFCO (Association of American Feed Control Officials) established the dog and cat food nutrient profiles.

Most pet owners believe a team of nutritionally trained scientists/veterinarians wrote the nutrient profiles pet foods are held to (to make the claim ‘complete and balanced’). But that is not actually true.

AAFCO shares: “In 2007 the AAFCO Pet Food Committee again formed Canine and Feline Nutrition Expert Subcommittees and charged these subcommittees with the task of revising the AAFCO Nutrient Profiles in consideration of the information in the 2006 NRC Nutrient Requirements of Dogs and Cats (2006 NRC).”

In other words, representatives of regulatory (AAFCO members) and industry (AAFCO advisors) participated in the AAFCO Pet Food Committee ‘subcommittee’ that determined what nutrients and at what percentage would be required for a ‘Complete and Balanced’ pet food. Industry and regulatory members of the subcommittee did consult the 2006 NRC (National Research Council) Nutrient Requirements of Dogs and Cats – so the subcommittee did base the nutrient profiles on quality science, right? Sort of.

The 2006 National Research Council Nutrient Requirements of Dogs and Cats that current cat and dog food nutrient profiles are based on – was funded by the Pet Food Institute, the trade association representing the largest manufacturers of pet food.

In review: the current nutritional profiles – that have failed thousands of dogs diagnosed with diet related taurine deficient dilated cardiomyopathy – were…

  • Written by an AAFCO subcommittee that included regulatory and industry members
  • Based on science that was funded by the pet food industry
  • Established as law to make a “Complete and Balanced” claim on the pet food label

Who should be held responsible for the “Complete and Balanced” nutritional failure?

Should the pet food industry be allowed to write their own nutritional profiles? Was AAFCO correct to base the ‘Complete and Balanced’ claim on science funded by industry?

Should a non-government “feed” regulatory association (AAFCO) that is heavily influenced by industry be provided the responsibility of developing a pet food nutrient profile? Or should that responsibility be solely charged to government authorities such as the FDA? Or who should be charged with the responsibility for determining what is truly ‘Complete and Balanced’ pet food?

Should the pet food manufacturers themselves be held accountable for the thousands of diet related taurine deficient dilated cardiomyopathy?

 

Personal opinion: they are all responsible and they ALL owe thousands of pet owners an answer to why their dog died or is sick because of a Complete and Balanced nutritional failure.

 

Wishing you and your pet(s) the best,

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


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9 Comments

9 Comments

  1. kelsy

    August 23, 2018 at 1:42 pm

    Thanks for the great article. We no longer feed any dry kibble as it is all processed dead food, meaning No nutrients and No enzymes, it only provides calories. Most kibble is about 50% cheap sugar, which also feeds any cancer cells. Big Pet Food is not required to put sugar on the ingredients in order to mislead pet lovers. A bad diet with No nutrition like dry kibble or pasteurized canned pet food (pasteurized can food kills the nutrients) can also lead to joint disease and acl ccl knee tears in the joints. When my dog’s knee joint was fully torn, the vets tried to sell painful expensive tplo or tta surgery, but we got a posh dog knee brace to support the knee till it healed and they recommended to feed or supplement our dog’s food with real frozen raw chubbs with ground up bone, joints, meat and organs. The raw must Not be pressurized, No hpp, No radiation and No pasteurization so the nutrients and enzymes stay alive for help with healing the joints. The combo of frozen raw ground up bones, joints, organs & meat and the support of the dog knee brace, my dog’s knee healed in only a few short months and was walking normally and is now running and playing with No surgery ever. We still feed the raw frozen food with frozen green beans or frozen mixed veggies for fiber for firm poop. As we want to keep our dog’s joints healthy. Its a good idea to at least supplement your dog’s diet with some frozen raw and or a raw organic whole egg.

  2. Janice

    August 23, 2018 at 3:13 pm

    As Susan’s earlier article cited above points out, the 2006 Nutrient Requirements text was partially funded by the pet food industry. It is good to investigate this, but that fact alone does not mean that its conclusions are biased. I think the scientists might have something to say about that, and it would be good to hear from them. But in any case, I have found that even foods that are supposed to be complete and balanced only roughly conform to the NRC recommendations. You can check this by comparing the nutrient profile of a dog food (IF the manufacturer will provide that) with the NRC tables. It doesn’t take a math genius to do the calculations, and it is worth it for the sake of your dog. Another problem I have found is that the recommended amount of food by most manufacturers is more than my dog needs to maintain his weight (and his thyroid is monitored and he does get exercise), so only a high quality food relatively low in calories will provide the necessary amounts of required nutrients. Reducing the amount of a higher calorie food to keep him from becoming obese would deprive him of adequate nutrients (I have done the calculations, and this applies even to many high quality moist and frozen dog foods). This is especially important now, given the dilated cardiomyopathy problems that may be related to taurine deficiency and possibly inadequate amino acids, especially methionine and cystine.

  3. T Allen

    August 23, 2018 at 4:14 pm

    I think that the pet food companies should be held responsible because when they get dragged into court (hopefully a class action lawsuit) they will immediately implicate AAFCO as the source of incorrect nutrition guidelines. If they are smart they’ll sue AAFCO but will they bite the hand that feeds them? Only time (and lawsuits) will tell. In the meantime we need to educate people to supplement their pets diets with real food and don’t feed just one commercial diet!

  4. Dave Horchak

    August 24, 2018 at 11:37 am

    It’s a marketing gimmick if the incompetent federal government doesn’t set standards and fine liars

  5. judy acedo

    August 24, 2018 at 12:04 pm

    Recently read some disturbing facts about Aafco.
    Sounds like a good ol boy network, most I feel dont have much knowledge of what is needed in pet food, or dont care where its sourced from. Euthansia drugs found in pet food? I find it increasingly difficult to trust any company or manufacturer. Thanks for your diligence Susan.
    The public NEEDS people like you.

  6. Peter

    November 17, 2018 at 6:53 am

    Good reporting. Among the many critics of the lax, functionally inaccurate, and even deceptive AAFCO “complete and balanced” standards developed by ad hoc committees composed of industry representatives (with a vested interest in influencing AAFCO decision-making) is one of their own panel experts, stating: “although the AAFCO profiles are better than nothing, they provide false securities.” (JAVMA: 1993).

    • Peter

      November 17, 2018 at 7:11 am

      “Because the public has become comfortable with the idea that commercial pet foods can provide complete and balanced nutrition for the life of the animal, basic diet is no longer generally considered an important source of disease. Pet owners and veterinarians have literally been trained to look elsewhere for causes and treatment options.” –Susan Wynn, World small animal veterinary association world congress proceedings, 2001.

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