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Pet Food Regulations

Complete and Balanced? Maybe…Maybe Not

Complete and Balanced pet food is significantly important. Unfortunately, a pet is only receiving complete and balanced nutrition IF they happen to be consuming the right amount of food. An AAFCO failure that millions of pets are paying the price for.

Complete and Balanced pet food is significantly important. Unfortunately, a pet is only receiving complete and balanced nutrition IF they happen to be consuming the right amount of food. An AAFCO failure that millions of pets are paying the price for.

This is Rover. He is a lovable 30 pound couch potato. Walking ten foot out into the back yard several times a day to ‘go potty’ is the most exercise Rover gets.

Rover’s family pays close attention to his weight. They have found that feeding Rover 25% less pet food is the perfect serving size to maintain Rover’s waistline.

What Rover’s family doesn’t realize however, is the result of feeding 25% less pet food could result in Rover getting only 75% of the nutrients he needs. Overtime, Rover could get sick from nutrient deficiencies.

Complete and Balanced? Only if you are feeding the right amount.

The claim is on almost every bag or can of pet food, assuring consumers that said bag or can provides all the nutrients your pet needs.

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

Explanation: Complete and Balanced means the pet food contains all of the nutrients (protein, fat, fiber, vitamins and minerals) that a cat or dog needs – and in the proper amount. The nutrients a dog or cat needs AND the the proper amounts are established in pet food regulation by AAFCO through “Nutrient Profiles”. AAFCO has two Nutrient Profiles in both cat food and dog food; adult and young animal (such as puppy or kitten – this same category is used for nursing animals). Click Here to view an AAFCO document providing Nutrient Profiles for cats and dogs. Below is an image of the dog nutrient profile (notice the two columns – “Growth & Reproduction” and “Adult Maintenance”)…

So…if a puppy food meets the nutritional requirements of the Growth and Reproduction column per 1,000 kcal – the puppy food is “Complete and Balanced” per AAFCO. And if an adult dog food meets the nutritional requirements in the Adult column per 1,000 kcal – the dog food is “Complete and Balanced” per AAFCO.

But there is a problem. Or two.

The ‘Complete and Balanced’ claim on a pet food label is NOT required to be based on the manufacturer suggested feeding amount  – what consumers would base how much food to provide their cat or dog (to actually provide the pet with a Complete and Balanced diet). And…the ‘Complete and Balanced’ claim is not based on calorie requirements a high energy level dog needs or the low calorie requirements a couch potato cat needs.

Instead, AAFCO regulation for Complete and Balanced requires a pet food to meet specific nutrient requirements per 1,000 kcal.

Complete and Balanced =
all the nutrients (protein, fat, fiber, vitamins and minerals) in the proper amount –
per 1,000 kcal of pet food.

This sounds like a good system, until you realize that pets have different calorie per day (energy) needs while having the same level of nutrient need (vitamins and minerals) for their physical size.

A ten pound dog requires a particular level of calcium, copper, magnesium, Vitamin A, and numerous other nutrients based on his body weight. The 10 pound dog’s need of calcium, copper, magnesium, Vitamin A and numerous other nutrients is NOT based on his activity level. These nutrient needs are the same whether the dog is an active ten pound dog or an inactive ten pound dog.

But…an active ten pound dog will need higher calorie consumption based on his energy needs. And an inactive ten pound dog will need less calorie consumption based on his lesser energy needs.

The problem…AAFCO Nutrient Profiles do not recognize varied energy needs/calorie requirements of cats and dogs. Ignoring calorie requirements of active or inactive pets causes some pets to consume higher levels of vitamins and minerals for their body size, and causes some pets to consume insufficient levels of vitamins and minerals for their body size.

The National Research Council has established generalized calorie/energy needs for dogs based on activity level. Simply put, the more active the dog is – the more calories the dog needs for fuel.

The problem…

Mr. Zip and Zoom is a 5 year old, ten pound active dog. His calorie requirements – because of his activity level – is around 400 kcal per day.

Mr. Couch Potato is also a 5 year old, ten pound dog. But Mr. Couch Potato gets no exercise. His calorie requirements – because of his decreased activity level – is around 300 kcal per day. One hundred calories less per day than Mr. Zip (same size/weight dog).

Even though these two dogs have different calorie requirements per day – because of their size/weight, they have the exact same daily requirement for most other nutrients per day. Such as…

When Mr. Zip and Zoom consumes more food – to meet his calorie/energy needs – he is consuming more vitamins and minerals than his physical size needs.

Because the ‘Complete and Balanced’ system does not recognize the high calorie need of some pets…

Mr. Zip’s need for high calorie consumption results in –

Consuming more pet food, which results in –

Consuming more vitamins and minerals his body size requires.

When Mr. Couch Potato consumes less food – to meet his calorie/energy needs – he is consuming less vitamins and minerals than his physical size needs.

Because the ‘Complete and Balanced’ system does not recognize the low calorie need of some pets…

Mr. Couch Potato’s need for low calorie consumption results in –

Consuming less pet food, which results in –

Consuming less vitamins and minerals his body size requires.

Over time, both of these dogs could suffer from health issues relating to excess vitamin/mineral consumption or health issues relating to nutrient deficiency.

And we have the same concerns with ‘Complete and Balanced’ cat food. The National Research Council has established generalized calorie/energy needs for cats based on lean or overweight.

We need a better system.

The AAFCO Complete and Balanced system is flawed. It neglects to consider the energy differences of pets. And the AAFCO Complete and Balanced system is not directly linked to the feeding directions on pet food labels (more on this below).

The European pet food industry organization FEDIAF has a much better system than AAFCO.

Nutrient requirements (to base the Complete and Balanced claim on) under AAFCO for dogs have only two categories.

Dog Food per AAFCO

  1. “Adult Maintenance” (active adult dogs, inactive adult dogs and senior dogs)
  2. “Growth and Reproduction” (puppies and nursing females)

Nutrient requirements (to base the Complete and Balanced claim on) under FEDIAF (in Europe) for dogs have multiple categories, including young puppies, older puppies and nutrient profiles recognizing the varying calorie requirements of active or inactive dogs.

Dog Food per FEDIAF

  1. “Recommended nutrient levels for early growth and reproduction” (young puppies and nursing females)
  2. “Recommended nutrient levels for late growth” (older puppies)
  3. “Recommended nutrient levels for adult dogs based on a MER of 110 kcal/kg BW” (active adult dogs)
  4. “Recommended nutrient levels for adult dogs based on a MER of 95kcal/kg BW” (inactive adult dogs)

Nutrient requirements (to base the Complete and Balanced claim on) under AAFCO (in the US) for cats have two categories.

Cat Food per AAFCO

  1. “Adult Maintenance” (active adult cats, inactive adult cats and senior cats)
  2. “Growth and Reproduction” (kittens and nursing females)

Nutrient requirements (to base the Complete and Balanced claim on) under FEDIAF (in Europe) for cats includes nutrient profiles recognizing the varying calorie requirements of active or inactive cats.

Cat Food per FEDIAF

  1. “Recommended nutrient levels for feline growth and reproduction” (kittens and nursing females)
  2. “Recommended nutrient levels for adult cats based on a MER of 100kcal/kg BW” (active adult cats)
  3. “Recommended nutrient levels for adult cats based on a MER of 75kcal/kg BW” (inactive adult cats)

Europe recognizes the diet should be balanced per activity level/calorie requirements of the pet. Europe’s regulatory system allows for high calorie pet food or low calorie pet food while containing the same vitamin and mineral level required for pet body size.

The US – AAFCO – does not.

To read the FEDIAF nutritional guidelines for complete and balanced pet food, Click Here.

Unfortunately, the only resolve to this issue will need to come from AAFCO. Nutrient profiles need to be added for active and inactive dogs and cats, and senior cats and dogs. We will be making a proposal to AAFCO to add this topic to the July 2018 meeting.

We will also be adding to our request for discussion the vast variation of feeding directions on pet food labels. Below are a few examples of dramatic variations to manufacturer feeding directions for cat food…

And a few variations to manufacturer feeding directions for dogs…

These issues – Complete and Balanced ignoring the calorie requirements of active or inactive pets, feeding directions being all over the map  – are AAFCO failures. It is unknown why these issues have been ignored. All we know with certainty is AAFCO must do better with existing regulations. We will ask – and of course we will keep consumers updated to AAFCO’s decisions.

AAFCO Pet Food Committee co-chair Kristen Green was emailed January 29, 2018 with my initial questions on this issue. She promised a response within the week. That response was not received.

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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12 Comments

12 Comments

  1. T Allen

    February 5, 2018 at 10:00 am

    Once again you have outdone yourself Susan! Have you considered moonlighting doing consulting work at the Veterinary colleges? A one day seminar with you could make a HUGE difference in the lives of young vets as well as their future clients! Thank you for another exemplary lesson in why AAFCO doesn’t meet our standards for scientific rigor or trustworthiness!

    • Susan Thixton

      February 5, 2018 at 10:28 am

      Thank you. I would welcome any opportunity to speak to veterinary students!

      • Pet Owner

        February 5, 2018 at 9:30 pm

        You should market yourself in that direction! ?

  2. anonymous

    February 5, 2018 at 11:27 am

    There is an even bigger problem associated with COMPLETE AND BALANCED. Because there is no requirement for the manufacturer to state whether the food is COMPLETE AND BALANCED as it is in the bag (after its cooked) or if its COMPLETE AND BALANCED after its formulated and before it’s cooked and made into little kibble (same is true of dehydrated, fresh etc). So you don’t even know if what is on the bag is PRE cook or POST cook. In fact, most foods are COMPLETE AND BALANCED “as formulated” but not once they are cooked and then placed into the bag (when they are dried and more moisture may come out than anticipated. A whole other level of problem to the complete and balanced claim.

  3. Debbie Perkins

    February 5, 2018 at 12:19 pm

    Thank you Susan! This is what I’ve been saying to veterinarians for years and no one has ever listened. When my bulldog had to lose weight and maintain said loss because of knee issues and surgery, I had to enlist a nutritionist to have a diet formulated. Because just feeding less like the bags say is not the answer. My bulldog weighs 55 pounds and can only eat around 540 calories/day without gaining weight.

  4. Janice

    February 5, 2018 at 12:22 pm

    The NRC (of the National Academies) offers a way to determine nutrient requirements based on the activity of the dog, e.g., on p. 359 of the 2006 Nutrient Requirements book, method 2. The weight used in calculating nutrient requirements is metabolic weight, which can be determined by a formula.

  5. Janet

    February 5, 2018 at 12:30 pm

    Thank you, Susan, for pointing out these discrepancies as well as the comparison with the European system. These are details that the majority of pet owners probably don’t even think about and just trust “their government” to be on top of. Most people don’t even know what AAFCO is and probably don’t even think about who establishes pet food guidelines or regulations.

  6. Tryniti

    February 5, 2018 at 1:38 pm

    Honestly, I’d be more worried about issues in this regard; Diets that claim they can meet your pet’s nutritional needs for the life of your pet, when NO such long-term study has actually been done by any of these companies. A 6-month feeding trial is AAFCO’s gold standard. That is not enough time to determine if a pet can and should live off of one food their entire lives, as many do. I can’t think of a single human being that has a complete and balanced meal, every single meal. It’s more important that you get all the nutrients you need to even out in about a week. This is something I learned when switching my dog to a raw food diet. So, no, they don’t need every single vitamin and mineral in every meal. Just like we don’t. This is honestly not something I’d be worried about. I think if pet owners were encouraged away from dry foods, and away from feeding a single formula for their whole pet’s life, that would be a much better solution to this problem. Just my two cents! I still, of course, appreciate everything you do to illuminate real issues in the pet food industry and how you fight for pet’s health in this country.

    • JaneeS

      February 11, 2018 at 6:12 pm

      That’s why I believe a rotational diet is good, using different brands, different protein sources or formulations. I think it helps even out the required and changing nutritional needs of my dog. I started doing this when my girl was a pup. She’s really healthy, so I think it works for her. Now she can eat anything at any meal without having food slowly introduced, just like humans can consume different foods all the time. She can eat raw, cooked foods, canned foods, human grade or pet feed, like kibble, as a last resort. I know that not every pet is ok with food being switched and some have allergies, so this might not be possible for everyone.

  7. ann

    February 5, 2018 at 2:04 pm

    There are so many dog and cat food that is all for one in that it is one food for kittens/puppies, Adults and Seniors. For example Natural Balance, there is no way that one food can be balanced for a pet at different stages of their life. They all have different needs at different ages.

  8. Pet Owner

    February 5, 2018 at 9:29 pm

    What about Vitamins and Minerals, like “One A Day” for humans. They claim complete supplementation. But wouldn’t effectiveness vary due to the inherent differences in people, such as age, activity, metabolism, deficiencies, etc.. Maybe the PFI is using that loophole for their own purposes?

  9. landsharkinnc

    February 6, 2018 at 7:57 am

    and ( unless you have revised your thinking on this ) AAFCO doesn’t ‘count calories’ the same way we do — from your article ‘Pet Food Calorie Misinformation ‘ from Jan 2012 .. this is like throwing the baby out with the bath water …. NOTHING on the processed food labels really address the dog/cats needs.

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