Consumer Input Requested – Definition of Feed
AAFCO is defining the word ‘feed’. With permission from AAFCO, here are the definitions proposed thus far. Consumer input is requested.
Last year AAFCO defined ‘feed grade’; “Feed Grade: Material that has been determined to be safe, functional and suitable for its intended use in animal food, is handled and labeled appropriately, and conforms to The Federal Food, Drug and Cosmetic Act unless otherwise expressly permitted by the appropriate state or federal agency.”
This year AAFCO wishes to define ‘feed’. A working group was formed; regulatory, industry and consumer advocates are part of the group. Our first webinar meeting was last week. AAFCO explained the definition they are wanting is the product itself – what is feed? Feed grade – which was defined last year – is a descriptive term relating to the quality of the pet/animal product (human grade is a descriptive term too). Now they are wishing to define the product itself – feed.
With permission from the working group leader (AAFCO member/State Department of Agriculture), multiple possible definitions are listed below for consumer input.
(1) Materials eaten by animals.
Input: This definition is very simple, but clear.
(2) All material(s) which are consumed or intended to be consumed by animals, including pets and specialty pet, including raw materials and ingredients.
Input: A little more detailed than #1, but clearly defines that ‘feed’ is what animals consume (not food).
(3) All food and/or food ingredients which are consumed or intended to be consumed by animals other than man.
Input: This definition uses the term food which I personally disagree with. Feed does not abide by food law; in my opinion the definition of feed should not reference food unless it IS food (legally). The exception would be human grade pet foods – which do meet the legal requirements of food.
(4) Edible material(s) which are consumed by animals other than humans and contribute energy and/or nutrients to the animal’s diets. (1) Substances fed for a nutritive effect in the animal (e.g., providing one or more nutrients or other nutritive effect); and (2) substances that have technical effects in the food (e.g., anti-caking agents, binders, emulsifiers, enzymes, mixing aids, preservatives, processing aids, stabilizers, and substances added for aroma, flavor, or other technical effects) rather than nutritive effects in the animal. It includes pet food, specialty pet food, animal feed, and raw materials and ingredients. This is intended to be equivalent to the materials also described as food in 21 USC 321.
Input: Very complicated definition, but includes all of processing ‘substances’ included in manufacture. I disagree with the first word “Edible”. Many materials used in pet food are deemed “Inedible” by USDA.
(5) Edible material(s) which are consumed by animals and contribute energy and/or nutrients to the animal’s diet. (Usually refers to animals rather than man.)
Input: Again I disagree with the first word “Edible”.
(6) An article intended for use for food or drink for animals other than humans, including raw materials and ingredients.
Input: The word ‘food’ included in this definition concerns me. Feed is legally not food.
Defining ‘feed’ is challenging. The ‘material’ animals eat should be food (law defines food as what humans and animals consume), but because FDA and each State Department of Agriculture does not enforce food law with the material animals eat – the term ‘feed’ is needed. A clear definition of feed should tell consumers the ‘material’ could be a violation of law, BUT if the definition did – it gives (almost) legal permission for the adulteration. So…what should the definition of feed be? How should it be phrased in order to make it clear to consumers feed is not food, but not give permission for feeds to violate law?
Please provide your input on which of the above definitions you like or provide an improved definition in the comment section below. The next meeting is scheduled for September 21, 2016. Consumer input will be provided in the meeting.
Note: Please do not send your comments to AAFCO. Post them here and they will be collected and provided to the working group at the next meeting (9/21).
Wishing you and your pet(s) the best,
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