Speaking to Consumers through Pictures
One of my pet food peeves is when those responsible for enforcing pet food regulations ignore violations of pet food law. No one is enforcing a significant pet food regulation and consumers are being misled because of it.
Would you eat this for dinner?
What about this? Would you consider this food for yourself or your family?
Well guess what – these beautiful images of real food are part of pet food labels.
Pet food – the majority of pet foods – are using images of human grade food on labels. These images tell consumers the pet food is made from human grade ingredients.
Human grade ingredient claims is a sore spot for regulatory authorities, that is…the words “Human Grade”. There is little more that will cause a regulatory official (State Department of Agriculture and FDA) to take swift action other than the two little words “Human Grade” on a pet food label. Officials have forced manufacturers to remove products from store shelves all because of those two little words (“Human Grade”). In fact, for a pet food to be allowed to state those two words – “Human Grade” – on their labels, they have to go through a lengthy and detailed verification process with the FDA. Once the FDA verifies that each and every ingredient meets the legal requirement of “food” they are provided with FDA’s ‘Letter of No Objection’. No objection to the human food/human grade claim.
So, in order for a pet food to ‘say’ Human Grade in words, they must go through the FDA Letter of No Objection process. But no one – and I mean no one – cares if pet foods speak the very same words through images.
What is your opinion…Are the pictures on the following pet food labels ‘saying’ Human Grade without words? Are they speaking to the pet food consumer with images?
Of course these images are speaking to consumers. And the above is just a tiny portion of pet food labels – or pet food websites – that display images of human grade food. Better than 50% of all pet food labels, and a huge majority of pet food websites display images of Human Grade ingredients on them. Most who display these types of human grade food images, have NOT obtained a FDA Letter of No Objection to make the Human Grade claim.
There is a law within pet food regulations that is specific to images on a pet food label…
The law is: PF2.(c)
“A vignette, graphic, or pictorial representation on a pet food or specialty pet food label shall not misrepresent the contents of the package.”
In other words, pet food regulations require that a picture or graphic on a pet food label MUST portray the actual contents of the pet food. If this law was enforced, the only pet foods that would display human grade ingredients on the label would be those that have gone through the FDA ingredient verification process (Letter of No Objection).
But instead…each and every regulatory authority (each State Department of Agriculture and FDA) chooses NOT to enforce this law. In the last two years (before things have gotten out of control as they are now) I have complained to regulatory officials numerous times about this issue. They have stated to me this is not a health risk to pets – and they don’t have time to enforce this regulation.
Motorists going down the highway all slow down when the police are around with their radar guns, everyone abides by speed limits. Pet Food knows there is no need to abide by speed limits. There is no police around. They know that regulatory authorities will come down swiftly and firmly if they state the words ‘Human Grade’ on the labels. They know no regulatory authority cares if they say the same words through pictures.
Because State Department of Agriculture and FDA don’t enforce their own laws, consumers are being misled to believe many pet foods are made with human grade ingredients when they are actually made with feed grade/pet grade ingredients. As things stand now, pet food companies that are actually made with human grade ingredients are forced to jump through regulatory hoops, pet foods that are not made with human grade ingredients are allowed to openly violate regulations.
If you see images of human grade ingredients on a pet food label or website, before you believe that the pet food is made from human grade ingredients, call or email the manufacturer and ask them for a copy of their FDA Letter of No Objection. Because those responsible for enforcing regulations are not acting responsibly (protecting the consumer), we all must do our homework before we believe any pet food. If you discover the pet food actually does not have FDA permission to make the Human Grade claim, please report the product to your State Department of Agriculture for misleading images. You can find your State Department of Agriculture contacts by clicking Here.
For the upcoming AAFCO (American Association of Feed Control Officials) meeting (early August 2015), the co-chair of the Pet Food Committee recently sent an email to all committee members asking for suggestions of discussion. The human grade claim on pet food labels was mentioned as a possible.
I sent my suggestion to AAFCO that product images are openly making the human grade claim through the use of pictures. I asked that this discussion take place at the next meeting as pet food labels are out of control and misleading consumers to believe human grade ingredients are used in most pet foods (when the opposite is true). I was told no. The only discussion that might take place is regarding the words human grade on a label, the discussion of misleading images will not take place.
I will continue to ask regulatory authorities about this issue, at every opportunity. Will they ever listen? Will they enforce the law and stop misleading images on pet food labels? They should. There is no excuse.
Wishing you and your pet(s) the best,
What’s in Your Pet’s Food?
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The 2015 List
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