If FDA and AAFCO would abide by their own regulations, the biggest change in pet food since the invention of kibble would be a name change. It should be called Cat Feed and Dog Feed. The mission: a legal name change.
First, a couple of questions for you.
What do you understand to be the difference between an animal ‘food’ and an animal ‘feed’?
To your understanding, is there a quality difference between a ‘food’ and a ‘feed’? Is one perceived to be higher quality than the other?
The commercial products that pets consume are allowed to be called ‘food’, but they are not held to any regulatory ‘food’ requirement. They are allowed to be called ‘food’, but they are not required to be manufactured with ‘food’ ingredients, they are not manufactured in a ‘food’ facility, and they are not warehoused or transported as ‘food’ is legally required. The system is skewed and consumers are being misled.
The legal definition of food is: “articles used for food or drink for man or other animals”. However because federal and state regulatory authorities don’t enforce the legal requirements of ‘food’ for animals, the term ‘feed’ is applied to what animals consume.
Much of the waste from the production of human ‘food’ becomes animal ‘feed’. Some of this waste can be a good source of nutrition for pets (such as internal organs from healthy, slaughtered animals), but unfortunately some of the waste is hideous and the thought of any animal consuming it under any circumstance is absurd (such as euthanized, diseased animals rendered to become meat meal or animal fat). ‘Food’ is legally not allowed to contain any part of a euthanized animal, a diseased animal or an animal that was rejected by the USDA. ‘Feed’ is provided a loophole to utilize this waste through FDA Compliance Policies.
‘Food’ is held to a high standard for manufacturing, warehousing and transportation. ‘Feed’ (currently) has little to no legal standard for manufacturing, warehousing and transportation.
Even though pet food is allowed to be termed ‘food’ – the largest majority of commercial pet foods do not meet any of the legal requirements of food.
It should be termed pet feed. Cat Food should be changed to Cat Feed. Dog Food should be changed to Dog Feed. I will be making a formal request to FDA and to AAFCO to legally require the products that cats and dogs consume be termed in direct relation to what they are made from, and manufactured as – feed. Consumers deserve to understand what they are purchasing.
Significant. There are actual pet ‘foods’ out there – made using 100% ‘food’ ingredients and manufactured in certified ‘food’ facilities. In order for these companies to disclose to consumers they are using actual ‘food’ ingredients and that their products are made in an actual ‘food’ facility – these companies have been forced by State and Federal Authorities (under threats of their products being pulled from store shelves) to obtain a ‘Letter of No Objection’ from FDA.
What is a ‘Letter of No Objection’? It’s a letter that states the FDA does not object to these manufacturers calling their pet products what they actually are…food. State and Federal Authorities behind the scenes have harassed manufacturers of actual pet ‘foods’ – threatening to pull their products from store shelves – if they don’t provide FDA with a quality statement affidavit from each ingredient supplier and provide evidence the ‘food’ is manufactured in a certified ‘food’ facility. (The other pet ‘foods’ don’t have to do this.)
And the kicker…to my knowledge, there is no formal procedure established by FDA (provided to the public) for this Letter of No Objection. Without published formal procedure for the Letter of No Objection, at FDA’s discretion it can be approved or rejected – with no explanation.
So…State and Federal regulatory authorities allow a pet food to be called a food even though it doesn’t meet any legal requirement of a food while making actual pet foods jump through hoops that even a food for a human doesn’t have to provide.
And in the middle of this mess is consumers – who are being misled into believing the pretty images of grilled meats on the label of that cat or dog product is actually ‘food’. Right now – the very same ingredients (including waste ingredients not allowed in ‘food’) used in cattle feed, pig feed, horse feed, or poultry feed is being sold to consumers as pet ‘food’. ‘Food’ is implied everywhere with pet products, when very few actually contain one drop of ‘food’ as it is legally defined.
I have sent both FDA and AAFCO requests asking what the official procedure would be to legally change the name pet food (cat food, dog food) to pet feed (cat feed, dog feed). The exception would be those companies that have already proved to FDA or that can prove to FDA they are an actual ‘food’. The FDA has agreed to a face to face meeting at the upcoming AAFCO meetings in Sacramento, CA. regarding this issue. AAFCO President elect responded, but directed me to the Pet Food Committee; request was sent, no response yet.
Consumers deserve to know what they are buying – food or feed. Regulatory authorities need to take swift action to require the products designed for our pets are termed according to the standards of their ingredients and how they are manufactured.
Please provide your comments below – I will take your messages to FDA and AAFCO. Please post your comment to the food/feed name change. Tell authorities your understanding of ‘food’ and ‘feed’. Tell them your challenges when trying to find a safe ‘food’ for your pet. Tell them what you need from regulatory authorities to assure your pet’s food is safe. Hint: If you want these officials to read your message – be polite.
This is step one – telling regulatory authorities what consumers feel, and presenting them with their own regulations. Follow-up steps will be determined by their response.
Wishing you and your pet(s) the best,
What’s in Your Pet’s Food?
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