The Next Step – Consumer Support
The procedural request has been submitted, now it is time for pet owners to gather signatures telling AAFCO consumers support labeling changes requiring pet feed to be labeled as feed. Everyone’s help is needed.
What we want…
Clearly label pet products as ‘Feed’ or ‘Food’; if the product meets the legal requirements of food it will be termed Cat Food or Dog Food on the label and in all marketing – if the product does not meet the legal requirements of food it will be termed Cat Feed or Dog Feed on the label and in all marketing.
Simple, easy to understand transparency for consumers.
Everything boils down to this one sentence of law (Federal Food Drug and Cosmetic Act):
In prescribing a definition and standard of identity for any food or class of food in which optional ingredients are permitted, the Secretary shall, for the purpose of promoting honesty and fair dealing in the interest of consumers, designate the optional ingredients which shall be named on the label.
Feed grade pet product ingredients ARE “optional ingredients” permitted by FDA and each State Department of Agriculture. “For the purpose of promoting honest and fair dealing in the interest of consumers”, these pet products must be declared as Cat Feed and/or Dog Feed on the label.
The procedural steps have been completed (FDA requested we submit the feed/food labeling issue as an addendum to our Citizen Petition filed October 2016). Here is the link to the Regulations.gov website (our addendum is the second item): https://www.regulations.gov/docket?D=FDA-2016-P-3578
In part – we submitted the following addendum:
(5) This petition requests the Commissioner to establish a standard of identity for pet food/treat products providing consumers clarification. Pet food/treat standard of identity would be a simple, easy to understand classification of ‘pet feed’ or ‘pet food’. Pet products that meet the requirements of “Human Grade” as defined by AAFCO would be termed “Pet Food” (Example: cat food, dog food). Pet products that do not meet the full requirement of Human Grade would be termed “Pet Feed” (Example: cat feed, dog feed) with the option for verified exception (a) below.
(a) Similar to the USDA grading of meat, this petition requests the Commissioner establish an optional fee-based pet product ingredient quality verification system; providing consumers a validated standard of identity to quality of ingredients even if the pet product was manufactured in a USDA or pet food facility (does not meet the full requirement of Human Grade pet food). Pet products that complete the verification process (verifying all human grade ingredients) would be provided opportunity to state on product labels and in marketing the claim ‘Verified Pet Food’ (or similar disclosure) providing consumers with another level of standard of identity.
Reverification would be required at any ingredient change or supplier change.
This petition requests Dog Feed/Cat Feed, or Dog Food/Cat Food, or Dog Food Verified/Cat Food Verified to replace the current classification – all products classified as ‘food’. Example: ABC Brands Gourmet Gravy Beef Dog Feed or ABC Brands Gourmet Gravy Beef Dog Food. Pet Feed or Pet Food or Pet Food Verified standard of identity to be required on the product label, the product website, and all marketing material.
This petition requests the definition of ‘pet food’, ‘pet food verified’, and ‘pet feed’ become public information available on the FDA website.
This petition requests the Commissioner to promptly establish the above standard of identity for pet food products providing consumers with honest and fair information. Should participation from AAFCO (Association of American Feed Control Officials) be required, this petition requests the Commissioner to work with AAFCO to promptly facilitate this consumer transparency update.
Now the hard part…
FDA believes the fastest path to making this feed/food declaration of pet products is through the AAFCO process. FDA agreed to introduce the disclosure at the upcoming AAFCO meeting (beginning August 10, 2017).
Going ‘through the AAFCO process’ means…
- FDA introduces the suggestion at the meeting in August 2017;
- Industry will throw a hissy fit;
- Because existing regulations within the AAFCO Official Publication will need to be changed, the existing Pet Food Labeling Modernization Working Group will (consisting of regulatory, consumer advocates and industry advocates) will write/update the necessary laws;
- The new regulations developed by the Working Group will be discussed at a future AAFCO public meeting, more industry hissy fit, AAFCO members will vote to approve or deny the labeling updates.
We are requesting the schedule to follow this timeline…
- Update all existing Model Regulations for Pet Food and Specialty Pet Food to include the feed/food/verified food distinction to be completed no later than the August 2018 Annual Meeting. Updated model regulations to be published in the 2019 AAFCO Official Publication.
- Deadline for pet food manufacturer compliance no later than 1 year from publication of the 2019 Official Publication (deadline: January 2020).
Feed has a loud voice at AAFCO, their complaints regarding required feed/food labeling will be listened to by AAFCO. Consumer voices need to be louder!
Although it would be wonderful if hundreds of thousands of consumers could attend an AAFCO meeting declaring their support for the feed/food required labeling, at $500 just to attend – that’s not going to happen. The next best thing – is hundreds of thousands of signatures on a petition telling AAFCO to swiftly move the feed/food required labeling through.
So many consumers ask me how can they help? This is how. Help get signatures on this petition.
The petition is hosted on the Care2 website, here is the direct link: http://www.thepetitionsite.com/924/546/122/tell-aafco-consumers-support-%E2%80%98food%E2%80%99-or-%E2%80%98feed%E2%80%99-disclosure/
Sign and share! Send the petition to every pet food consumer you know – Care2 makes it easy to share.
Signatures will be delivered to AAFCO at the August meeting (beginning 8/10/2017).
This change in pet food won’t happen easily – industry will battle us. But…with thousands – hundreds of thousands of signatures on this petition consumers will be a loud voice that AAFCO will need to listen to. Sign and share! Thank you in advance.
Wishing you and your pet(s) the best,
What’s in Your Pet’s Food?
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