What They See, What We Need
Consumers won’t be happy when they see what State regulatory authorities look at on pet food labels. This is a concerning problem, but there is a simple resolve. States could work together to improve the safety of pet food.
Each year, pet food/treat manufacturers are required by law to register their company with each State Department of Agriculture (U.S.) they sell products in. As well, most State Department of Agriculture agencies require pet food/treat manufacturers to register each product they sell within state boundaries (often charging a fee for each registration). While the goal of this registration is certainly an effort to help assure the safety of pet foods, knowing what regulatory authorities check makes reaching that goal doubtful. Is pet food safe with the current regulatory system?
Georgia Department of Agriculture requires pet foods/treats to register each year, deadline January 31. Georgia charges pet food manufacturers $75.00 to register the company and $40.00 for each “pet food or specialty pet food less than or equal to 10 pounds” sold within the state. As well, pet food/treat manufacturers are required to submit each product label (each year with any changes) to Georgia Department of Agriculture with the registration; labels are scrutinized by Georgia to assure legal requirements are met.
The state of Georgia posts all pet food registration information/all products registered on their website. Georgia provides a ‘search’ option providing consumers with the ability to look up any product registered with the state. As example, Blue Buffalo Pet Food has 411 different products registered with Georgia Department of Agriculture. The registration of these 411 Blue Buffalo products provides Georgia with $16,440.00 in registration fees each year (just from Blue Buffalo).
Hill’s Pet Nutrition has 338 products registered with the state of Georgia – providing $13,520.00 in registration fees each year.
Mars Petcare has 408 products registered with the state of Georgia – providing $16,320.00 in registration fees each year.
Nestle Purina Petcare has 827 products registered with the state of Georgia – providing $33,080.00 in registration fees each year.
(For these four pet food companies – 1,984 different pet food/treat products, totaling $79,360.00 in registration fees only to one state, each year.)
But this is just one state. The same registration requirement, label submission/label scrutiny, and registration fees are required by law in almost all of the other 49 states.
Imagine how much money is provided to each State Department of Agriculture for registration fees for every pet food/treat manufacturer. For just the four pet food companies mentioned above (Blue Buffalo, Hill’s, Mars, Purina) – an estimated $2 to $4 million dollars a year is paid to state government in registration fees each year (some states charge higher fees, some states charge lower).
So…this whole process seems VERY regulatory – giving consumers the impression that each State Department of Agriculture is ‘on top’ of pet food companies watching every move they make. Certainly States are verifying lots of things with all those required label submissions each year to assure consumers pet foods in their State are safe…right? Not quite.
To consumers, significant pet food/treat label information that should be verified by someone of authority would be things like quality of ingredients (are they feed grade or food grade?), verification that the ingredients listed on the label are actually in the pet food (and nothing else), and country of origin of ingredients (including all supplements).
But that’s not what is important to regulatory. With pet food labels – on average – regulatory authorities only check to make sure pet food labels submitted to them each year include these things…
- Brand name
- Product name
- Species – such as ‘dog food’ or ‘cat food’
- Quantity statement – the weight of the pet food in the container
- Feeding Guide – directions for consumers on how much of the pet food to provide per size of pet
- Guaranteed Analysis
- List of Ingredients
- Life stage – such as Kitten, Adult, Senior
- Nutritional Adequacy Statement – such as is the pet food ‘Complete and Balanced’ and information if the pet food meets AAFCO nutrient profiles or if the pet food was determined to be complete and balanced per a feeding trial
- Manufacturer or Distributor name and address
Just considering the front and back of a pet food label (not information on the side panels), here is what a typical pet food label looks like (picture one), the information that regulatory looks at on the front label (picture two), and what regulatory pays no attention to (picture three)…
And the back of the label…
In other words, the majority of information printed on a pet food label – a label that definitely influences pet food consumers – is NOT verified for accuracy, NOT scrutinized for adherence to law, NOT even looked at by any regulatory authority. Even though this label is required by law to be submitted each year to almost every State Department of Agriculture (opportunity for 40+ regulatory agencies to scrutinize all claims on the label), only a few things are actually looked over. This same problem applies to thousands of dog and cat food products and thousands more dog and cat treat products.
The problem and a simple resolve.
The problem is that State Department of Agriculture agencies do not work together. Georgia Department of Agriculture reviews the minimal required information on the label, Florida Department of Agriculture reviews the same minimal required information on the label, Texas Department of Agriculture reviews the same minimal required information on the label, and on and on. Each state – each year – reviews the same minimal information on pet food/treat labels. They repeat (and repeat and repeat) the exact same work being done in most other states.
To be fair to State Department of Agriculture – the review each year of even the minimal required label information on 10,000+ pet food/treat products is a massive undertaking. Thousands of emails/phone calls back and forth with manufacturers are required, thousands of hours of work invested.
But…this system is antiquated. This current system benefits no one but pet food manufacturers (allowing them to make misleading and potentially false claims on labels). Because label review is repeated and repeated and repeated by each (most) State Department of Agriculture agencies, there is no time or government budget left to scrutinize the pet foods/treats as consumers need regulatory to do.
Most of these State Department of Agriculture agencies send representatives to AAFCO (Association of American Feed Control Officials) – BUT year after year – meeting after meeting, no State Department of Agriculture representative ever thinks/discusses how can they as individual States work together to improve the system.
A better system would be…
States sharing the label review workload.
With all the technology at our fingertips, State Department of Agriculture agencies could easily share the workload of pet food/treat label review. Products scrutinized could be held in a database – only accessible to other agencies – where any State representative at any time could double check the review.
With all this time and budget saved from repeating and repeating the same review process State after State, a better system would be States working together to scrutinize the full label (and website).
With a little planning and team work – and again with technology at our fingertips – State Department of Agriculture agencies could easily share the workload to scrutinize the full pet food/treat label – and the pet food website (considered an extension of the label). In the suggested database accessible to all State agencies – representatives could add notes of violations specific to their own State (which just might end up being a violation in another state which wasn’t caught by another representative).
Imagine the regulatory system we could have if States worked together? Consumer complaints could be easily shared. Pet food testing/investigations could be easily shared between all of the states. Misleading and/or false information on pet food labels and websites could finally be stopped. No one State can manage scrutiny of 10,000+ pet food/treat labels and thousands of pet food websites. Consumers lose when States try to manage the massive pet food industry alone.
What can you do?
Write an email/letter to the head of your State Department of Agriculture. Example letter below.
As a pet owning resident of this State, I write to alert you to a serious problem in pet food. I am asking [your State] to consider an alternative program that benefits our State and benefits consumers.
Pet food/treat manufacturers are required to register in each State they sell products in; most States require review of labels of more than 10,000 different pet food/treat products. This exact same review process is repeated and repeated in multiple States. Because of the massive workload, many label concerns are ignored (including pet food websites which are an extension of the label).
The perfect example of a problem ignored was Evanger’s Pet Food – sold in all U.S. states. In January 2017, a dog died in Washington state because the pet food was sourced from pentobarbital contaminated meat. The Evanger’s Pet Food website (extension of the label) told consumers the meat was “Human Grade”. Many pet food consumers purchased this pet food directly because of this “Human Grade” claim. Pet food regulations have strict requirements for the use of the term “Human Grade” which were NOT met by this pet food company. In other words, the “Human Grade” claim should have NEVER been on the pet food website. Washington State Department of Agriculture (where the pet food was sold) did not scrutinize the Evanger’s website (stopping the false/misleading claim), neither did 49 other State Department of Agriculture agencies. A dog died, multiple others became ill because a pet food company was making a false/misleading claim that no regulatory agency bothered to verify (and each one of them should have).
My suggestion is for our State to build a coalition with other State Department of Agriculture agencies where instead of repeating the exact same workload in many States – work could be shared. States could share pet food label review work, allowing them more time to scrutinize the full pet food label and websites. This isn’t about changing law; we have laws in place that could be better implemented if States worked together. Our current system is antiquated. Pets are dying because each State tries to manage the massive pet food industry alone.
Please make this happen. Establish a system respectful of each State’s laws but enables a system to better ensure the quality and safety of pet food, to better enforce existing laws.
Change needs to happen. Our current system is a failure.
Wishing you and your pet(s) the best,
What’s in Your Pet’s Food?
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