Is a 2,000% increase of a required pet food nutrient too much? No established regulatory maximum level of nutrients IS a risk.
Some regulatory authorities test pet food on a regular basis, most of the testing performed is for nutrient requirements (Protein, Fat, Minerals). Most of the time these test results are not public information, but Missouri Department of Agriculture is a regulatory authority that does make results public. Missouri testing results are provided in a database on the agency’s website.
In the past year, Missouri Department of Agriculture (MDA) tested 24 dry cat foods and 27 dry dog foods for protein, fat, moisture, and required mineral content.
Cat Food Test Results
From the 24 cat foods tested in the past year by MDA, below is a bar graph showing the varying levels of calcium. The first bar is the AAFCO required minimum amount of calcium for adult cat food (0.6%), the second bar is the lowest result of calcium (Royal Canin Feline Care Nutrition Hairball Care Dry Cat Food) and the third bar is the highest result of calcium (Essence Air and Game Fowl Cat Recipe Dry).
Pet food regulations have NO maximum level of calcium established for cat food, so ANY LEVEL (beyond 0.6%) of calcium is acceptable. There is a 500% increase in calcium levels from the required minimum to the highest test result.
Iron results from cat food testing show more dramatic differences. Pet food regulations require a minimum of 80 ppm (parts per million) iron in cat food – no maximum level of iron established for cat food. Lowest result for iron was Iams Proactive Health Urinary Tract Health with Chicken Cat Food, highest result was Essence Ranch and Meadow Cat Recipe Dry.
Even though there is a 1,200% increase in iron levels from the regulatory minimum to the highest result – both cat foods are considered “Complete and Balanced“.
Pet food regulations require a minimum of 5 ppm Copper to meet the “Complete and Balanced” cat food claim. From regulatory testing, the lowest result was of Top Kat Premium Cat Food Gourmet Formula Chicken, Turkey and Fish Flavors – the highest result was of Purely Feline Indoor Cat Ocean Whitefish & Turkey Meal Recipe Cat Food.
From required minimum of copper in cat food to the highest level tested by MDA – there was an 780% increase of copper.
Pet food regulations require a minimum of 75 ppm Zinc to meet the “Complete and Balanced” cat food claim. Regulatory testing found the lowest level of zinc in Top Kat Premium Cat Food Gourmet Formula Chicken, Turkey and Fish Flavors – the highest level of zinc in Whole Hearted Grain Free Salmon Recipe All Life States Cat Food Dry.
And again, there is a 550% increase of zinc from required minimum to the highest level tested by MDA when both pet foods are considered “Complete and Balanced“.
Dog Food Test Results
Over the past year, Missouri Department of Agriculture (MDA) tested 27 dry dog foods.
Pet food regulations require a minimum of 5.5% Fat in an adult dog food, no maximum level is established in regulation. MDA test results showed Rachael Ray Nutrish Turkey, Brown Rice & Venison Recipe Dog Food Dry as the lowest result for fat – Extreme Dog Fuel 30-20 Pro-Athlete as the highest result.
MDA test results showed an increase of 244% from minimum required fat to maximum result.
Pet food regulations require an adult dog food to contain a minimum of 0.08% sodium – no maximum level of sodium is established in regulations. The lowest level of sodium in dog foods tested by MDA was for Canidae Grain Free Pure Ancestral Freeze-Dried Raw Coated Avian Formula Dog Food – the highest level of sodium in dog foods was for Rachael Ray Nutrish Turkey, Brown Rice & Venison Recipe Dog Food Dry.
There was a 687% increase of sodium from the minimum required sodium level to the highest results.
Pet food regulations require an adult dog food to contain a minimum of 5 ppm Manganese, regulations have no maximum level established. The lowest level of managanese of dog foods tested by MDA was Diamond Professional Chicken & Pea Formula for Dogs – the highest level was American Natural Premium Large Breed Puppy Dog Food.
Test results showed a 1,320% increase of manganese from the required minimum to the highest result.
Pet food regulations require an adult dog food to contain a minimum of 40 ppm Iron, regulations have no maximum level established. The lowest result for iron was Nutro Wholesome Essentials Small Bites Adult Pasture-Fed Lamb & Rice Recipe Dog Food Dry – the highest level of iron was Farm Table Grain-Free Chicken & Sweet Potato Recipe Dog Food for All Life Stages.
Test results showed more than a 2,000% increase of iron from the required minimum to the highest result.
Change is Needed
The dramatic differences from minimum required levels of nutrients to the highest levels found in lab analysis should be sufficient evidence that maximum levels of nutrients should be established in regulations. What health consequences do pets suffer from by these dramatic nutrient differences?
Science links high levels of iron to cardiomyopathy. From Iron Overload Cardiomyopathy in Clinical Practice (human medicine) (bold added for emphasis): “Iron overload is the accumulation of excess body iron in different organs as a result of increased intestinal absorption, parenteral administration, or increased dietary intake. The term iron overload cardiomyopathy (IOC) recently has been introduced to describe a secondary form of cardiomyopathy resulting from the accumulation of iron in the myocardium…” Could excess iron be linked to the current issue of dilated cardiomyopathy in cats and dogs?
Copper is another example. Scientists will be publishing a paper very soon on Copper Storage Disease documented in dogs linked to excess copper in pet food (to my understanding most of the documented cased are linked to the pet food ingredient Copper Sulfate). Missouri Department of Agriculture cat food results ranged from 10 ppm to 44 ppm of copper – dog food results ranged from 8 ppm to 32 ppm copper. Do we really need to wait for more pets to die before a maximum level of copper is established?
Pet owners can take action by…
- Ask your State Department of Agriculture to work with the Association of American Feed Control Officials (AAFCO) to establish maximum levels of all pet food nutrients. You can find your state representatives by clicking here.
- Ask your State Department of Agriculture to publish all ‘feed sampling’ (what they call it) testing results on their website – in a location easy for pet owners to find.
- Ask the FDA to establish maximum levels of all pet food nutrients. You can email FDA at: AskCVM@fda.hhs.gov.
Wishing you and your pet(s) the best,
Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
TruthaboutPetFood.com
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Dr. Oscar Chavez, Veterinarian
May 28, 2019 at 3:08 pm
Susan,
Yes there is great variability in nutrient supplementation among pet foods, thank you for always pointing that out! Here’s a tip that could help:
At least part of the problem may be (ironically and inadvertently) driven by consumers looking for All Life Stage food. This is why I always recommend feeding food intended for the appropriate life stage: adult maintenance, or puppy/kitten on the label, and avoiding All Life Stage food for feeding adult pets. Per AAFCO, for a pet food to be considered All Life Stage, it must be formulated to meet the most stringent life stage, which will always be growth/reproduction. Therefore, food labeled All Life Stage is essentially puppy/kitten food. If you have an adult, there will always be excesses in the food that your pet doesn’t need.
A differentiator to help some of this already exists: pet parents should look for adult maintenance and/or growth on the label and for pet companies that make distinct formulations. Unfortunately many smaller companies simply make one formulation and label it for all stages, this has become quite popular.
At the end of the day, the foods you summarize here are just improperly formulated. The AAFCO requirement for Calcium for kittens is only 1.0 gram per 1000 kcals, so even an All Life Stage food should be within 120 to 150% of that, in the range of 1.2 to 1.5 grams per 1000 kcals. These maximums you list here are 3 times that! There’s no doubt these are just not properly formulated. However, if pet parents avoid All Life Stage food, they could mitigate this effect in some case.
Raw Feeder
May 30, 2019 at 8:37 am
I hate to say it doc, but I doubt you can avoid excessive levels. Here’s why: who sets the levels for vitamins and minerals? (AAFCO of course). How do they arrive at these standards? Mixed bag at best (through all the various reading I’ve done). Case and point, cats were going blind, some were dying do to taurine deficiency in cat food back in the late seventies/ early eighties. Yet, cat owners were being told their cat food met the rigorous AAFCO standards back then. Wasn’t the commercial food back then supposed to be balanced and nutritious? Weren’t there studies saying everything was fine. It wasn’t though, was it? Here we are almost 40 years later, and we are seeing pentobarbital, high doses of vitamin D, high carbohydrates in the food. Spray on some synthetic vitamins and minerals and we call it complete and nutritious. Only problem is dogs and cats are getting sicker earlier and earlier in life. Tell me doc, how many obese, diabetic dogs and cats do you see? How many with rotten teeth at an early age? All I know is my dogs are much better off with me feeding them raw food instead of high carb, processed kibble. In the end, I am responsible for their health. AAFCO, the FDA, and the AVMA can give me all the warnings they want about feeding a raw and unbalanced diet, but all I see is animals dying from commercial pet food that in my opinion is ultimately poisoned (pentobarbital, aflatoxins/mycotoxins, antibiotics, and lethal high doses of synthetic vitamins) and has had numerous recalls for the items I have just listed. If veterinarians were smart they would start recommending natural prepared foods (yes, they are out there). I am not talking about the ones found in local pet stores either. It means vets doing their research as well.
~Pet Owner~
May 28, 2019 at 9:03 pm
The irony is, pet owners are so “frightened” from NOT using a “complete & balanced” PF but they could actually be doing more harm. My estimate would be to widely rotate (more trusted) brands because they all couldn’t be making the very same mistake / mis-proportion (per ingredient). Also add real whole food (human edible) ground beef, sweet potato, brown rice, and other foods your dog can tolerate. But quit kibble, it’s cheaper and probably even more susceptible to mis-proportioning.
Reader
May 28, 2019 at 9:09 pm
It’s one thing to include a way for us to take action. But I think something is seriously wrong when I (as both a consumer and a pet owner) is being made responsible to FIX a fraudulent situation. Clearly the words “COMPLETE & BALANCED” is a guarantee made on a pet food LABEL. And from what I understand, companies can’t lie on the package itself. They can on their website, and they can mislead through “splitting ingredients” and all of that. But if my dog is getting excessive calcium (for example) then my dog is being INTENTIONALLY harmed! Especially growing puppies.
How can that NOT deserve formal legal action to rectify!
Susan Thixton
May 29, 2019 at 9:35 am
I agree with you. The legal challenge (my guess) would be is that law has not established any maximum levels for these nutrients – only minimum levels are established. Thus legally a pet food with a 2000% increase in iron (as example) is not in violation of any rule or law. To me, ‘Complete and Balanced’ should mean something. Again opinion – as things are now, in many cases it doesn’t mean much at all. There is no “balance”.
~Food For Thought~
May 30, 2019 at 2:48 pm
Hate to say it – but sometimes there’s a bit of disrespect and condescending tone about some comments. “If veterinarians were smart they would start recommending natural prepared foods (yes, they are out there). I am not talking about the ones found in local pet stores either. local pet stores. It means vets doing their research as well.” Any idea who Dr. Oscar Chavez is? Check out the resources below.
Also combined in the comment are separate issues that distort the main topic at hand, about there being “no established regulatory maximum level of nutrients IS a risk.” To which Dr. Chavez points out that the risk can be mitigated by choosing the appropriately identified “life stage” PF formula. The other issues including safely calculated Vit. & Min. dosage is relative (2) The bio-availability of ingredients is a factor (3) And toxic ingredients like pentobarbital negate the value of ANY formula or meal. So why would that be a part of this discussion?
Dr. Chavez is a wonderful, personable, caring Vet who is a champion of healthy food, and a nutritional consultant to “Just Food For Dogs” which is now available in key PF Supply Stores (like Pet Food Express). JFFD is a product that helped pioneer an alternative canine feeding format. Dr. Chavez is objective, scientifically based, rational and a very articulate communicator! Also a champion of PF advocacy work.
I feed all kinds of formats (excluding kibble) and the bag of raw beef I pulled out of the freezer says “Complete & Balanced” but not for which life stage. Should I feed it to an immature large pup, my pregnant bitch or my senior? Doesn’t warn me not to! Also am not sure how this raw food is supplying enough energy requirements without carbs.Hmmm. My dog has a very high metabolism, very busy all the time. So I know that I need to rotate his diet, including whole foods like ground sirloin, Sojo’s pre-mix, sweet potato or brown rice. Plus I rotate in a limited ingredient protein PF with a full formulation of Vits. & Mins. for dogs.
When these (all or nothing) “Raw Food” enthusiasts get going, make it sound like all that’s necessary is a bunch of raw meat into a bowl, and be done. But we’re not feeding Lions at the Zoo (or wolves) and even then animals which are under the provision of human care, are provided nutritional supplements. Animals in the wild eat a broad diet constantly. Yet these commercial raw food products vary a great deal including: the ingredients, how they’re processed, and what assurances are guaranteed about the quality of sourcing. Oh, it’s on the website, ya’ sure. My motto to everyone is, you’d better hedge your bets, constantly.
The point is, the more complex the diet (for the sake of long term truly complete & balanced feeding) then effort is required for research, understanding labels & packaging information, knowing how it’s produced, sourced, and the manufacturer’s reputation (meaning the degree of truthfulness). Also note that the same companies making inferior traditional PF, have expanded their SKUs to include “raw and freeze dried” products because of the evolving market place.
Resources:
https://petfood.aafco.org/Labeling-Labeling-Requirements
AAFCO’s explanation on Nutritional Adequacy. This is a statement that indicates the food is complete and balanced for a particular life stage, such as growth, reproduction, adult maintenance or a combination of these, or intended for intermittent or supplemental feeding only. Products conspicuously identified on the principal display panel as a snack, treat, or supplement are exempt.
From: AAFCO METHODS FOR SUBSTANTIATING NUTRITIONAL ADEQUACY OF DOG AND CAT FOODS
https://www.aafco.org/Portals/0/SiteContent/Regulatory/Committees/Pet-Food/Reports/Pet_Food_Report_2013_Midyear-Proposed_Revisions_to_AAFCO_Nutrient_Profiles.pdf
The specific example for iron can be generalized to most essential minerals, and demonstrates the impossibility that any list of concentrations can invariably ensure that all nutrient requirements are fulfilled in all diet formulas without additional considerations. As stated for the previous editions of the AAFCO Dog and Cat Food Nutrient Profiles, formulating a product according to the Profiles is only one part of a nutritionally sound, scientific development that must consider all other aspects of the product. The fact that a dog or cat food is formulated to meet a specific AAFCO Profile should not deter or discourage the manufacturer from conducting appropriate feeding trials to further confirm and ensure the diet is nutritionally adequate for its intended use.
Minimum and some maximum nutrient concentrations were established in the Profiles for two categories; growth and reproduction (gestation/lactation), and adult maintenance. Maximum nutrient concentrations were established for nutrients where the potential for overuse or toxicity is of concern and likely to occur if attention is not paid to the concentrations of those nutrients. The absence of a maximum concentration should not be interpreted to mean that nutrients without a specific maximum contentare safe at any concentration. Rather, it reflects the lack of information in dogs and cats on toxic concentrations of that nutrient. Establishing a maximum concentration implies safety below that concentration for long term consumption and to set a maximum arbitrarily might prove worse than no maximum at all.
Just Food For Dogs – https://www.justfoodfordogs.com/
Conny White
June 3, 2019 at 8:25 am
I have an academic doctorate degree and get confused. Old vets have told me to rotate foods, so I feed a mixture which is the only thing that has probably helped to avoid this DCM issue thus far. I used dehydrated THK and canned with minimal kibble. I also add in real cooked meat. And, I have a Great Dane on a home cooked BalanceIT meal this past year due to Chronic Pancreatitis. Just switched to ProPlan Savor Beef for our kibble mix-in since the smaller Canadian company we were using in the past had trouble sourcing consistent ingredients and the dogs were having digestive issues when we got a bag of kibble that was different. I have the utmost respect for our vets and the mess they are in with dog food. The ingredient lists, vitamins/minerals and analysis is all misleading so, we cannot blame the vets when the information they are taught or provided on the bags is completely false. I am a healthcare provider and unless $$$/profit is involved the research just won’t be done in our country.
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