Economically Motivated Adulteration; an FDA Approved Pet Food Business Practice

Recently, the FDA added “economically motivated adulteration” of foods to import alerts, a move to notify officials to be on the lookout for products that might not be as they appear. The agency has multiple pages on their website about this type of adulteration, not only for imported foods but for products manufactured in the US.

The FDA defines it as: “Economically motivated adulteration (EMA) includes the substitution, addition, or omission of a substance in a product for the purpose of increasing the apparent value of the product or reducing the cost of its production for economic gain.”

The FDA provides multiple examples of economically motivated adulteration such as: “Olive Oil: Similar to honey and maple syrup, some companies have previously diluted more expensive extra-virgin olive oil with less expensive vegetable oil but sold the mix as pure olive oil at a higher price.”

And the agency provides examples of enforcement action taken against companies that have sold economically motivated adulterated foods, as well as the legal consequences suffered by the companies: “a father and son who ran Casey’s Seafood were sentenced to prison for repackaging foreign crab meat as blue crab caught in the U.S.”

But…

There is another example of economically motivated adulteration that is 100% FDA’s fault, with no legal consequences experienced by any company profiting from the fraud. Many feed grade pet foods.

The FDA Center for Veterinary Medicine states: “we do not believe that the use of diseased animals or animals that died otherwise than by slaughter to make animal food poses a safety concern and we intend to continue to exercise enforcement discretion.”

The FDA Center for Veterinary Medicine is the sole decision maker that allows reduced cost substituted (and illegal) ingredients in pet foods that appears to be of greater value on pet food labels providing significant economic gain of pet food manufacturers.

Which results in ingredients sourced from this:

or this:

or this:

To be sold to consumers packaged like this:

and like this:

Evidence of economic motivation:

How much would a consumer pay for a pet food labeled truthfully like this (or would they even purchase it)?

Opinion: No pet food consumer would buy it, which is why it is hidden from consumers.

There is no doubt. Because the FDA Center for Veterinary Medicine allows pet food manufacturers to source inexpensive (and illegal) substitute ingredients while marketing their foods with no disclosure to the truthful quality of ingredients – they are allowing these manufacturers to profit from selling adulterated pet foods. It is plain and simple FDA enabled economically motivated adulteration.

It is a federal crime recognized in all foods…except pet food.

Feed free to express your opinion about non-disclosed illegal ingredients resulting in economic gain of pet food manufacturers to 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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