When Does The Name Cross the Health Claim Line?

Per the FDA, when a pet food makes a health claim, it crosses into a drug category (no longer a food). Specific to pet food health claims, the FDA states:

“For more than fifty years, dog and cat food manufacturers have marketed diets identified on their labels or in labeling or other communications disseminated by or on behalf of the manufacturers (‘manufacturer communications’) as being intended to diagnose, cure, mitigate, treat, or prevent diseases (‘treat or prevent disease‘). By virtue of their intended use to treat or prevent disease, such products meet the statutory definition of a drug in section 201(g)(1)(B) of the Federal Food, Drug, and Cosmetic Act (the FD&C Act).”

FDA allows these types of health claims (treat or prevent disease claims) on veterinary diet pet foods. The agency requires these types of pet foods to only be sold through veterinarians. Such as:

The name of this pet food is: Hill’s Prescription Diet i/d Chicken Flavor Dog Food. The Hill’s website states: “Therapeutic adult dog food to help manage digestive upsets.”

With veterinary diets that FDA allows to make health claims, the manufacturer is required to provide science to substantiate the claim. FDA states:

“FDA will consider whether the product is responsibly marketed in other respects as well. For example, a therapeutic claim that is not scientifically substantiated would be considered false or misleading, thus making the product misbranded.”

But…some pet foods are taking the treat or prevent disease health claims in a different direction, without meeting the requirements of sold only by a veterinarian. Some pet foods are utilizing the name of their products to suggest a health claim.

Hill’s Pet Food manufactures a pet food named “Adult Perfect Digestion Chicken & Barley Recipe Dog Food“.

To be clear, the name of this dog food is “Perfect Digestion“. The predominately displayed words on the label – Perfect Digestion – is the name of the dog food, allowed to be boldly printed on the label because it is the name of the product. In this instance, Hill’s is not making a label claim of “perfect digestion”, Hill’s named the product “Perfect Digestion”.

When you look at the veterinary diet and the ‘over the counter’ diet side by side…

…”Digestive Care” on the veterinary diet (left side) is a health claim, allowed because the product is sold exclusively through veterinarians. But “Perfect Digestion” (right side) is the actual name of the dog food, not considered a health claim by FDA, not required to be sold through a veterinarian.

Hill’s is not the only manufacturer being creative with the name of their products. Purina Pet Food manufactures multiple products that include a health-type claim in the name…

The name of this cat food is “AdvantEDGE Adult Digestive Support+ Salmon & Rice Formula Dry Cat Food“. The predominantly displayed words Digestive Support on the label is not a health claim, it is the actual name of the cat food.

And this pet food – “Vibrant Maturity Adult 7+ Formula” – Vibrant Maturity is not a label claim, it is the actual name of the dog food.

Blue Buffalo makes a line of cat and dog foods named “Life Protection“.

FreshPet manufactures a dog food named “Digestive Health“.

Again, all of these pet foods named their products Digestive Health, Life Protection, Digestive Support, and Perfect Digestion. The bold display of the name on each label is allowed because it is the product name.

Are the names of these pet foods misleading consumers?

Is the FDA allowing these pet foods to cross the health claim line with product names?

Susan Thixton
Pet Food Consumer Advocate
TruthaboutPetFood.com
Association for Truth in Pet Food

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