Ingredients are required to be listed on a pet food label according to weight, heaviest to lightest. But…regulatory loopholes allow manufacturers the opportunity to deceive pet owners.
Almost every pet owner notices claims of ‘Chicken or Beef is the First Ingredient’ in pet food marketing. As well, most pet owners flip the bag or can over and look at the ingredient list to read where meat ingredients fall in the list – checking to be sure that chicken or beef is high on the ingredient list. Because most pet owners know ingredients are listed heaviest to lightest, they are given a confidence that chicken or beef listed high in the ingredient list means the pet food contains high amounts of chicken or beef.
But…
Many ingredients used in pet foods are dry ingredients – even chicken and beef. Manufacturers are allowed by regulations (and lack of regulations) to calculate the percentage of the dried ingredient by adding moisture back in. In a PetFoodIndustry.com article regarding the reconstitution of dried pet food ingredients, it explains…
“The mathematical ‘reconstitution’ of dry ingredients with added water to affect the orders of predominance and ingredient percentage claims on pet food labels is a long-practiced, yet often incorrectly implemented, concept.”
When manufacturers use dried, powdered ingredients, regulations allow manufacturers the ability to calculate percentages of ingredients used in the pet food by including the moisture added to reconstitute a dried ingredient. Such as 1 pound of dried chicken + 3 pounds of moisture to reconstitute = 4 pounds of chicken.
But, the industry admits there are problems with the calculations because the dried chicken is not reconstituted individually prior to manufacturing. Instead, ingredients are reconstituted during manufacturing. Because ingredients are NOT re-hydrated individually and weighed, manufacturers are allowed to guesstimate how much the re-hydrated ingredient weighs, which in turn can alter the amount of chicken (or other dried ingredients) is actually in the pet food (and can alter the ingredient list – putting meat ingredients higher on the list). Manufacturers can decide – with no regulatory oversight – that dried chicken will weight 3 times or 4 times or more when it is re-hydrated during manufacturing. It’s all left to the manufacturer’s discretion.
And because a dried ingredient such as chicken is re-hydrated during the manufacturing process and provided with a pick-your-own estimate of how much the re-hydrated chicken weighs – the system doesn’t take into account other ingredients that are also re-hydrated during the manufacturing process altering their end weight as well.
Such as…if a pet food contained 1 pound of dried chicken and 3 pounds of dried corn, during manufacturing both ingredients would re-hydrate with the moisture added. Manufacturers are allowed to assign a moisture weight increase to the chicken, BUT are not required to assign the same moisture weight increase to the corn. This can result in a pet food unfairly claiming to have more chicken than corn in the final product when the opposite is true.
The industry fairly explains that moisture added during manufacturing should not be used to re-hydrate just one ingredient which increases the stated percentage of that ingredient:
“…one cannot legitimately reconstitute dry ingredients in a preferential manner. If the water added to a mixture purportedly reconstituted the dried chicken ingredient, for example, it would also hypothetically reconstitute all the other dried ingredients, such as the grains. The net effect should be no material shift in those ingredients’ order of predominance.”
“As contemplated under the AAFCO regulation, a fruit (whether dried or not) can be added at 3% of the dry food formulation to substantiate a “with fruit” claim on the label. Even if after removal of the moisture (both that added and inherent in the ingredients) the actual percentage contribution of fruit is less than 3%, that still conforms to the rules, because percentages are based on amounts as they go into the formulation, not out. The same premise allows a manufacturer to add a high-moisture ingredient, such as fresh lamb, to a dry food mixture and still declare it as if its inherent moisture was still present; i.e., above the grains and other ingredients that are already low moisture prior to processing.”
Unfortunately for pet owners, there is no authority that validates the actual percentage of an ingredient used in a pet food. There is no authority that validates ‘Chicken is the First Ingredient’ claim. The industry does warn manufacturers “discrepancies in orders of predominance and percentage claims could potentially arise if the product was subject to more rigorous regulatory review.”
We (pet owners) definitely need ‘more rigorous regulatory review’. Without proper regulatory review – pet owners can be deceived and our pets suffer.
Ask your manufacturer if any dried/powdered ingredients are used in your pet food. If so, ask for the percentage of dry (un-hydrated) ingredient used in the formula and also ask for the percentage of hydrated ingredient. Ask the manufacturer if the calculations of re-hydration also are applied to all other dried ingredients (such as grains).
And please tell regulatory authorities to validate the percentages of ingredients in pet foods. Email the FDA at: AskCVM@fda.hhs.gov and find your State’s regulatory officials here: https://www.aafco.org/Regulatory.
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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Concerned
June 2, 2021 at 4:16 pm
so the AAFCO Label is just all BS. So the manufacturer can then add the moisture back in to hydrate meat protein but not for legume/bean plant protein….so the plant protein % in the product could way above the meat protein based on Susan’s corn scenario in the article.
T Allen
June 2, 2021 at 4:21 pm
For the last 30years I have always assumed meat or poultry listed by name at the beginning of the ingredient list was calculated fresh weight and automatically dropped it 3-4 places down the list. That was common knowledge long ago and we spread the word far and wide. Usually #2 or #3 was “meal” of some kind after the manufacturers caught on we weren’t accepting corn or rice as # 2. The deception in the industry has destroyed all trust for knowledgeable people so this is not a surprise but we do need stronger laws to stop the deceit.
A Lover of Fur Children
June 2, 2021 at 8:51 pm
Yeah, this is why if you buy dog food meat, fish, or eggs should be the first 5 ingredients. Actual meat, not byproducts or meat and bone meal or beef and bone meal, actual meat.
Concerned
June 4, 2021 at 11:46 am
And you can not even go by the first 5 ingredients.
This study also DNA tested pet foods “to test whether actual ingredients matched package labels.” Their findings: “Every sample we looked at had some inaccuracy, based on our results, some more egregious than others. As for the DNA results, generically speaking, we found that many of the pet food products were comprised of low-value ingredients, such as chicken, and that products claiming to be made from high-value ingredients, such as fish and novelty proteins, typically contained more low-value ingredients than high-value ingredients.”
https://truthaboutpetfood.com/two-new-studies-emphasize-pet-food-regulation-failures/
A Lover of Fur Children
October 13, 2021 at 7:24 pm
So nothing is safe anymore? We’d try making our dog his own food but I think not getting all your basic nutrition requirements is slightly worse than a terrible quality dog “food”. We feed him half Northwest Naturals frozen raw and the other half is a high quality kibble. Fingers crossed the industry gets better.
Concerned
July 2, 2021 at 1:35 pm
Please remember that fresh meat will be 70-80% moisture. So that fresh meat protein that is listed first could be way down that ingredient panel list if everything was converted to the same measuring method.
A Lover Of Fur Children
January 2, 2022 at 9:37 am
Yeah, I’m trying to convince my family to let me feed him half homemade BARF raw for moisture and the nutrients he’s not getting in kibble. It’ll still be half kibble because even though I’m 95% sure the recipe I made has all the required nutrients in commercial food, I still don’t want to risk nutritional imbalances.