Up until October 1, 2024 the FDA worked with AAFCO to provide scientific review of new proposed pet food/animal feed ingredients. Now, both plan on approving new ingredients separately – each with their own separate system. Giving the appearance these two organizations are working against each other/competing with each other.
FDA’s system is termed the Animal Food Ingredient Consultation (AFIC) process. FDA’s process will be similar to the previous AAFCO ingredient approval process, excluding any involvement with AAFCO. Ingredient manufacturers will submit a proposed ingredient name, definition, and submit scientific evidence the ingredient is safe. With livestock feed ingredients, the manufacturer will also be required to submit evidence the ingredient would be safe for human food consumption. Based on FDA’s review, the ingredient will be approved or rejected. Pending and approved ingredients will be published on the FDA website, and will be open for public review and comment.
AAFCO’s proposed system for pet food/animal feed ingredient approval will be similar to their previous process, excluding any involvement with FDA. Scientific review of ingredients will be performed by Kansas State University, specifically KSU will manage the scientific review process soliciting various experts (at their discretion) to perform the proposed ingredient review. Kansas State “will manage the process of soliciting subject matter experts”. The same paperwork is required of the ingredient manufacturer that FDA requires; ingredient name, proposed definition, and scientific evidence to safety. BUT…AAFCO will charge a $50,000.00 fee for ingredient approvals (whether they are approved or rejected).
So many concerns without answers.
Neither FDA or AAFCO is explaining if these two separate ingredient approval processes will work together. Will the States accept FDA’s ingredients into state law or will some states reject FDA’s ingredients and only allow AAFCO ingredients (a show of allegiance to their AAFCO friends)? Will FDA accept AAFCO’s approved ingredients? If FDA does not accept AAFCO approved ingredients, the agency is appearing to say they will take enforcement action against pet foods/animal feeds using the AAFCO ingredients (non-FDA approved ingredients). “If FDA identifies a concern with respect to an unapproved animal food additive, we intend to take appropriate action to ensure the safety of the animal food supply, including notifying the public or pursuing enforcement action as warranted.”
Will the ingredient approval process supervised by Kansas State be subject to a concerning industry influence? Kansas State University has a long history of working with the pet food industry. In 2018 the Kansas State Veterinary School accepted “the largest corporate gift in the college’s history” from Hill’s Pet Food. Would donations to the University influence an ingredient approval?
Could an ingredient manufacturer be rejected through the FDA process, then turn around and submit the same ingredient through the AAFCO process and gain approval?
And then there is the issue of financial interest by those that will be approving ingredients (through AAFCO). The AAFCO proposal states they will approve approximately 15 ingredients a year, which results in $750,000.00 in revenue. AAFCO does not explain how those funds will be disbursed; how much of the money goes to Kansas State, how much money is paid to each of the scientific review personnel, and how much money is paid to AAFCO. Financial incentives certainly cause concern that ingredients will be approved without proper due diligence.
It is hard to imagine that pet food/animal feed regulations could get worse – but until both parties (FDA and AAFCO) start giving us more information, we are left to believe that things could get worse. The regulatory authorities involved with AAFCO and the regulatory authorities of FDA working against each other will do nothing but cause future conflicts that us and our pets could pay the price for.
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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