AAFCO Asks for Public Comments on Label Regulations

For the past eight years, AAFCO has been developing some pet food label updates. The most significant change will be a Nutrition Facts box (similar to that on human food labels) that will be required on pet food labels.

Surprisingly, AAFCO has asked for comments on the proposed regulations. AAFCO typically does not ask for comments on pending regulations, so we don’t know why (or what’s behind) in this circumstance they did.

AAFCO sent out an email on September 30, 2022. The first paragraph of the email stated:

“The Association of American Feed Control Officials (AAFCO) is committed to supporting consumers’ requests for consistency and transparency for pet food product labels. Over the past eight years, AAFCO’s Pet Food Committee has conducted consumer focus groups, surveyed state feed programs, and collaborated with industry partners as part of the Pet Food Label Modernization (PFLM) project. As a result, the Committee is making substantial updates to how nutrition fact boxes, ingredients, safe handling and nutritional adequacy verbiage is presented on pet food and specialty pet food packaging.”

Their email also stated:

“We are requesting that our industry partners review the attached draft Model Pet Food Regulations and provide any comments in writing to PFC@aafco.org by October 31, 2022.”

AAFCO asked for “industry partners” to review the draft Model Pet Food Regulations and provide comment. There was no mention of consumer comment, there was no mention of ‘consumer partners’.

Unfortunately, this is the attitude we have to deal with. Regulatory authorities – the state and federal feed officials of AAFCO – don’t consider us (consumers) as ‘partners’. They only consider industry as partners (which is an additional problem – how can you regulate your partner?).

Regardless to the fact that AAFCO did not ask for consumer comment, pet owners can read the draft Model Pet Food Regulations and should they choose to, send a comment to the Pet Food Committee at PFC@aafco.org by October 31, 2022.

With regards to the Nutrition Facts box – regulation PF5 (beginning on page 5), below is an image of an earlier version to give you an example of what it will look like (this is not the required information, only a visual example to help you understand the regulation).

Another issue in the draft regulations that we feel is not properly explained are found in section PF12 Handling and Storage Instructions, page 18. AAFCO draft regulations state “If any graphics are used to support handling and storage instructions, the following graphics (and only the following graphics) may be included“.

While some of these graphics are easily understood when and why they would be used, others are not. Such as the first graphic “Separate from human food“. We do not know what AAFCO’s intentions are with this particular graphic.

Again, even though AAFCO did not ask for consumer comment – please don’t hesitate to read through the draft regulations and send them your sentiments.

We sent AAFCO the following comment on 10/3/22:

I received your September 30, 2022 email request for comment regarding draft Model Pet Food Regulations. It was very disheartening to read the email requesting only “industry partners” to review the regulations and submit comments. Your email evidences AAFCO’s continued attitude neglecting to include consumers. As a consumer representative that has attended more than 10 years of meetings, I find this attitude very concerning. Pet food consumers should be included as an equal stakeholder to industry.

Regardless of the fact consumer input was not requested, we provide the following comment.

We were confused with the information in PF12 (b) Handling and Storage Instructions, page 18. No explanation was provided as to when the graphics would be used on a label. While some are easily understood, some are not. Such as the first graphic “Separate from human food”. In what circumstances would this graphic be used on a pet food label? Are there additional regulations not included in this draft that would require this graphic to be used on a label? Are there additional regulations not included in this draft that require any of the graphics to be used on labels?

Are there guidance documents that will further explain the draft regulations? If so, will those guidance documents be released for consumer review?

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Will AAFCO ever listen to us? Time will tell.

Wishing you and your pet the best –

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

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