There are ingredients used in pet food that don’t necessarily require a legal definition. ‘Apple’ as example. Apple is a common food, a familiar food that doesn’t require a legal definition. The Association of American Feed Control Officials (AAFCO) have released their list of approved common foods, ingredients that can be used in pet food/animal feed without a legal definition.
Pet owners can Click Here to download the AAFCO Common Food Index.
But as with anything in pet food, it is not as simple as they make you believe.
The legal definition of a Common Food‘ is:
Common foods are defined as: “Food items commercially available and suitable for use in animal food but are not defined by AAFCO, including but not limited to certain whole seeds, vegetables, or fruits. Common food for animals may include common human foods that are known to be safe for the intended use in animal food. Manufacturers are responsible for determining whether a common food is safe and has utility for its intended use prior to commercial distribution as animal food.”
The AAFCO “Common Food Index Policy Guidelines” states:
“These common foods must align with the feed term Common Foods in the Feed Terms and Definitions within Chapter 6 of the AAFCO Official Publication. The CFI is not a substitute for the AAFCO process for new feed ingredient definitions; Chapter 6 of the Official Publication, alone, contains the officially recognized feed ingredient definitions.”
So in just these two quotes – we have AAFCO referencing these ingredients as “food“, “animal food” and “feed“. So what are they – feed or food?
The answer: they can be either quality (without disclosure to the consumer).
The key for pet owners to understand ingredient quality of common foods is six little words included in AAFCO’s Common Food definition…
“suitable for use in animal food”
Suitable for use in animal food means any quality of ingredient is allowed. Below is a screen shot image of an AAFCO meeting minutes from 2016 when the definition of feed grade and suitable for use in animal food was approved.
Please notice that the legal definition of Feed Grade states that ingredients conform to federal law (food) unless they are allowed not to (feed).
Also please notice that the legal definition of Human Grade has no similar wording, ingredients are required to be human edible and ONLY human edible.
Thus, AAFCO’s new Common Food Index allows manufacturers to list a common food on the label – such as “Apple” – without disclosing to consumers if the ingredient is a food or an inferior quality feed (such as an apple like you buy at the grocery or rotting apples rejected for use as human food).
AAFCO claims their new Common Food Index is “providing transparency“, but does it? Is is transparency when consumers/pet owners are not informed on a pet food label if the ingredient is food or feed? Is it transparency when all ingredients are labeled the same (‘apple’) when they are allowed to be dramatically different in quality?
Thankfully, we have federal law on our side. Federal law requires transparency with common food names, not allowing two different classifications of a common food to use the same name (law quoted below in our message to AAFCO).
AAFCO is asking for input on their Common Food Index. Below is what we provided to AAFCO:
Title 21, Chapter 1, Subchapter E, Part 502.5 General Principles (a) states: “The common or usual name of a food, which may be a coined term, shall accurately identify or describe, in as simple and direct terms as possible, the basic nature of the food or its characterizing properties or ingredients. The name shall be uniform among all identical or similar products and may not be confusingly similar to the name of any other food that is not reasonably encompassed within the same name. Each class or subclass of food shall be given its own common or usual name that states, in clear terms, what it is in a way that distinguishes it from different foods.”
AAFCO’s legal definition of common food states “Food items commercially available and suitable for use in animal food…” Because animal food/animal feed is provided with the ability to utilize ingredients classified as ‘suitable for use in animal food’ – AAFCO allows a subclass of food. Federal law requires each class or subclass to be given its own common or usual name to distinguish it from different foods.
We ask AAFCO to include within the Common Food Index the suitable for use in animal food subclass. Such as ‘apple’ – which would be the true common name of food grade/edible and ‘feed grade apple’ – which would be the subclass.
Without this disclosure on pet food labels, pet food consumers are being misled into believing that apples are apples – when in pet food/feed all apples (and all other ingredients suitable for use in animal food) are not required to be the same as the foods we are familiar with.
Will AAFCO abide by federal law or will they ignore it? Time will tell.
Pet owners are encouraged to send AAFCO their comments. Please send your comment by June 2, 2023 (and please be respectful). You can submit your message Here.
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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