What has to be, where it has to be, what it has to say, what it can’t say…and more about dog food and cat food labels. Lessons shared from the AAFCO Pet Food Labeling Workshop.
It’s a bit exhaustive…all the things that are of significance on a dog food or a cat food label. Things that the typical pet food purchaser doesn’t think about but things that a state feed inspector and a pet food manufacturer has to focus on and know like the back of their hand. The following is TruthaboutPetFood.com’s abbreviated Pet Food Labeling 101. Your opportunity for a brief walk in the shoes of pet food manufacturing and pet food regulation enforcement. Pay attention, there’s a test at the end to see what you’ve learned.
Note: Personally I think many of these regulations are misleading consumers and protecting the interests of big business, but that is not the point of this article. The following is only an abbreviated explanation of existing AAFCO labeling regulations; not a statement of support of these regulations.
Ok…so how much do you know about pet food labels? Let’s begin with proper terminology; pet food labeling terms you should be familiar with. When you walk into a pet store and start your walk down the dog food or cat food aisle, the area of the pet food bag or can that you notice first…that is displayed for you to see first, is called the “principal display panel”. The “ingredient statement” is the section on the pet food label that provides a list of this food or treat’s list of ingredients.
Besides the ingredient statement, each pet food label must include
1. The product name and brand name.
2. The species name (dog, cat) this food is designed for.
3. Quantity statement; how much pet food is in this bag/can. Must be placed on the lower third of the principal display panel.
4. Guaranteed analysis of this pet food stated as Crude Protein (minimum), Crude Fat (minimum), Crude Fiber (maximum), and Moisture (maximum).
Plus, a pet food label must include a nutritional adequacy statement, feeding directions, and name and address of manufacturer or distributor.
Sounds simple enough doesn’t it. Well…
Pet food A is named Fluffy Brand Adult Cat Food
Pet food B is named Fluffy Brand Cat and Kitten Food
Pet Food A is name correctly if it meets AAFCO requirements for adult cats; pet food B is named correctly if it meets AAFCO requirements for adult cats and kittens. But..it just happens that both of these cat foods list 26% crude protein in the Guaranteed Analysis. Because AAFCO nutrient profiles say that a kitten food must be a minimum of 30% crude protein, Fluffy Brand Cat and Kitten Food would be labeled incorrectly. The manufacturer would need to remove the ‘Kitten’ from the pet food name or increase the crude protein percentage of the food to be called a kitten food.
Here’s another pet food…
Fluffy Brand Chicken Adult Cat Food
And the ingredients statement lists the following: Chicken Meal, Chicken Liver, Rice, Chicken Fat, …
This pet food would be mis-labeled because the name states ‘Chicken‘ yet the ingredients state ‘Chicken Meal‘. Chicken Meal is not the same as Chicken. The correct pet food name should be changed to ‘Fluffy Brand Chicken Meal Cat Food’.
Another factor in the pet food labeling process is the Guaranteed Analysis. See if you can tell which one of these pretend Guaranteed Analysis statements follow AAFCO guidelines…
1. Protein 26%
Fat 18%
Fiber 5%
Moisture 10%
2. Crude Protein 26%
Crude Fat 18%
Crude Fiber 5%
Moisture 10%
or,
3. Crude Protein, min 26%
Crude Fat, min 18%
Crude Fiber, max 5%
Moisture 10%
The correct Guaranteed Analysis is number three.
Crude Protein, min 26%
Crude Fat, min 18%
Crude Fiber, max 5%
Moisture 10%
Protein, fat, and fiber listed in the Guaranteed Analysis of a pet food label must be listed as ‘crude’. And protein and fat must be listed on a label as the minimum – fiber must be listed as the maximum included in the pet food.
Pet foods must also include a “nutritional adequacy statement”, which is similar to a purpose of the pet food statement. The required nutritional adequacy statement of Pet food A says ‘Fluffy Brand Adult Cat Food is formulated to meet the nutritional levels established by the AAFCO Cat Food Nutrient Profiles for maintenance of the adult cat.’ This is a correct nutritional adequacy statement.
But what would happen if Fluffy Brand Adult Cat Food label would make the nutritional adequacy statement “Fluffy Brand Cat and Kitten Food meets the nutritional requirements of cats and kittens.” Would that nutritional adequacy statement be correct? No, it wouldn’t. AAFCO regulations require exact wording for nutritional adequacy statements. The exact wording must be ‘(Pet Food Name) is formulated to meet the nutritional levels established by the AAFCO Cat Food Nutrient Profiles for maintenance of the adult cat.” Exactly; word for word.
Feeding directions need to be just so as well. Feeding directions should provide weight of animal classifications as well as frequency of feeding. As example, “Feed 1/2 cup for each ten pounds” is not correct; “Feed 1/2 cup for each ten pounds daily” is correct.
And lastly the ingredient statement should look like this…
Chicken, Chicken Meal, Chicken Liver, Chicken Fat, Pumpkin,…
and not this…
Real chicken breast meat, chicken meal from muscle meat only – no bone or internal organs, USDA Grade A chicken liver, chicken fat, pumpkin…
No grade or classification of ingredient is allowed. Pet Food manufacturers can only use AAFCO defined pet food ingredients or ingredients that would be considered GRAS (Generally Recognized as Safe). ‘Real chicken breast meat’ could only be stated as ‘chicken’. USDA Grade A would be considered a ‘grade of ingredient’ and is not allowed on pet food labels.
Do you think you understand what it takes to label a pet food? Ok…here’s a test.
Part 1
Put yourself in the shoes of a AAFCO pet food inspector, examine the following pet food labels (for this purpose we are only looking at pet food name, Guaranteed Analysis, ingredient list, and feeding directions). Which label(s) will pass inspection?
Which label(s) won’t pass inspection and why?
Pet Food Label A
Fido’s Brand
Beef Dog Food
Ingredients: Beef, beef liver, organic choice sweet potatoes, chicken fat….
Guaranteed Analysis
Crude Protein max 26%
Crude Fiber max 5%
Crude Fat min 8%
Moisture min 10%
Feeding Directions
Adult Dog to 15 pounds feed 1/2 cup daily
Adult Dog 15 to 30 pounds feed 3/4 to 1 cup daily
Pet Food Label B
Fido’s Brand
Beef Adult Dog Food
Ingredients: Beef, beef liver, organic sweet potatoes, chicken fat….
Guaranteed Analysis
Crude Protein max 26%
Crude Fat max 8%
Crude Fiber max 5%
Moisture min 10%
Feeding Directions
Adult Dog to 15 pounds feed 1/2 cup daily
Adult Dog 15 to 30 pounds feed 3/4 to 1 cup daily
Pet Food Label C
Fido’s Brand
Beef Adult Dog Food
Ingredients: Beef, beef liver, organic sweet potatoes, chicken fat….
Guaranteed Analysis
Crude Protein min 26%
Crude Fat min 8%
Crude Fiber max 5%
Moisture max 10%
Feeding Directions
Adult Dog to 15 pounds feed 1/2 cup daily
Adult Dog 15 to 30 pounds feed 3/4 to 1 cup daily
Pet Food Label Test Part 2
Now put yourself in the shoes of a pet food manufacturer. Your company has just developed a new maintenance cat food for adult cats. You have just been handed the following choices for a pet food name. Your choice of pet food name must match the ingredient list of your food. Which pet food name is correct according to AAFCO labeling requirements?
Pet Food Ingredients: Chicken, chicken meal, chicken liver, brown rice, chicken fat, pumpkin, vitamins and minerals.
Pet Food Name
Choice 1. Fluffy’s Chicken & Tuna Adult Cat Food
Choice 2. Fluffy’s Chicken Adult Cat Food
Choice 3. Fluffy’s Chicken & Liver Adult Cat Food
(Answers below)
While the above was just a small portion of what a pet food manufacturer or a State feed inspector has to do to make sure pet foods are labeled correctly, there is a great deal more to understand about pet food regulations. And AAFCO certainly holds a great deal of the power in pet food world.
Members of AAFCO have developed over the years the health claims that can or cannot be stated on labels, and pet food name requirements such as the 95% rule where a Turkey Adult Cat Food would have to contain 95 percent turkey in the formula exclusive of water sufficient for processing the food. AAFCO has developed animal food ingredient definitions and possibly the most important – nutrient profiles (the required nutrients of pet foods).
When you consider that AAFCO members are not – on average – scientists with degrees in animal nutrition, when you consider that AAFCO members have full time jobs besides their voluntary position with AAFCO, its a bit overwhelming to think they have the responsibility of developing intricate animal feed guidelines (their manual is over 500 pages) for chickens to cows to cats and dogs. The above was just a small piece of only dog and cat food labels…think about every single aspect of every animal feed. I’m worn out just thinking about it.
So…how do you think you did on the pet food test?
The answers…here’s the three pet food labels again…
Pet Food Label A
Fido’s Brand
Beef Dog Food
Ingredients: Beef, beef liver, organic choice sweet potatoes, chicken fat….
Guaranteed Analysis
Crude Protein max 26%
Crude Fiber max 5%
Crude Fat min 8%
Moisture min 10%
Feeding Directions
Adult Dog to 15 pounds feed 1/2 cup daily
Adult Dog 15 to 30 pounds feed 3/4 to 1 cup daily
Pet Food Label B
Fido’s Brand
Beef Adult Dog Food
Ingredients: Beef, beef liver, organic sweet potatoes, chicken fat….
Guaranteed Analysis
Crude Protein max 26%
Crude Fat max 8%
Crude Fiber max 5%
Moisture min 10%
Feeding Directions
Adult Dog to 15 pounds feed 1/2 cup daily
Adult Dog 15 to 30 pounds feed 3/4 to 1 cup daily
Pet Food Label C
Fido’s Brand
Beef Adult Dog Food
Ingredients: Beef, beef liver, organic sweet potatoes, chicken fat….
Guaranteed Analysis
Crude Protein min 26%
Crude Fat min 8%
Crude Fiber max 5%
Moisture max 10%
Feeding Directions
Adult Dog to 15 pounds feed 1/2 cup daily
Adult Dog 15 to 30 pounds feed 3/4 to 1 cup daily
Which label(s) will pass inspection?
Which label(s) won’t pass inspection and why?
Pet Food Label C will pass inspection. Pet Food Label A and B would not.
What’s wrong with Pet Food Label A?
The pet food name does not specify a class – it should read Adult. Ingredient panel added ‘choice’ which is a quality statement; not allowed. In the Guaranteed Analysis, the order of analysis was incorrect; it should be crude protein, crude fat, crude fiber, and moisture. Plus the Crude Protein was listed as max and it should be listed as minimum.
What’s wrong with Pet Food Label B?
Guaranteed Analysis lists crude protein and crude fat as maximum values, it should be minimum values.
And Part 2 of our pet food test…Which pet food name is correct according to AAFCO labeling requirements?
Pet Food Ingredients: Chicken, chicken meal, chicken liver, brown rice, chicken fat, pumpkin, vitamins and minerals.
Pet Food Name
Choice 1. Fluffy’s Chicken & Tuna Adult Cat Food
Choice 2. Fluffy’s Chicken Adult Cat Food
Choice 3. Fluffy’s Chicken & Liver Adult Cat Food
The correct pet food name is Choice 2 or Choice 3. Choice 1 is incorrect because the food does not contain tuna.
Next time you purchase a dog food or cat food from your favorite Pet Food Store (support your local independent pet food stores!), know that the manufacturer that you trust not only has to be concerned about ingredient quality and safety, they have to worry about the pet food label and the many tiny details AAFCO regulations require.
Some may not be a fan of AAFCO (I’m on the fence) but I assure all that very soon our team of Pet Owner Advocates will be lobbying AAFCO just as industry has for years. We fully expect to have the interests of Pet Owners in the forefront of attention of AAFCO members. I’ll keep you posted on our progress.
