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Pet Food Regulations

FDA is trying to pull a fast one…

Be prepared, FDA is working their way towards replacing the term feed with food.

The FDA is actively trying to end the use of the term ‘feed’.  Shielding industry – seemingly specifically the pet feed industry – at the expense of transparency for pet owners.

In the Federal Register on November 3, 2022 – the FDA posted a notice requesting comments regarding the “Federal-State Food Regulatory Standards”. These ‘standards’ are an effort between FDA and some US States. This federally funded program is an effort to have uniform regulations and uniform enforcement of law. The animal feed/pet food portion of these Regulatory Standards is currently termed “Animal Feed Regulatory Program Standards” (AFRPS) – BUT…FDA is proposing to change the name and legal definitions within the Standard to “Animal Food” instead of “Animal Feed.

The FDA claims the change from Animal Feed to Animal Food will “improve program effectiveness, understanding and clarity.” However, the FDA did not provide any evidence to support their claim that changing feed to food will improve program effectiveness, understanding or clarity.

Would changing the name of the program (from feed to food) really improve effectiveness, understanding and clarity?

No, it won’t. In fact, the name change does nothing to improve effectiveness, would add to the confusion, destroys clarity and puts an end to transparency efforts for pet food consumers.

As example, AAFCO – the Association of American Feed Control Officials – is a partner organization of the Animal Feed Regulatory Program Standards (AFRPS). In order to achieve ‘clarity’ AAFCO would need to change their name to AAAFCO – the Association of American Animal Food Control Officials.

The 25 member states of AFRPS would need to change wording of their state laws. As example, North Carolina laws are titled “Commercial Feed Law”, pet food is legally defined as “any commercial feed prepared and distributed for consumption by pets.” In the North Carolina laws, the term ‘feed’ is referenced 152 times. To achieve the ‘clarity’ that FDA claims occurs with the name change, the state of North Carolina would need to change 152 different words within their state laws. And this same reference to feed in each of the other 24 member states would need to be legally changed as well.

Even the job titles of employees who enforce the regulations are called “Feed Officials” – not ‘Animal Food Officials’.

Who is going to pay for these hundreds – if not thousands – of different changes to state laws? Changes to law is not a simple process, and it is not accomplished for free.

Unless everyone makes the feed to food changes to their laws, organization names, and employee titles – there is NO improvement to effectiveness, understanding and clarity as FDA claims this proposed name change will achieve. Unless everyone makes the legal feed-to-food change, FDA’s proposal significantly adds to confusion.

But…the feed-to-food name change DOES provide some protection to pet feed producers.

In the past ten years, the consumer awareness of the differences between feed and food has grown significantly. Evidence of this is the growth of human grade ingredient pet foods and financial interest of traditional pet feed brands in pet ‘foods’. Such as General Mills’ – the owner of Blue Buffalo – 2020 investment in Pet Plate and Mars Petcare’s 2022 purchase of Nom Nom.

It benefits industry to make all pet ‘foods’ appear to be similar, no separation between feed and food. It benefits feed grade pet food manufacturers to be classified as animal food grade manufacturers. But it certainly does not benefit pet owners.

Unfortunately, the date to post a comment on this issue has passed (comment period closed January 3, 2023) on the Regulations.gov website. Our consumer association posted a lengthy and a second brief comment before the deadline closed. But pet owners can (and please do) send a comment regarding the proposed feed-to-food name change directly to FDA Center for Veterinary Medicine. Email FDA CVM at: AskCVM@fda.hhs.gov.

Wishing you and your pet(s) the best,

Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
TruthaboutPetFood.com
Association for Truth in Pet Food


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10 Comments

10 Comments

  1. T Allen

    January 5, 2023 at 3:09 pm

    I’ll bet the mid-west/ western states will throw a fit! As they well should. Talk about unfunded mandates…

  2. Stephen Abarno

    January 5, 2023 at 3:24 pm

    Nothing new with the criminals at FDA !! The AAFCO is just as bad !!! American pets get poisoned just like people with the FDA and CDC !!

    • Robin Madrigal

      January 5, 2023 at 7:18 pm

      Thank you. Stephen, for stating exactly what I was thinking having now lost two family members “suddenly” shortly after their “safe and effective”, and being told by doctors their heart attacks were “normal” not related to anything recently injected within the previous two weeks prior to their passings.

  3. sonya manejkowski

    January 5, 2023 at 3:28 pm

    The FDA dept. regulating pet food is soooo in bed with those they regulate.
    60 minutes needs to know, every major news outlet that is online, TV, newspapers.

    One day some little child will eat their dog’s kibble and gets hospitalized– then their greedy pockets will be punished.

  4. Alexandra Whitelock

    January 5, 2023 at 4:03 pm

    I’m a bit puzzled. Dry food bags say ‘Dog Food’…not dog ‘feed’…🤷‍♀️
    I adore my dogs…go great lengths for their health. But…they are animals…not humans sooo in a dictionary sense, dog food is a feed…right?
    I understand the difference between crap swept up off milling floors..,waste products.
    Scratching my head on this…

    • Amy Renz

      January 6, 2023 at 12:36 pm

      Hi Alexandra,
      As Mom to 3 dogs, and owner of a human grade dog *food* manufacturer that’s proudly included in The List that Susan Thixton publishes, the difference for me between Feed and Food comes down to a simple question:

      Is it edible under the regulations of the Food Drug and Cosmetic Act?

      If it is, then the word “Food” applies. If it is not, then the word “Feed” applies. This distinction makes things very clear for me and perhaps/hopefully many other consumers.

    • T Allen

      January 7, 2023 at 8:35 pm

      In the past, feed was for animals. Chicken feed, livestock feed, poultry feed, etc. And food was for people. In order to help make our dogs and cats more like members of the family, after they moved inside instead of living in the barn, feed was rebranded “pet food”. Labels show pictures of whole, wholesome “food” that you would want to eat so you would buy it for your pet. Unfortunately what is in the bag/can is not the “food” the picture shows but nasty, toxic, 3D and rendered garbage. Which shouldn’t even be fed to animals but is and needs to be labeled as “feed”.

  5. Marybeth F. Marousek

    January 5, 2023 at 4:28 pm

    I sent my comment to the FDA Center for Veterinary Medicine. I hope they have a big voice in this decision.

  6. Krista Karpowich

    January 5, 2023 at 6:43 pm

    Same old, same old. Unfortunately Susan, I think you have a job, make that a mission for life. We have the wrong agencies overseeing the health of our pets 🙁

  7. Carol Bryant

    January 6, 2023 at 5:58 pm

    Thanks for putting this info out there. I am sharing everywhere.

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