Per federal law, feed grade pet foods are required to be labeled as “imitation“.
Federal laws, specific to animal food – “Sec. 501.3 Identity labeling of animal food in package form” – clearly defines labeling requirements for pet food (or any animal food). But…just like other laws of pet food, these laws are not being enforced.
Quoting:
“(1) A food shall be deemed to be an imitation…if it is a substitute for and resembles another food but is nutritionally inferior to that food.”
And federal law spells out exactly what “nutritionally inferior” means.
“(i) Any reduction in the content of an essential nutrient that is present in a measurable amount.”
There is no argument, feed grade pet food ingredients – labeled as another food – are nutritionally inferior. Example: chicken.
The AAFCO legal definition of pet food chicken allows for the ingredient to be condemned chicken – certain to be nutritionally inferior to USDA inspected and passed edible chicken.
AAFCO also allows pet food chicken to be mainly chicken skin and bones – little or no meat. Again, certain to be nutritionally inferior to chicken consumers are familiar with in human food.
Based on federal law, pet foods with ingredients that are nutritionally inferior “in any measurable amount” – are required to be labeled as “imitation” OR the pet food would be misbranded and it would be required to be recalled. Quoting law (bold added):
“Under the provisions of section 403(c) of the Federal Food, Drug, and Cosmetic Act, a food shall be deemed to be misbranded if it is an imitation of another food unless its label bears, in type of uniform size and prominence, the word imitation and, immediately thereafter, the name of the food imitated.”
Comparing the protein content of 100 grams of USDA inspected and passed edible chicken to feed grade/pet food chicken we find significant nutritional differences.
There is NO question about it. Pet food feed grade chicken IS nutritionally inferior to human grade chicken. So…per federal regulation – a pet food/animal food is required to include the word “Imitation” in the product name (on the label) when the food is “substitute for and resembles another food but is nutritionally inferior to that food.” This law means that all pet foods using feed grade ingredients (nutritionally inferior) are required to be labeled like this:
The unfortunate thing for millions of US pet owners, this is another law that is ignored by FDA.
We will be requesting the FDA enforce these pet food labeling laws. Should the Agency respond – it will be shared.
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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~Pet Owner~
October 3, 2019 at 4:06 pm
How can you have “farm-raised” imitation chicken?
Do the imitation chickens run with the real chickens?
Susan Thixton
October 3, 2019 at 4:53 pm
The point is the name of the pet feed is required by law to include the word ‘imitation’ in front of the ingredient being imitated – because it is nutritionally inferior to chicken. The word imitation would at least give pet owners a heads up to the ingredient not being chicken as most understand it. But I agree – the farm raised imitation would be interesting.
T Allen
October 3, 2019 at 7:53 pm
“Farm raised” is a useless term as it is. There aren’t too many “city raised” chickens!! On the other hand, ” farm -raised imitation” is perfect because it’s so silly it would get people’s attention and maybe they’d stop and think about it. 🙂 Great job Susan!
Mitch
October 3, 2019 at 6:23 pm
Thanks for all you do, Susan. Nothing you write surprises me, considering that literally every RX drug approved by the Fraud and Deception Agency can kill us or our animals. The FDA is supposed to protect us and our animals, but they only exist to protect the corporate profits.
M
October 4, 2019 at 12:21 am
I’m very scared about my dry food it’s called Pedagree. They seem too like it but my Sister feeds nothing but dry food all the time too my Dog & Her 2 dogs. I think it’s wrong of her for doing so. That is why Sam has allergy because she’s feed Him that. Any way. It’s very hard living with her because she has probulms. Can’t get help that she should.
Cannoliamo
October 4, 2019 at 11:40 am
I’m just guessing, but that may be why the imitation prescription diet food can be dispensed from imitation pharmacists with imitation prescriptions at artificially inflated prices.
Sue
October 5, 2019 at 10:07 am
That was good Cannoliamo! It is absolutely disgusting what our so called “safety food advocates” are NOT enforcing, I often wonder what they feed their pets, if they have any. I’ll bet it’s not any of this crap!! FDA, really? should be ashamed as well as AAFCO, both are supposed to be protecting animals and are obviously not.
Tina
October 7, 2019 at 11:47 pm
How informative. & disgusting. Thanks a lot