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.
“(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.”
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,
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