Notes from AAFCO Meeting January 2019

Another AAFCO meeting completed. Here are the notes from the 2019 mid-year meeting.

The January Association of American Feed Control Officials (AAFCO) meeting is complete. FDA was not in attendance. Every decision made during this meeting was made without FDA approval.

During the session “Model Bills and Regulations Committee“, Pet Fooled (documentary about the pet food industry) producer Kohl Harrington went to the microphone and asked the committee a question regarding a discussion of the definition “Adulteration”. It was more than apparent Committee Chair Mr. Doug Lueders (Minnesota Department of Agriculture) did not like the question or Kohl Harrington. Mr. Lueders was rude and disrespectful shutting down any attempt for clarification asked by Kohl Harrington.

During this same session, there was brief discussion on an AAFCO rule “Regulation PF12. Chews, Bones and Toys for Pets or Specialty Pets“. The discussion was short as this particular regulation was moved to another Committee to discuss again in the future (it was moved to the Pet Food Committee). It should be noted…AAFCO does not write laws governing pet “Toys”. It is unknown why this word is included in the current laws.

On day 2 of the January 2019 AAFCO meetings was the Ingredient Definitions Committee where we had discussion again about the pet food ingredient “Buffalo”. History behind this ingredient discussion is some pet food manufacturers are using Bison – otherwise known as the American Buffalo that is a much more expensive product. Other manufacturers are using Water Buffalo imported commonly from India, which is far less expensive than the Bison ingredient. The AAFCO concern is the two different ingredients are misleading consumers. In fact it was stated some companies have “shady practices” hiding the Water Buffalo ingredient from consumers, “plenty of evidence it is intentional“. Unfortunately – again, AAFCO made no decision on this ingredient (in other words, pet foods will be able to continue to mislead pet owners). We will have to wait until the next meeting for more information.

During the Pet Food Committee meeting there was discussion about ‘the 95% rule’. The FDA explains this pet food regulation as: “The “95%” rule applies to products consisting primarily of very few ingredients. They have simple names, such as “Beef for Dogs” or “Tuna Cat Food.” In these examples, at least 95% of the product must be the named ingredient (beef or tuna, respectively), not counting the water added for processing.”

While there was no mention of any specific pet food company, during this discussion we learned that some pet food manufacturers are misleading pet owners by claiming ‘95% Beef (or other meat)’ when they are including the moisture of the meat. Meat is up to 70% moisture – thus the claim of ‘95% Beef’ cannot be made unless the moisture was removed (the pet food would actually only be estimated 30% Beef). “Percentage claims that are inflated” is what consumers currently have to deal with. And again, no decision was made on what to do about this pet food problem. Discussion will continue at the next meeting.

The second half of the Pet Food Committee meeting was devoted to providing updates to AAFCO’s work on “Pet Food Label Modernization”. AAFCO performed a consumer survey on the proposed label updates and their results were quite surprising (but not in the way AAFCO probably expected. Below are slides of the presentation – provided by a pet owner who watched the meeting online.

As we expected (but AAFCO did not), consumers wanted a ‘Pet Nutrition Facts’ box to provide the same nutritional information that was on human food labels.

The pet owners surveyed liked the calories per cup. Note that the proposed updates would include a breakdown of calories obtained from Protein, Fat and Carbohydrates.

The pet owners surveyed did not know who AAFCO is, or what AAFCO does.

Regarding the ingredient listing on pet food labels:

The pet owners surveyed stated “meal products” (meat meal ingredients such as chicken meal) “can contain lots of parts of things and are not particularly healthy.” The AAFCO officials were shocked by this stating (at the meeting) there is a “lack of consumer understanding of the nutritional benefits of meals.” This AAFCO statement was opinion, no information was provided to validate their opinion.

In the image below, the proposed change in the way ingredient listings would be presented on a pet food label was provided to the pet owners surveyed. The current listing of ingredients on a pet food label are presented in order of weight in the actual pet food (heaviest to lightest) seen in the image below in the top green highlighted box. The proposed ingredient listing was to break the listing into two sections – main ingredients and ‘Contains 2% or less of’ listing of ingredients. This is displayed in the second green highlighted box below.

The pet owners surveyed did not like the change in ingredient listings. Further they preferred “vitamins listed by common names.”

The slide below was regarding warning statements proposed for all styles of pet food. The warning on the right side is proposed for raw pet food, the warning on the bottom right is proposed for kibble.

One of two significant pieces of information (personal opinion) discovered by the AAFCO pet owner survey was found in the following slide:

The pet owners surveyed stated “When evaluating the raw product, most consumers are aware of the danger of salmonella and follow cleanliness practices to prevent it, both in human and pet food.” Unlike FDA opinion, consumers are not ignorant of the safe handling procedures for raw meat.

The next section was regarding a ‘seal’ AAFCO wants to include on pet food labels in the future for ‘Complete and Balanced’. The seal is displayed center bottom of this slide – pictured below the large 55 lb circle on this label example. And the other significant piece of information gathered from this pet owner survey is found on the slide below.

The surveyed pet owners did not like the seal, and significantly the pet owners did not believe Complete and Balanced was true. It was stated at the meeting, pet owners felt the Complete and Balanced claim was “weak, meaningless, just another marketing statement.”

The discussion during the meeting after the slide presentation was more than concerning. AAFCO members continued to make statements that felt almost as if they believed pet owners are stupid.

A consumer posted a question in the AAFCO system Slido.com asking (twice) for the definitions of ingredients and regulations governing pet food to be public information – AAFCO deleted their comment (twice) ignoring the question. I walked to the microphone and told the crowd the following:

“In defense of consumers, how are consumers supposed to know – what you here are surprised that they don’t know – when the OP (Official Publication – AAFCO owned book of pet food ingredient definitions and pet food regulations) is owned by AAFCO and not public information? So I think you are expecting consumers to know things – when how can they? It’s not public information.”

Dr. Judy Morgan followed telling the room ‘Finding consumers don’t know who AAFCO is and saying you need to reach out to consumers, I would say you need to reach out to veterinarians. You are saying veterinarians should provide nutritional information to their clients – we are not given nutritional courses other than what we’re told about selling prescription diets. I bet if you did a focus group on veterinarians, three fourths of them wouldn’t know who AAFCO is. I think you better start there, and then they can educate their clients as to what they are looking for on labels.’

Will AAFCO listen to us? Doubtful.

All in all it was a successful meeting seeing friends and quality pet food manufacturers. Friends in attendance were Dr. Cathy Alinovi, Chelsea Kent, Dr. Judy Morgan (and her wonderful husband), Laura Beveridge (pet owner), Kohl Harrington, Tazz Latifi. Quality pet food manufacturers in attendance that allowed us to get to know them even better was Answers and All Provide. My thanks to all of them for attending.

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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