Right Wrongs in Pet Food Regulations

In two weeks, the American Association of Feed Control Officials (AAFCO) will host another pet food/animal food regulatory meeting.  Even though you might not personally be able to attend, you can help influence the regulatory process.  Note:  this industry desperately needs help.  Here are some glaring wrongs in pet food regulations and a plea for your help to right them.

AAFCO is a voluntary body comprised of State Department of Agriculture employees who along with various representatives of FDA develop all the pet food/animal food ingredient definitions, nutrient profiles, label requirements and so much more that each state makes into law (the laws that govern all pet foods/animal feeds).  The AAFCO organization is subdivided into action specific committees such as (and important to pet food consumers) the Ingredient Definitions Committee and the Pet Food Committee.  Each Committee within AAFCO also hosts what is known as “Advisors” – non-voting members mostly from industry.  Currently, on the two most significant pet food committees (Ingredient Definitions Committee, Pet Food Committee) there are 12 to 14 representatives of industry and only one consumer representative (Dr. Jean Hofve; I was removed from these committees at the last meeting – no reason provided).

Now imagine the AAFCO members, with mostly agriculture related degrees, having to write proposed regulations on animal specific nutrient requirements and detailed labeling requirements.  Imagine being in charge of (as example) writing the proposed legal definition of a pet food ingredient.  Where do you start?  Oh, and this task of writing the legal definition of a pet food ingredient is in addition to your ‘regular’ job and you possibly have to use your own money and vacation time to attend regulatory meeting.  So where do you start?  Who do you turn to?

I can tell everyone, from the personal experience of attending AAFCO meetings, most AAFCO members turn to the “Advisors” of each committee.  In other words, they turn to industry to write their own regulations.  This is NOT a means to blame AAFCO – this is simply the facts of how things work.  Industry – the Pet Food Institute, the National Renderers Association, the American Pet Products Association, the National Grain and Feed Association, and the American Feed Industry Association (all representing their members – Big Pet Food, and Big Pet Food ingredient suppliers) – are literally writing their own regulations.

Examples of the influence of industry on pet food regulation…
Because properly disposing of waste such as downer livestock animals, diseased animals, euthanized animals, rodent/bird feces infested vegetables and grains would be an expense to industry, the FDA and AAFCO have provided industry with a method to sell such waste as pet food ingredients.  Just about any pet food ingredient could be sourced from healthy animals or fresh vegetables or it could be sourced from diseased – rejected for use in human food animals and moldy, filth contaminated vegetables.  The pet food consumer is provided with NO clarification to the quality of any particular pet food ingredient.  None.  In fact, it’s illegal to state quality of ingredient on a pet food label.  A pet food would be pulled from store shelves by regulatory authorities if a quality minded manufacturer stated on the label the grade or quality of  the ingredients in their pet food were USDA inspected and approved (human grade).

Pet food ingredient definitions don’t clearly identify exactly what any ingredient contains.  As example, ‘chicken’ on a pet food label could be ONLY chicken skin and bone – no meat.  Industry doesn’t want us (petsumers) knowing exactly what our pets are eating.  At one of the AAFCO meetings I attended, I heard the discussion at the Ingredient Definitions Committee regarding the development of a name for a pet food ingredient sourced from expired foods from groceries (expired Hot Pockets was the example provided); it was stated ‘We have to come up with a name that the consumer will buy’.

Even down to what is stated on pet food labels have been skillfully crafted by industry.  The Guaranteed Analysis statement required on pet food labels is by no means a ‘guarantee’ of anything.  Most significantly, fat is required to be listed on a pet food label as minimum.  Not actual fat content as human food labels are required to do – only the least amount of fat possible in that pet food.  Thus, a pet food label might state 5% fat on the label, when actually it contains 20% fat.  Calories are calculated differently in pet food as in human food – significantly less.  And pet food products are allowed to display imagines of fresh meat and vegetables on the label – implying the pet food is sourced from grilled chicken breasts or freshly picked vegetables – when just the opposite is true (no grilled chicken breasts…no meat at all, and waste vegetables unsuitable for use in human food).

Needless to say, pet food regulations are not consumer friendly.  Regulators of the pet food industry need to hear from consumers – to hear that you (and you, and you, and you) want them to make conscious efforts towards consumer friendly pet food regulations.  I tell them this is what consumers want, but many of those in charge don’t seem to believe me.  So I’m asking you (and you, and you, and you) to send a message or call your AAFCO representative and tell them you want consumer friendly pet food regulations.

Example email:

Dear ________,

I am writing you as a concerned pet food consumer.  When I walk into a pet food store, there are thousands of options for me (and my pet).  But in closely examining the labels, I am provided with no clarification of the quality of the pet food or treat I am purchasing.  Does this pet food contain rejected for use in human food ingredients?  Are the meats and vegetables used in this pet food the same quality as the foods I buy for the rest of my family?  Does this food contain GM ingredients? Which countries did this pet food company source ingredients from?  In other words, I have to become a private detective to determine if a pet food is good for my pet to consume.

This shouldn’t have to happen.

As well, why isn’t the nutritional statement on pet foods the same as any other food I purchase?  Why are calories calculated lower on pet foods?  Why isn’t the actual nutritional content of the food stated on pet food labels?  Why should a consumer have to learn a completely different language (ingredient definitions) to determine what is included in a pet food.

I am aware the next AAFCO meeting is coming up soon.  I ask you, as my State Representative to take an active role in changing pet food regulations to be consumer friendly.  Pet food consumers deserve to know what they are buying.

Thank you,

________________

Click Here to go to the AAFCO webpage listing of members.   This directory lists members by state and provides phone and email contact information.

Thanks to everyone for voicing your opinions to our regulatory authorities.  I will (of course) be reporting to you during the AAFCO meeting (January 22-24 in Albuquerque, NM).   Let’s hope AAFCO members will listen to us.

Wishing you and your pet(s) the best,

Susan Thixton
Pet Food Safety Advocate
Author, Buyer Beware
Co-Author Dinner PAWsible
TruthaboutPetFood.com
PetsumerReport.com

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