This was a question sent to me by a reader. And my answer is…no and yes. Here’s why.
AAFCO – Association of American Feed Control Officials – is a non-government association made up of government employees (state and a few federal). The key words to recognize in order to understand what AAFCO is are ‘Feed Control Officials’. For the most part, AAFCO is comprised of state Feed Control Officials (State Department of Agriculture representatives) that work together to develop future laws governing the food animals consume (feed). The work of AAFCO includes guidance and cooperation with FDA as well.
AAFCO doesn’t ‘approve’ pet foods. Actually AAFCO itself doesn’t approve or reject or have any regulatory authority at all. The confusion as to why many pet food consumers think AAFCO certifies or approves pet foods comes from the statement found on many pet food labels: ‘XYZ Pet Food is formulated to meet the nutrition levels established by the AAFCO Food Nutritional Profiles’. In many states (but not all), in order for a pet food to be labeled as a ‘food’ it is required by law to meet the nutritional requirements established by AAFCO. It would be individual states – not AAFCO – that basically ‘approves’ a pet food (or approves it to be classified as a food instead of classified for supplemental feeding).
AAFCO’s ‘provides complete and balanced nutrition’ statement that appears on most pet food labels is perceived by many (and marketed by many) as the level of excellence – what all pet foods should be measured by. But, here are some problems with that…
1. The AAFCO system is feed, not food. In the Feed Control Official world, feed is what animals eat, food is what humans eat. Per FDA Compliance Policies and AAFCO established model bills, feed is allowed to contain euthanized animals or pesticide contaminated ingredients – food cannot. AAFCO has a separate division that is specific to pet food, but Feed Control Officials still consider pet food a feed. Most states (ok…all states) don’t take issue with a pet food (aka pet feed) containing protein sourced from euthanized animals or pesticide laden grains/vegetables. Even though the ‘stuff’ that pets consume is titled ‘pet food’ it is considered ‘pet feed’ and it is held to regulations of feed (not regulations of food).
2. The nutritional requirements established by AAFCO adopted by many states (but not all) were (again) based on feed quality of ingredients, not food quality of ingredients. And these nutritional requirements were established for highly processed foods like kibble. This can pose a problem for pet foods that are made from food quality ingredients and are lightly processed. It’s known as bioavailability – how well the body absorbs a nutrient. Mother Nature immediately understands what food is and utilizes the nutrition found in that food easily. To the contrary, Mother Nature might not easily utilize a synthetic supplement (man made instead of Mother Nature made) or a nutrient sourced from a decaying, euthanized animal protein. Mother Nature can readily absorb the nutrients from a lightly processed food, but she undoubtedly is challenged to utilize the nutrients in a highly processed food. But in pet food regulations, it is a one size fits all nutritional requirement. The AAFCO system does not acknowledge that a pet might utilize nutrition received from food better than it would from a feed or synthetic supplements.
Some pet foods that use whole food ingredients (not feed ingredients), recognize if they met the AAFCO one size fits all nutritional requirements, their food could actually be toxic to some pets (with some nutrients). These companies choose to forgo the ‘meets the AAFCO nutritional requirements for complete and balanced nutrition’ label claim. Does that make these foods inferior? Absolutely not. In many cases, the manufacturers of these human grade/whole ‘food’ pet foods provide superior nutrition. They are food – exactly what Mother Nature understands as the perfect method to provide the pet with required nutrition.
But does that mean all pet foods that do not meet the AAFCO nutritional requirement for complete and balanced nutrition are superior nutrition for our pets? No, it doesn’t. Because there are no regulations specific to food grade ingredients or whole food nutrition for cats and dogs – undoubtedly some of these pet foods could be lacking in some nutrients needed by our pets. The key for pet food consumers to know the difference is to talk with the manufacturer. If your pet’s food does not meet AAFCO nutrient profiles, ask the manufacturer why. In many cases, you’ll learn amazing things about the pet food – why the company chose not to follow the AAFCO path.
3. AAFCO’s established complete and balanced nutrition provided daily is not how Mother Nature intended. Animals (and humans) are designed to be ‘seasonal eaters’. The Cleveland Clinic defines seasonal eating as: “Eating foods when nature produces them is what people the world over have done naturally through most of history, before mega-supermarkets dotted the landscape and processed foods become ubiquitous. Seasonal eating is also a cornerstone of several ancient and holistic medical traditions, which view it as integral to good health and emotional balance.”
AAFCO’s established requirement that animal food should contain 100% of necessary nutrients the animal would need each day would be more suited for mass production of livestock animals (cattle, pigs, chickens) which have a short life span (from months to a few years). These 100% daily nutrient requirements were put in place decades ago because the livestock industry needed the animals to grow quickly and be healthy enough to be processed (slaughtered) as food. Today, there is no time to allow mass produced livestock the opportunity to eat seasonally. Pets (cats and dogs) are expected to live long lives, thus the need for daily balanced nutrition is not the same as it is for mass produced livestock. But…in the one size fits all world of AAFCO – the same nutritional requirements met daily in feed is also required of pet food.
So, back to the question sent to me by a consumer – Should my pet’s food be AAFCO approved? Yes and No.
In that the AAFCO established nutrient requirements only fit one segment of pet food (feed grade ingredients, mostly high processed) – yes, meeting the complete and balanced claim with pet foods made with feed grade ingredients and pet food that are highly processed is probably better than nothing.
But due to the concerns explained in this article, no – I do not believe a pet’s food is required to meet the complete and balanced nutritional requirements established by AAFCO. What I believe (personal opinion) is the most important thing to consider when feeding our pets is that they be fed food (USDA inspected and approved for human consumption) – not feed (can be rejected for use in human food, euthanized animals, chemical and pesticide laden).
I believe AAFCO’s complete and balanced can be a benefit or it can be a curse. There is no simple answer.
One last thought…if the AAFCO complete and balanced claim was really the level of excellence it is proclaimed to be, then why is obesity in pets epidemic? Why do 50% of all dogs die of cancer? Why do so many pets have skin issues or kidney disease or an array of other common diseases?
Wishing you and your pet(s) the best,
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