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Pet Food Regulations

Substantiate a Label Claim

The FDA told us that a pet food manufacturer should have information to substantiate a label claim is truthful and not misleading. So…let’s ask pet food for that substantiating information, see who provides it and who doesn’t.

The FDA told us that a pet food manufacturer should have information to substantiate a label claim is truthful and not misleading. So…let’s ask pet food for that substantiating information, see who provides it and who doesn’t.

The FDA recently told pet food consumers that “a manufacturer or distributor should have information to substantiate that the claim is truthful and not misleading” in reference to pet food labels.

The FDA tells pet food consumers that “Pet food labeling may not be false or misleading in any particular.”

Based on these two FDA requirements of pet food, Association for Truth in Pet Food (ATPF – our pet food consumer association) will be sending Science Diet a request for information to substantiate the roasted chicken image on their label. At the same time, ATPF will ask Science Diet to substantiate the “Made in the USA” label claim. Per FTC requirement and per AAFCO requirement, “Made in the USA means that “all or virtually all” the product has been made in America. That is all significant parts, processing and labor that go into the product must be of U.S. origin.” (In other words, if Made in the USA is stated on a pet food label, requirements are that all ingredients must be of U.S. origin – no Chinese sourced supplements.)

Science Diet Crafted Cat Food compare

ATPF will be sending Merrick Pet Food the same request for information to substantiate the grilled steak label image and their label claim Made in the USA.

Merrick Classic Beef food image compare

And ATPF will be sending many other pet food manufacturers requests for information to substantiate their label claims – just to make certain that no pet food label is “false or misleading in any particular”.

All requests will be documented online, all responses and lack of responses will be documented on the same webpage at AssociationforTruthinPetFood.com (to be built and announced soon). If the FDA and each State Department of Agriculture refuses to police misleading pet food label claims, then consumers and consumer advocacy organizations (ATPF) have no choice but to take this to the streets.

Every pet food consumer has to right to ask any pet food manufacturer to provide information to substantiate label claims. I think we should all ask.

As example, below is the letter sent to Science Diet (from ATPF)…

On behalf of pet food consumers, I am writing requesting information from Hill’s Science Diet to substantiate the roasted meat and grilled meat images on your line of ‘Crafted’ pet foods. As example, the Crafted Grain Free Herbed Chicken & Chickpeas Recipe Cat Food label contains an image of roasted chicken on the label. Per the FDA, pet food manufacturers are required to provide information to substantiate label claims – as well, FDA states that “Pet food labeling may not be false or misleading in any particular.” Thus, I am requesting information from Hill’s Science Diet to substantiate the roasted and grilled meat images on all of the ‘Crafted’ line of pet foods.

As well, I am requesting information to substantiate the ‘Made in the USA’ label claim on ‘Crafted’ line of pet foods. Per FTC requirement and per AAFCO requirement, “Made in the USA means that “all or virtually all” the product has been made in America. That is all significant parts, processing and labor that go into the product must be of U.S. origin.” Thus, I am requesting information from Hill’s Science Diet to substantiate the Made in the USA label claim on all ‘Crafted’ line of pet foods.

To provide full transparency on our end, AssociationforTruthinPetFood.com – a pet food consumer advocacy organization – will be posting all requests for information to substantiate label claims and company responses on our website for all pet food consumers to read.

Pet food consumers await your response to this request for information.

Susan Thixton
Pet Food Consumer Advocate

Association for Truth in Pet Food

 

Please know – that each one of you has the right to ask any pet food manufacturer to substantiate a pet food label claim. And please do ask them to substantiate anything on the label you question. For record purposes, forward all responses to me (Susan at Truth about Pet Food dot com – or use the contact form on the website) so they can be posted on our Association website for all pet food consumers to read. This will be interesting to see what types of responses we get.

There are many, many pet food labels that I question – this will be on on-going pet food advocacy effort.

 

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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17 Comments

17 Comments

  1. Casey

    June 26, 2015 at 3:38 pm

    It will be interesting to see what they come back with. Or if they respond at all.

    The fact that their pretty pictures do not in any way reflect what is actually in the food has never stopped them before, though.

  2. Batzion

    June 26, 2015 at 3:46 pm

    Sue, I think we’re going to need more than “Made in the USA.” The World Trade Organization just ruled against country-of-origin labeling on meat imported into the U.S. It might be “Made in the USA,” but with ingredients from where? We will need a label saying that the meat was sourced in the U.S. http://www.foodsafetynews.com/2014/10/wto-rules-against-country-of-origin-labeling-on-meat-in-us/#.VY2riFKAogQ

  3. foodguy

    June 26, 2015 at 4:40 pm

    Asking manufacturers to substantiate claims is silly. The one’s who can substantiate claims will substantiate those claims, and the one’s that cannot, either will not respond, or will respond as if they have substantiated the claim.

    Now, the FDA’s blase attitude on this matter is absolutely disgusting. They basically admitted, while it is illegal, they will not pursue the matter.

    • Susan Thixton

      June 26, 2015 at 4:42 pm

      I feel we have to ask manufacturers because of FDA’s attitude. Pet Food consumers deserve to know if the label is accurate or misleading.

      • Ann*

        June 26, 2015 at 5:20 pm

        I agree with both of you, we must ask and then those who don’t answer must be viewed as using silence to avoid the truth. I will not buy their food if they do not respond to my questions. There are still enough reputable companies out there to give my business to them instead of a fraudulent company.

  4. Nina Wolf

    June 26, 2015 at 6:04 pm

    Imagine al the wasted time and effort put into these queries every day, but consumers, responsible pet nutrition stores, advocates, etc. It is utterly ridiculous to put the onus on all of us, instead of on the one agency who has the authority to enforce. But this is the situation we are left with. You go girl, and if I can help let me know. See you soon!!!!

  5. foodguy

    June 26, 2015 at 6:06 pm

    But there is nothing to hold them responsible for lying, so there is no benefit to telling the truth. They are never going to answer you honestly, or anyone else honestly for that reason.

    Susan- I don’t think the manufacturers is the path. Look at how few have taken your pledge? Does this mean that manufacturers that have not taken your pledge are lesser quality than those who have taken your pledge? Not necessarily so.

    The problem with the pet food industry is that it is so protected from any and all repercussions, aside from maybe a nation wide recall. What is going to happen when people find out that respected brands are using chinese processed chicken, or byproducts, or anything else? If history tells us, absolutely nothing because some of those companies have already rebounded.

    It’s like the claim grain free or gmo free at this point. I don’t know how many bags of dog food would test void of grain if there was a batch analysis done. Because they are being produced in the same facility, often with very little cleansing done between batches. That is why the FDA found products to contain dna of ingredients not listed on the label. If it happens with proteins, you think they care about grain?

    Ultimately our government loves grain- it subsidizes the shit out of it. That’s why it is cheaper to buy a burger and fries with a sugar drink then it is to buy a bag of conventionally farmed carrots in the super market. Our government loves monoculture chem ag corporations, and mass produced beef, chicken, and pork. That is what feeds America and it’s pets.

    • Susan Thixton

      June 26, 2015 at 6:15 pm

      I agree, there is nothing to hold them accountable. I feel like I have to try something however. I’m so appalled at how pet food labels have gotten completely out of control because each State Department of Agriculture and FDA has sat back and done nothing to enforce regulations. Again, I realize it might be futile, but I have to try.

  6. keith

    June 26, 2015 at 6:07 pm

    My holistic veterinarian said to avoid feeding any big commercial pet food ever.

    Vet said to feed real meat and real veggies. If you buy real meat and real veggies and feed it to your dog, you know what your dog is eating.

    Why wonder what lies the big commercial corporations are feeding us. Avoid buying and instead buy real meat and veggies.

    This week my dog is eating raw ground turkey and frozen green beans. Absolutely loves it and his health has improved with feeding real food..

    But even dogs that are use to big commercial pet fast food processed wheat corn soy kiibble, will become use to eating real food and will soon prefer real food.

    This is very simple and an easy change.

    I have an acquaintance that only adopts dogs with cancer from the killing centers. He said he immediately puts the cancer dogs on a raw food diet. Some are not accustomed to eating raw food, but that is all that they are provided with each day, and if they don’t eat it, then put it back in the fridge and offer the raw food the next day. He said in a few days, the dog will be hungry to eat the raw food, and in a few weeks will prefer raw food.

    He said most the dogs cancers will shrink and even disappear on a real healthy food diet, with absolutely no big commercial pet food ever. Its the commercial pet food that feeds the cancer so that is permanently removed from the diet forever.

    He said these dogs eat very well and all the cancer dogs are walked several miles a day as oxygen also killls cancer cells.

    This is something to learn. If dogs with cancer can get better eating real food and exercise, then why risk your dog getting cancer eating big commercial pet food loaded with wheat, corn, soy and chemicals, when it is easier to feed your dog real meat and real veggies anyway and avoid cancer too.

    Makes sense.

    • Samantha Cuellar

      June 27, 2015 at 2:44 am

      That’s great, Keith, that raw foods kill cancer cells (along with oxygen), but I’m afraid of giving my dogs raw foods due to the fact that I can only get this raw foods from supermarkets or pet food stores which has gone thru the processing from slaughterhouse to wherever it ends up. How do I know this raw food isn’t shipped from China? And if it is coming from somewhere in the US, how do I know how many hands have touched this raw meat after using the restroom and not washing their hands and it ending up having salmonila or ecoli? That’s my worst fear with raw food, so I always end up cooking it. How do I get past this fear?

    • InkedMarie

      June 27, 2015 at 7:52 am

      Keith,
      Are you using a ground raw meat that contains bone? What about organs? If not, what you’re feeding isn’t balanced.

    • Yvonne McGehee

      June 29, 2015 at 12:42 pm

      Feeding a complete raw diet is not as easy as feeding some meat and vegetables. Meat and vegetables are woefully calcium deficient for dogs, for starters. Such a diet will also be difficient in vitamins and minerals and microminerals. Feeding a complete diet takes work, and most people are not about to do what is needed. There are professionals who can help you make a complete raw or home cooked diet. One of K9 Kitchen, in Canada. There is also an online site from UC Davis that can give complete recipes for normal and special needs diets for dogs. My diet is not an analyzed diet, it is simply a diet that has worked for my breed for all life stages. You can look at it too. http://personal.palouse.net/valeska/fresh-food-diet.htm I hope you, or others reading your post, will realize that making a complete diet to sustain a dog for a lifetime, is more complex than feeding just meat and vegetables.

      • Pacific Sun

        July 1, 2015 at 1:39 am

        This such a dilemna. Is it better to feed a commercial “complete and balanced” meal with side effects and the risk of recall, or a whole food diet that might not be perfect? I see (especially in your case per your website) where large dogs need the right mix to keep their bones strong, and for breeding purposes. But what about average household pets in general?

        One solution is “rotation” feeding. That way the pet gets a smattering of whole fresh foods with natural vitamins and minerals. Then back it up with a reliable, dependable commercial food, and alternate with RAW too. That way your pet is used to all formats of feeding, the pet’s enzymes are being replenished, and it will get a broad array of vitamins and minerals from different brands and formulas of commercial food.

  7. No Time to Waste! (Reminder!)

    June 27, 2015 at 1:05 pm

    Please circulate the Whitehouse.gov petition: 100,000 signatures are required by July 5, 2015. Click here – https://petitions.whitehouse.gov//petition/require-pet-food-manufacturers-disclose-quality-ingredients

    Should Pet Food manufacturers be required to disclose quality of ingredients?

    PF can be made from real food ingredients just like what you’d purchase in the grocery or it can be made from an inferior quality of ingredients known in the PF Industry as feed grade, pet grade, or inedible ingredients. The trouble is the consumer can’t tell the difference between food or feed grade. Yes, inedible ingredients are allowed in PF by the FDA! Including expired retail MEAT that isn’t even stripped of its packaging! Per FDA Compliance Policies MEAT is sourced from diseased, dead, or dying animals. Chemical or pesticide contaminated vegetables and fruits, and mycotoxin ridden grains, are used.

    If you agree that PF consumers deserve to know the difference before they buy, then the FDA must require the quality of ingredients to be labeled as feed or food grade.

    As of June 27 there are only 8 more days to sign the Whitehouse.gov petition and reach (at least) 5,000 signatures. We are at 3,400 today. Please circulate this reminder asking even more people to pass it forward! Thank you.

  8. Lisa

    June 30, 2015 at 11:31 am

    Merrick also has two mislabeled limited ingredient diet products on the market: canned cat food for cats, one duck pate and one turkey pate which state “single protein” on the front of both labels. The fourth ingredient, however, is “dried egg product”. After contacting Merrick via email and phone, they have confirmed that the dried egg product is chicken egg product, and not duck or turkey egg product, as I asked.

    They are not single protein foods.

    “We pawsitively regret this ‘error'”, was the email response I received; the products are “currently under review to make them single protein”.

    Who does quality control for Merrick’s labeling, Micky Mouse? A third grader reviewing her homework before submitting it would have noticed the problem.

    Some cats are allergic to both chicken and eggs, allergies go far beyond just being a little itchy, scratching themselves raw and breaking skin can lead to secondary infections, (my cat ended up with a staph infection before we realized he should avoid eggs, in addition to chicken, as his vet diagnosed).

    There are customers who won’t take the time to look at the ingredients on Merrick’s LID label; they will only notice e.g., ” duck pate recipe” and “single protein” on the front label.

    Come on FDA, at least pretend like you give a damn.

  9. Paula

    June 30, 2015 at 4:18 pm

    This is a great petition to sign since they are in the process of repealing the Country of Origin label on all meat and poultry. Whether you feed raw to your dog and roasting dinner for your family, don’t you want to know where it came from.

    https://secure.consumersunion.org/site/Advocacy?page=UserActionInactive&id=3035

    • Pacific Sun

      July 1, 2015 at 1:31 am

      Thank you for this heads up. Whether regulated or not any manufacturer can choose to identify where their produce comes from. In our State all the Produce is so labeled as well as the (formerly fresh) now frozen whole fish in the Fish Market. Please should only buy what they can identify. Soon the manufacturers will get the message.

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