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The Biggest Change in Pet Food Since the Invention of Kibble

If FDA and AAFCO would abide by their own regulations, the biggest change in pet food since the invention of kibble would be a name change. It should be called Cat Feed and Dog Feed. The mission: a legal name change.

If FDA and AAFCO would abide by their own regulations, the biggest change in pet food since the invention of kibble would be a name change. It should be called Cat Feed and Dog Feed. The mission: a legal name change.

First, a couple of questions for you.

What do you understand to be the difference between an animal ‘food’ and an animal ‘feed’?

To your understanding, is there a quality difference between a ‘food’ and a ‘feed’? Is one perceived to be higher quality than the other?

The commercial products that pets consume are allowed to be called ‘food’, but they are not held to any regulatory ‘food’ requirement. They are allowed to be called ‘food’, but they are not required to be manufactured with ‘food’ ingredients, they are not manufactured in a ‘food’ facility, and they are not warehoused or transported as ‘food’ is legally required. The system is skewed and consumers are being misled.

The legal definition of food is: “articles used for food or drink for man or other animals”. However because federal and state regulatory authorities don’t enforce the legal requirements of ‘food’ for animals, the term ‘feed’ is applied to what animals consume.

Much of the waste from the production of human ‘food’ becomes animal ‘feed’. Some of this waste can be a good source of nutrition for pets (such as internal organs from healthy, slaughtered animals), but unfortunately some of the waste is hideous and the thought of any animal consuming it under any circumstance is absurd (such as euthanized, diseased animals rendered to become meat meal or animal fat). ‘Food’ is legally not allowed to contain any part of a euthanized animal, a diseased animal or an animal that was rejected by the USDA. ‘Feed’ is provided a loophole to utilize this waste through FDA Compliance Policies.

‘Food’ is held to a high standard for manufacturing, warehousing and transportation. ‘Feed’ (currently) has little to no legal standard for manufacturing, warehousing and transportation.

Even though pet food is allowed to be termed ‘food’ – the largest majority of commercial pet foods do not meet any of the legal requirements of food.

It should be termed pet feed. Cat Food should be changed to Cat Feed. Dog Food should be changed to Dog Feed. I will be making a formal request to FDA and to AAFCO to legally require the products that cats and dogs consume be termed in direct relation to what they are made from, and manufactured as – feed. Consumers deserve to understand what they are purchasing.

Significant. There are actual pet ‘foods’ out there – made using 100% ‘food’ ingredients and manufactured in certified ‘food’ facilities. In order for these companies to disclose to consumers they are using actual ‘food’ ingredients and that their products are made in an actual ‘food’ facility – these companies have been forced by State and Federal Authorities (under threats of their products being pulled from store shelves) to obtain a ‘Letter of No Objection’ from FDA.

What is a ‘Letter of No Objection’? It’s a letter that states the FDA does not object to these manufacturers calling their pet products what they actually are…food. State and Federal Authorities behind the scenes have harassed manufacturers of actual pet ‘foods’ – threatening to pull their products from store shelves – if they don’t provide FDA with a quality statement affidavit from each ingredient supplier and provide evidence the ‘food’ is manufactured in a certified ‘food’ facility. (The other pet ‘foods’ don’t have to do this.)

And the kicker…to my knowledge, there is no formal procedure established by FDA (provided to the public) for this Letter of No Objection. Without published formal procedure for the Letter of No Objection, at FDA’s discretion it can be approved or rejected – with no explanation.

So…State and Federal regulatory authorities allow a pet food to be called a food even though it doesn’t meet any legal requirement of a food while making actual pet foods jump through hoops that even a food for a human doesn’t have to provide.

And in the middle of this mess is consumers – who are being misled into believing the pretty images of grilled meats on the label of that cat or dog product is actually ‘food’. Right now – the very same ingredients (including waste ingredients not allowed in ‘food’) used in cattle feed, pig feed, horse feed, or poultry feed is being sold to consumers as pet ‘food’. ‘Food’ is implied everywhere with pet products, when very few actually contain one drop of ‘food’ as it is legally defined.

I have sent both FDA and AAFCO requests asking what the official procedure would be to legally change the name pet food (cat food, dog food) to pet feed (cat feed, dog feed). The exception would be those companies that have already proved to FDA or that can prove to FDA they are an actual ‘food’. The FDA has agreed to a face to face meeting at the upcoming AAFCO meetings in Sacramento, CA. regarding this issue. AAFCO President elect responded, but directed me to the Pet Food Committee; request was sent, no response yet.

Consumers deserve to know what they are buying – food or feed. Regulatory authorities need to take swift action to require the products designed for our pets are termed according to the standards of their ingredients and how they are manufactured.

Please provide your comments below – I will take your messages to FDA and AAFCO. Please post your comment to the food/feed name change. Tell authorities your understanding of ‘food’ and ‘feed’. Tell them your challenges when trying to find a safe ‘food’ for your pet. Tell them what you need from regulatory authorities to assure your pet’s food is safe. Hint: If you want these officials to read your message – be polite.

This is step one – telling regulatory authorities what consumers feel, and presenting them with their own regulations. Follow-up steps will be determined by their response.

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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19 Comments

19 Comments

  1. Christine

    July 14, 2014 at 3:21 pm

    Go Susan!

  2. Brenda

    July 14, 2014 at 3:52 pm

    Please attempt to guarantee that what is on the pet food/feed label is correct. Is it food or feed? And extend fairness to all producers of pet food. Specifically set pet food standards so that pet food may be called food and pet feed will be labeled feed.

    thank you

  3. karen

    July 14, 2014 at 4:24 pm

    yes, the time has come for a “name change”.
    i am all for it! the truth needs to come out!

  4. Joan Connorton

    July 14, 2014 at 5:08 pm

    I heartily endorse the proposed change to differentiate between pet food & pet feed. Everything is very vague when it comes to the FDA & the AAFCO & standards…but any rational person who cares about feeding his animal the best quality processed food available can tell you that dog ‘food’ sounds a whole lot more wholesome than dog ‘feed.’ ‘Food’ sounds like someone, anyone, somewhere, anywhere, at least looked at it, hopefully had some standards to fill before labeling it ‘food’…and that an animal can live a healthy life by eating …’food’. Ideally, I would like my companion’s food to be processed as carefully & hygienically as the food I buy for myself, and thus both would have the same label: FOOD.

  5. Wolf

    July 14, 2014 at 7:14 pm

    Labeling of pet food (or pet feed, as the case may be) would be tremendously helpful to consumers. Some consumers will continue to buy feed, some will choose food. But the choice should be informed and transparent. We should be aware of what we are purchasing. Labeling requirements would, in the ideal, be the same for those products meant for human consumption. Information should not be a dangerous commodity; if manufacturers are producing the quality products they claim, and delivering on the promises they advertise, there should be no problem at all. So why not put it all on the label, for us all to see? We are waiting. Impatiently.

  6. Ann *

    July 14, 2014 at 7:55 pm

    As the owner of a dog who almost died from eating the poisoned China chicken jerky “treats”, I go to great lengths now to ensure that the FOOD that I buy for my pets is just that – Food and not animal FEED. It would be invaluable for me in making my pet food selections to know more precisely what I am paying for. As it is now, I often have to contact the manufacturer of the product to clarify exactly what is in their product. In an attempt to avoid unwholesome or poisonous feed products, I am spending more money on the products than I did prior to my pet’s near fatal encounter with a “treat” that should never have been allowed on the store shelves.
    Enforcing the difference between pet food and pet feed is of vital importance to me and would be a big step forward in the transparency and truth in labeling that I had previously thought already existed. I have now become educated to the dangerous reality of what is going on with many pet feed manufacturers who are allowed to misrepresent what their feed actually contains. If they were required to call it feed and not food, that would be a big help in us consumers in knowing what they are selling to the public.

  7. Danelle Ericson

    July 14, 2014 at 8:28 pm

    As a pet parent to a dog who did die from the poisoned China chicken jerky, I also go to extraordinary lengths to make sure “anything” I purchase for my pets is FOOD, made in the USA and with “food” grade ingredients, human grade preferably. As everyone knows, this information is very difficult to obtain. So there are very few commercial products I can even think about purchasing. I feel this whole industry is a joke and cannot believe the FDA allows what is mostly “feed” to be labeled “food”. Why shouldn’t we be able to “know” what we are buying and feeding to our pets, who are members of our family? If I wouldn’t eat it, my dog will not eat it. Period. It is ridiculous the FDA makes companies that are trying to do the right thing by using quality items in their food/treats, jump through hoops to prove it but they just let all the other garbage food companies call items “food” when they are not. What Ann and Wolf said above, says the rest of what I would want to say. Thanks Susan, keep fighting for us please. You are very appreciated.

  8. Regina

    July 14, 2014 at 8:45 pm

    Wow. This is awesome. This, to me, seems like a no-brainer. Of course, we consumers are at the mercy of the “brains” that are able to sell us crap while making us think it’s good and healthy.

    I honestly don’t know how these people sleep at night, knowing that they are lying to consumers about the quality of what we are feeding our beloved furry family members.

    I really do hope this change from “food” to “feed” happens.

    Of course, being the cynic that I am, I just know they’ll use a font that makes the “e” look like “o” so they can continue to hoodwink ill-informed consumers.

  9. Kim Kalander

    July 14, 2014 at 9:27 pm

    Brilliant Susan!

    What a beautiful way to divide truly healthy pet food from lines containing ingredients that basically starve at a cellular level. Not to mention the cronic inflammation that leads to disease.

    I would like to see standardized testing required in order to use new ingedients. Yes, I am on a pea tear again. Manufactures have been using pea products for several years now with no legal definition and no official acceptance as a pet food ingredient. As a store owner I have witnessed a severe decline of success with grain free kibble due to the addition of legumes. A base line research for inflammation produced by pet food could also eliminate a multitude of illnesses that manifest years of suffering in pets. In other words if you could test a number of animals fed a corn based diet, you could rate the level of inflammation that food produces in the body. In contrast, you could then test food grade pet food and compare the difference. Inflammation leads to deterioration and then disease. It would also separate what feeds the body and what damages the body.

    Keep going!

    Kim

  10. dearcat

    July 14, 2014 at 10:34 pm

    Definately! As a mom to a Maine Coon, I am worried about what he is eating, especially now that he is 10. The huge corporations should be made to comply with pet food standards – food – not feed. Thank you for all you are doing on behalf of pets.
    sincerely,
    dearcat

  11. Dianne

    July 15, 2014 at 1:57 am

    So, if you produce feed, you are allowed to call it food. If you produce food, you have to prove it. What would happen if the people producing food, were to label it feed? Would they then have to get a letter from the FDA proving they are selling feed, not food? It would be an interesting experiment to see what would happen if food was labelled feed, since feed is labelled as food. If other labelling of ingredients is backwards, why not this?

    At some point it would have to be embarrassingly clear that the smaller manufacturers are being harassed and there is no way they can win the battle to sell their food. The situation is mind boggling.

  12. Elaine Ward

    July 15, 2014 at 8:41 am

    That’s why I make my own dog food.
    Please keep up the good work on behalf of our four legged friends.

  13. Andi Brown

    July 15, 2014 at 9:41 am

    This is a great change. People need to know that what they feed their pets may be keeping and making them sick. No matter what goes into commercial pet food/feed – by the time that it’s turned into dry food or kibble… there’s no real nutritional value in it. It’s why there is such a long list of isolated vitamins and minerals in the products. Thanks for doing such a great job with AAFCO and all that you do Susan!

  14. Nancy R

    July 15, 2014 at 12:03 pm

    I have owned many animals in my 65 years and some have been sickened by unsafe “Pet Food”. Little did I know, that, what I was feeding them was making them sick. Pet Food could be anything the manufacturer wanted to put into it, including diseased animals. Would your “food” be okay to eat if it was diseased? Please, we only want our pets healthy and happy. That will only happen if we know what we are feeding them. FOOD or FEED, will make it a world of difference.

  15. Amanda Bergeron

    July 15, 2014 at 1:56 pm

    I am not surprised, but I am still disgusted that any organisation responsible for the regulation of produce for ANY living mammal is so dishonest and intentionally allows misdirection by poor labelling standards.

    To say that these organisations have contributed to the ill-health of humans and companion pets is probably the harshest criticism I can level at them, but the lack of morality shocks me.

    Please take a step towards respectable business practices and ensure that produce is labelled correctly as to the content.

  16. Karen Granelli

    July 15, 2014 at 6:47 pm

    I fully support any efforts to require pet “feed/food” manufacturers & suppliers to be held accountable for the quality of the products they produce, including greater transparency regarding the level or grade (feed versus food) of ingredients & finished product. The current lack of FDA or INDUSTRY regulations are appalling & pets are continuously being harmed or put at risk of real harm due to this oversight. I sincerely hope the FDA is finally willing to begin treating the foods that we feed our pets as important in regards to safety regulations as the foods we humans consume. Otherwise…the pet food industry is going to continue to get a free pass to get over on consumers & put profit miles ahead of safety. In this regard…we are currently not much better than China, which is genuinely appalling in itself.

  17. Rose Sanchez

    July 25, 2014 at 6:18 pm

    As a consumer that is concerned about my pet’s health, I wish to see the following from pet food manufacturers:
    -No disease or euthanized animal parts or by-products can be used in food.
    -If labels say “Made in USA,” that means all ingredients and nothing sourced from China.
    -Clear definition, standards, and guidelines for certified facility and pet food label.
    -Pet food should held to higher standard than pet feed.
    -No toxic or controversial ingredients should be used in pet food or treats.
    -Use of holistic and safe alternatives for food preservation.
    -Accurate and clear ingredient listing.
    -Quick recall or safety protocol for deadly food and or pet treats.
    -Pet food manufacturers held accountable for sickness and deaths of pets.They advertise that pets are family members so they should held accountable for wrongful deaths.
    My dog just recently died on 7/2/2014, from acute kidney failure to to toxic ingredients in Ol’Roy Grilled Chicken Strips. I don’t want his death to be ignored by the pet food industry. I would like to see safer measures in place as soon as possible.

    • Will

      August 8, 2014 at 10:47 am

      Just curious – do you have definitive proof or test results indicating that what killed your dog came from the Ol’ Roy product? I have purchased Ol’ Roy (not the product you mention) in the past for my dog but only on a few occasions.. If you can prove what you say, you should consider a lawsuit or a demand from the company for some kind of fix.

  18. Sandy Murphey

    July 26, 2014 at 3:15 pm

    The following reflect my befliefs about pet food:
    Consumers need to be able to trust labeling, in order to choose what to feed their pets, in the same way they do to feed themselves.
    A legal name change makes fundamental sense as a step in choosing.

    “Consumers deserve to know what they are buying – food or feed. Regulatory authorities need to take swift action to require the products designed for our pets are termed according to the standards of their ingredients and how they are manufactured.”

    The lack of truth in labeling for both human and pet food consumption is leading to sickness and death that is preventable. We can only be responsible if we are informed. It’s your responsibility to monitor the ways we depend on to be informed.

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