Background: A veterinarian friend asked me if lot numbers and ‘Best by’ dates were required to be included on pet food labels. She has a client whose pet is sick believed to be linked to a pet food, was reporting the pet food to FDA – but the product label did not include lot number or ‘Best by’ information. I felt confident this was required information, but I was wrong. When I did some homework, I was shocked.
A page on the FDA website for pet owners, titled “Save Your Pet Food Lot Number!” explains why pet owners need to save/be aware of the lot number on their pet’s food label. The FDA gives the example of a pet food recall:
“The lot number is a crucial piece of information when you’re trying to identify if a product has been recalled or if you’re reporting a potential product problem to FDA or the company. The lot number helps identify a specific batch of pet food or treats. A pet food company may make a specific pet food in several plants in the United States. The lot number identifies when the product was made and the manufacturing plant, so problems can be quickly addressed.”
But…
This “crucial piece of information” is NOT legally required by FDA or AAFCO to be included on pet food labels.
Companies voluntarily include lot number identification on labels, perhaps more for their own protection than ours. The FDA also states the lot number “also allows a pet food company to quickly pull or recall a specific batch without having to recall all batches from store shelves.”
There are traceability laws that pet food manufacturers are required to meet, such as each pet food manufacturer is required to provide FDA will full details tracing where each lot of pet food was distributed to, and full details tracing each ingredient in each lot should a problem arise with the pet food. But, for pet owner traceability – lot number identification is not legally required.
Another piece of information that is crucial for pet owners is the ‘Best by’ date on pet food labels. The FDA provides this information about Best by dates on pet food labels: “Best By,” “Use By,” “Use Before,” or “Sell By” Dates—Each of these dates, determined by the company, indicates when a product’s quality starts to decrease. For example, the product’s flavor or color may degrade after these dates. Some pet food companies may use these dates, in conjunction with lot numbers, to help identify product batches.”
Key wording (of concern) in this FDA explanation is “Each of these dates, determined by the company…” In other words, the ‘Best by’ dates on pet food labels are not legally required AND are completely determined at the manufacturer’s discretion. No regulations require scientific foundation for the ‘Best by’ date, it could be randomly chosen by the manufacturer.
This is a significant failure in pet food regulations. To help protect our pets, Federal laws and AAFCO regulations should require pet food manufacturers to include lot number identification, and should require ‘Best by’ dates to be required on labels with the date based on scientific evidence of nutrient value.
We intend to submit a request to FDA and AAFCO for these “crucial” pieces of information to be legally required.
In the meantime, if your pet food’s label does not include this information – ask your manufacturer to add it to the label. As well, ask your pet food manufacturer how they determined the ‘Best by’ date.
Susan Thixton
Pet Food Consumer Advocate
TruthaboutPetFood.com
Association for Truth in Pet Food
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