Have you ever wondered why AAFCO has to define pet food ingredients? As example, chicken is already legally defined through the Poultry Products Inspection Act. So why would the chicken used in pet food require another definition?
The answer: because pet food chicken is held to a completely different standard than the chicken consumers are familiar with. The commonly known chicken is required to meet the legal standards of the Poultry Products Inspection Act, but the chicken used in (most) pet foods is NOT required to meet the legal standards of the Poultry Products Inspection Act (the exception would be human grade pet foods). To the confusion of millions of pet food consumers, both chicken ingredients have the exact same name even though they are held to two very different standards. Legally speaking, pet food chicken is a nonstandardized food (it does not meet the ‘standard’ of food chicken).
But, federal law takes into consideration this confusion caused by two very different ingredients of the same name. In fact, federal law – specific to animal food – requires the confusion to be addressed in the ingredient name.
Title 21, Chapter I, Subpart E, Part 502 Common or Usual Names for Nonstandardized Animal Foods states (bold added for emphasis):
“General Principles (a) The common or usual name of a food, which may be a coined term, shall accurately identify or describe, in as simple and direct terms as possible, the basic nature of the food or its characterizing properties or ingredients. The name shall be uniform among all identical or similar products and may not be confusingly similar to the name of any other food that is not reasonably encompassed within the same name. Each class or subclass of food shall be given its own common or usual name that states, in clear terms, what it is in a way that distinguishes it from different foods.”
There couldn’t be much more “confusingly similar” names than nonstandardized ingredients of pet food that have the EXACT SAME name as standard ingredients of food. The pet food ingredients chicken, beef, lamb, turkey, corn, peas, and on and on have a common name that is ‘confusingly similar’ (actually it’s identical) to standardized foods.
Most pet food ingredients are feed grade, a “subclass” of food. Law clearly requires that any “subclass of food shall be given its own common or usual name…that distinguishes it from different foods.” There is no doubt about it – feed grade ingredients are a subclass of food and they are required to be given a different name.
So…(here is where we need your support)…
Based on this law (and a few others) we have submitted an official request to the FDA to amend current pet food ingredient names. Based on the legal requirements within animal food law, we have requested FDA to require pet food label disclosure of the subclass ingredients feed grade.
The official request sent to FDA is termed a “Citizen Petition”, a process where individuals or organizations can make requests to FDA for changes in policy. Citizen Petitions submitted to FDA are posted on the government website Regulations.gov and are open for public comment. FDA is required by law to respond within 150 days (though they commonly ignore this legal deadline).
Our Citizen Petition can be read here. We make several legal arguments, proving to FDA that law requires the label disclosure of feed grade ingredients. As required, our Citizen Petition explains what we are requesting in Section A. We included in Section A existing laws and proposed laws that would make it clear to industry the feed grade disclosure requirements. Section B of our petition includes the grounds for our request, where we quote numerous sections of law evidencing feed grade is required to be disclosed on the pet food label.
Your part…Submit a Comment!
It is significantly important for FDA to see that pet food consumers support this change. As well, it is significantly important for FDA to see that pet foods using human grade ingredients support this change. And it is simple to show your support.
Our Citizen Petition is posted on the government website Regulations.gov. Click on the blue “Comment” box. You can include your name or you can remain anonymous. Added after original posting: Under the section “What is Your Comment About?” there is a drop down menu to choose a category, select the category “Individual Consumer“.
Please share the Petition with every pet owner you know and ask them to post a comment. Your comment can be as simple as ‘I support this petition’ to as detailed as you’d like to make it. Feel free to tell the FDA why you believe label disclosure of feed grade ingredients is necessary.
Everyone (but the pet feed industry) benefits.
These sweeping changes to pet food labeling will benefit millions of pet owners. After decades of pet food label deception, if FDA implements these changes as law requires, pet owners would finally know if they are purchasing pet food or pet feed.
We suspect the pet feed industry won’t be too happy about our Citizen Petition. We suspect they will be lobbying their members of Congress urging them to influence the FDA to ignore these legal requirements. To battle their lobbying efforts, we ask pet owners to share the Petition with their members of Congress too.
Send your Senate and House Representatives in Congress a message stating you are in support of Citizen Petition FDA-2022-P-1643-0001. Ask your Representative to urge the FDA to amend the common names of pet food ingredients disclosing the subclass feed grade as animal food law requires.
Wishing you and your pet the best –
Susan Thixton
Pet Food Safety Advocate
TruthaboutPetFood.com
Association for Truth in Pet Food
Become a member of our pet food consumer Association. Association for Truth in Pet Food is a a stakeholder organization representing the voice of pet food consumers at AAFCO and with FDA. Your membership helps representatives attend meetings and voice consumer concerns with regulatory authorities. Click Here to learn more.
What’s in Your Pet’s Food?
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The 2022 List
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Terri Nichols
July 25, 2022 at 1:47 pm
I support this petition. It is imperative that we label pet food with the same rules as human food. Why wouldn’t I want to know what I am really feeding my pet?
Christine
July 25, 2022 at 10:00 pm
Transparency within the pet food industry is imperative. I support this petition. I want to know what goes into my pets’ food!
Annette Mello
July 26, 2022 at 12:46 pm
this is what i put in the comment:
Citizen Petition FDA-2022-P-1643-0001
I urge the FDA to amend the common names of pet food ingredients disclosing the subclass feed grade as animal food law requires. Determining which cat pet food is best for my feline family is important to me and nearly impossible to do now.
Law requires the label disclosure of feed grade ingredients. As required, Citizen Petition explains what is being requested in Section A. Included in Section A are existing laws and proposed laws that would make it clear to industry the feed grade disclosure requirements. Section B of the petition includes the grounds for this request, and quotes numerous sections of law evidencing feed grade is required to be disclosed on the pet food label.
Ellen
July 25, 2022 at 2:03 pm
I want to know what’s in the food I feed my animals. they are mammals just like we are & need to have good clean food, so they don’t get sick
Phyllis Ball
July 25, 2022 at 2:48 pm
What is the appropriate Category to choose for a comment? Animal Feed Industry?
Susan Thixton
July 25, 2022 at 2:50 pm
There is a category for “Individual Consumer” – select that one. Thank you!
Alice Marino
July 25, 2022 at 2:56 pm
Item and as a consumer to know exactly what is and is not in my pets food!
Jynn
July 25, 2022 at 3:31 pm
Susan, what category do we click in the “What is your comment about?” section? Animal Feed Industry? Food Industry? Other government? Thanks in advanced!
Susan Thixton
July 25, 2022 at 3:34 pm
Choose “Individual Consumer” in the drop down menu. Thank you!
Lise
July 25, 2022 at 3:36 pm
Done. Added my comment. Please, everyone, pass this along.
Thank you, again, Susan for all you are trying to do. Never, never give up!
Beth Marousek
July 25, 2022 at 3:50 pm
I used your link and before writing a comment I reviewed the “Commenter’s Checklist”. Their list is somewhat daunting, but I hope readers will make their best effort to write a personal comment. We have a chance to make the FDA work FOR US!
rain
July 25, 2022 at 3:51 pm
most pet food is total garbage causing a variety of illnesses. they deserve better and for the cost the consumer does too
Jim Fiorillo
July 25, 2022 at 4:40 pm
I am more than tired of the influence that Pet Food Manufactures have directly and through “AAFCO” on the FDA regulations for their safety, quality and recalls. FDA should be a Federal regulatory agency, not a subsidiary of the Pet Food Manufacturers Association. Their primary statutory authority is to protect consumers and their pets against the use of ingredients that are neither wholesome nor nutritious and often outright harmful (as in the case of artificial flavors and artificial colors) to our pets. I spent THOUSANDS of DOLLARS ANNUALLY feeding my pets (I’m currently buying about three hundred 24-can cases per year of pet food that costs about $2.00 per can which totals around $4800 per year for my 7 cats) and have receive absolutely no protection from FDA or CVM on the ingredients used in the manufacture of this feed (labelled erroneously as “food). Why doesn’t the FDA pay more concern to the legislative intent of their principle charter and less attention to the needs of the industry lobbyists? IMHO, the FDA has been corrupted by the industry they are designed to regulate and are placing their concerns in a status of higher regard than the comments of consumers like myself or the pets we feed using the commercial pet “food” that this industry manufactures. In many instances, the regulations regarding pet safety are either secondary to the profit priorities of the manufacturers or in complete disregard. Please pay attention to the health need of my cats more than the profit needs of the corporations you so enthusiastically serve through your back-door and often non-public associations.
Lisa Powers
July 25, 2022 at 7:02 pm
It is shocking to see what pet food manufacturers are permitted to list in the ingredients labels: “Meat and meat by-products”??? Such as what? If a pet needs to eat a specific isolated protein for dietary issues, it’s impossible to make an informed choice of pet food. Pet foods must be properly identified and labelled.
Vanita Calvio
July 25, 2022 at 7:03 pm
It is extremely important that there is full disclosure about what we feed our pets. They are our an integral part of our lives and their health is as important as ours. They deserve the absolute best and do not deserve to consume garbage. There should be no difference in the information on the labels on their food and ours.
maica
July 25, 2022 at 8:27 pm
Done!! thank you
Sharon Oh & TheTucsonTrio
July 26, 2022 at 10:13 am
Completed comment and sent. Thanks for keeping us informed.
GRETCHEN
July 27, 2022 at 9:32 am
We need more transparency with how the food is made and what the ingredients mean. I have switched my cats to so many foods because of intolerances or suspected allergies. It’s frustrating because there are no standards and what we think is healthy is actually slowly poisoning our animals.
Francine
August 8, 2022 at 8:43 pm
“The document or docket you are looking for was not found.” (8-8, 8p)
Never ceases to amaze (the level…).
Susan Thixton
August 9, 2022 at 9:09 am
Here is the direct link to the document on Regulations.gov: https://www.regulations.gov/document/FDA-2022-P-1643-0001
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Lyn Murray
August 10, 2022 at 3:33 pm
I support this petition. It is past time manufacturers of cat food (and dog food, also!) listed all the ingredients i a manner we may actually understand, and also that they stop using feed-grade meats.
We have used Fancy Feast for our stray cat colony, and even the strays have recently (in last 3/4 months) begun to reject certain flavors. First they rejected the chicken, now they are rejecting the beef variety (we generally purchase the beef/poultry 30 can box). But if even STRAY cats, who are hungry all the time, are rejecting this food, that tells me the meats used are ROTTEN or Worse, full of medications/pesticides, etc.
I know this has been standard practice for many, many years, but, now because we are getting better information (thank you Truth About Pet Food), and learning the truth about manufacturers’ practices, it is imperative manufacturers MUST stop the practice of using diseased, rotten, medication-filled carcasses to feed our pets immediately! Bad food is causing illness, longterm health issues and even death of our pets!
Attention Pet Food Manufacturers: STOP this disgusting practice of using diseased, deceased and rotting animal carcasses in the processing of ALL pet foods! Your practices are injurious to our pets!