Every ingredient in your pet’s food has gone through an approval process, every ingredient in your pet’s food has a specific-to-pet food legal definition. Such as, chicken in your food has a very different legal definition than chicken in pet food.
Since 2007, the FDA and the Association of American Feed Control Officials (AAFCO) have had a formal agreement to work together to approve animal food (pet food and livestock feed) ingredients. The original 2007 agreement – termed a Memorandum of Understanding – stated that FDA would provide “scientific and technical assistance” of new ingredients (to assure ingredients are safe for intended species) and AAFCO would wordsmith the legal definitions of ingredients, holding all ingredient definitions within their Official Publication.
The official agreement (memorandum of understanding) between FDA and AAFCO has continued for the past 17 years, but is set to expire on 10/1/2024. However, AAFCO documents tell us the ‘expiration’ is confirmed even months before the agreement officially expires.
The AAFCO Board of Directors have published two Resolutions, one states:
“the U.S. Food and Drug Administration’s Center for Veterinary Medicine will no longer act in partnership with AAFCO to provide scientific and technical assistance in the review of ingredient definition submissions for safety and utility nor discretionally accept the AAFCO Ingredient Definition Process.”
“the FDA’s Center for Veterinary Medicine will be utilizing a new process for ingredient review known as the Animal Food Ingredient Consultation Program.”
This tells us that FDA – without notifying the public – has changed everything about pet food/animal feed ingredients. FDA is stopping their participation with AAFCO for pet food/animal feed ingredients and suddenly (without notice) doing things their way.
But what is ‘their way’? We sent FDA Center for Veterinary Medicine the following questions:
When was this change developed by FDA?
How will the public provide input on new ingredients?
Why was this change implemented without notification to the public?
Please provide all details about the ‘Animal Food Ingredient Consultation Program’.
And the agency responded with:
“At this time, the FDA cannot provide any additional information. We look forward to sharing details with all stakeholders as soon as we are able.”
What? The FDA refuses to provide information on something that could dramatically affect pet food and animal feed? How can a federal agency dramatically change things in pet food/animal feed without public notice?
Unfortunately, it gets worse…
AAFCO published a second Resolution that appears to say AAFCO will continue to do what they have always done, ignoring what FDA has plans to implement. Quoting the second Resolution:
“AAFCO will continue to lead new ingredient definitions through the Ingredient Definitions Committee for membership approval with transparent dialogue.”
Let the mayhem begin.
FDA plans on approving pet food ingredients their way through a so-far secret Animal Food Ingredient Consultation Program and at the same time AAFCO plans on approving pet food ingredients the same way they always have, except without FDA scientific review. What?
AAFCO’s legal definitions of ingredients are adopted by some states into state law. So does this madness between FDA and AAFCO mean some US states will have different ingredient definitions than others? Will state laws differ from federal laws with pet food/animal food ingredients?
Or…is this whole issue the FDA quietly (behind closed doors) manipulating their system to exactly what their friends at the Pet Food Institute wants?
The Pet Food Institute – the trade association that represents Big Pet Feed – has pushed a bill in Congress that would, if passed, remove the regulation of pet food on a state level, the bill proposes that FDA have sole responsibility to regulate pet food. “No State or a political subdivision of a State may directly or indirectly establish, maintain, implement, or enforce any authority or requirement relating to the marketing or labeling of pet food.”
Other concerns of the Pet Food Institute proposed bill include:
- Pet foods will NOT be considered misbranded if the product does not contain an ingredient listed on the label – giving pet food legal permission to use whatever ingredients they choose.
- Claims of Hairball control, tartar control, or urinary health on pet food labels will NOT be considered misbranded – even if the claims are solely marketing (no scientific evidence the pet foods actually perform as the label claims).
And…the proposed Pet Food Institute bill gives FDA full authority to approve pet food ingredients; “Creating a more streamlined Federal regulatory process for new pet food ingredients…”
We have to wonder…has the FDA taken this action, anticipating the bill will not pass, providing their friends at the Pet Food Institute with EXACTLY what they wanted? ‘No worry friend, we’ll take care of it for you.’
We don’t know what is happening. But we do know that this situation has the potential to be a great big mess, with pets potentially paying a high price for the AAFCO/FDA drama (otherwise known as the FDA please our friends drama).
And we know that pet food/animal food ingredient approvals SHOULD NOT be something a federal agency does behind closed doors. This is a huge betrayal of pet food consumers by the FDA, this is not a secret they should keep to themselves.
Should you wish to provide FDA Center for Veterinary Medicine your opinion of the secret they are keeping from pet owners – you can email them at: AskCVM@fda.hhs.gov.
Wishing you and your pet(s) the best,
Susan Thixton
Pet Food Safety Advocate
TruthaboutPetFood.com
Association for Truth in Pet Food
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Tom Kirby
July 19, 2024 at 1:07 pm
I just emailed them. I’ll let you know if I receive a response. This reeks. The feds are eliminating oversite everywhere they can. Our government in the US does not serve the people who fund it. The idea that there are two political parties is a joke. The two parties are like the fake “good guys” and fake “bad guys” in a wrestling match. The real winner is whoever is getting paid at the door. The show on stage is just a distraction from what’s really going on behind the scenes. The real losers, in this case, will be our pets.
Tom Kirby
July 24, 2024 at 4:00 pm
This is the response I received:
Thank you for contacting FDA’s Center for Veterinary Medicine (CVM). Unfortunately, we do not know what you are referring to with your below comments. There have been no changes to how pet food is regulated. Additional information on how FDA regulates animal food can be found at: https://www.fda.gov/animal-veterinary/animal-food-feeds/pet-food.
Sincerely,
CVM Compliance
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I replied with the facts:
Hi “CVM Compliance,”
The document at the link below states that the agreement between FDA and AAFCO “will have an effective period of performance from date of signature until 10/01/2024”
https://www.fda.gov/about-fda/domestic-mous/mou-225-07-7001
The AAFCO resolution linked to below states “the U.S. Food and Drug Administration’s Center for Veterinary Medicine will no longer act in partnership with AAFCO to provide scientific and technical assistance in the review of ingredient definition submissions for safety and utility nor discretionally accept the AAFCO Ingredient Definition Process.” as well as “the FDA’s Center for Veterinary Medicine will be utilizing a new process for ingredient review known as the Animal Food Ingredient Consultation Program.”
https://www.aafco.org/wp-content/uploads/2024/07/AAFCO-Resolution_2024-001-AFIC.pdf
So I ask again: Why won’t you provide the oversight that the pet food industry so desperately needs? Why won’t you make sure that the FDA works to protect US citizens and their pets? As it stands now, it seems that the AAFCO is making the rules, not the FDA. I think that’s backwards, don’t you?
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I’ll post again if I get another response.
Susan Thixton
July 25, 2024 at 9:59 am
Thank you Tom for writing them!
Tom Kirby
August 8, 2024 at 9:00 pm
This is their second response, if you’d even call it that. They just shrugged me off.
Please see: https://www.fda.gov/animal-veterinary/cvm-updates/fda-releases-two-draft-guidances-seeks-public-comment-pre-market-animal-food-ingredient-review.
Christopher Norrell
July 19, 2024 at 1:58 pm
Sue them for breach of procedure for not giving public notice. The fda has been just doing whatever the hell the want for too long
T Allen
July 19, 2024 at 2:20 pm
Very, very sad for pet owners and discouraging for people who know how the GOV works (or doesn’t). It’s going to be safer to feed table scraps then commercial pet food. Hang in there Susan! All you can do is keep us informed like you always have. 🙂
Anna August
July 19, 2024 at 5:51 pm
ASSHOLES!!! I only feed my dog’s Hills Science Diet now.
Lorraine Sukeena
August 1, 2024 at 4:48 pm
Not good ingredients
Lorraine
July 19, 2024 at 2:37 pm
Only thing that will stop this is consumers pulling away from top dog/cat food companies. Maybe they will think it over if their sales drop drastically.
kruzingwithk9s
July 19, 2024 at 2:49 pm
Does that mean that even the dog foods on your list will not be safe? Thanks for all you do.
Susan Thixton
July 19, 2024 at 2:59 pm
I personally still trust the pet foods on my List. But I do not know what the future will bring with this issue. I see it more of a way for companies that use waste ingredients to be further allowed to deceive the public.
Barbara Fellnermayr
July 19, 2024 at 6:07 pm
This is so disheartening. I feel so bad for the beloved pets that will be eating garbage. I guess the big pet food companies found some of the magic grease, for the palms of FDA officials. They, and the bigwigs at the big pet foods companies, should be forced to eat this food.
Since we are in Canada we are not bound by this craziness. BTW, I’d eat any and all of the ingredients found in our food.
My company, Amore Pet Foods, is on Susan’s list. We have ALWAYS used 100% human grade ingredients and have provided Susan with verification. As long as I own the company that will continue. After all, MY furbaby has to eat our food! I’ve owned the company since 2005 and have now plans on making any changes.
This is exactly why good food costs more. We don’t act as a garbage disposal.
Carl Straw
July 30, 2024 at 2:55 pm
Have you considered the liability issue of having a non-regulatory, voluntary group, sometimes led by individuals that have retired from their role in states of FDA, overseeing ingredient safety?