Pet Food stands alone from all other consumed products, but not in a good way.
#5 Pet Food/animal feed is the ONLY consumable product where laws regulating that product are written by a private corporation.
The laws that regulate every consumable product – meat, vegetables, water, frozen dinners, snacks, supplements…everything that is sold in your grocery store – are created by government. The process of law writing starts with a ‘bill’ introduced into Congress, the bill is researched, discussed, debated, edited, and finally voted into law. The entire law writing process is public.
That is…the laws that regulate every consumable product are created this way…except pet food laws.
Pet food/animal feed laws are created behind closed doors ($500.00 admission per meeting) by a private organization – the Association of American Feed Control Officials (AAFCO) – in two pay-to-attend meetings each year. Per AAFCO’s 2016 Form 990 tax return, the organization earned $384,635.00 for hosting private law writing meetings.
While lawmakers in Congress are influenced by outside lobbyists representing industry and consumers, lobbyists are not allowed to directly participate in the law making process. To the contrary, lawmakers in AAFCO allow multiple industry representatives and a few consumer representatives to be “advisors” to committees. Selected individuals are provided the opportunity to directly participate on AAFCO committees (in some cases outside advisors directly oversee committee work). On all AAFCO committees, industry representatives greatly outnumber consumer representatives. With AAFCO’s Pet Food Committee, there are 14 industry advisors compared to only 3 consumer advisors. At AAFCO’s sole discretion, the private organization decides who is allowed to participate on committees and who is not.
This one-of-a-kind law writing system is allowed due to a special agreement between FDA and AAFCO. The agreement is known as a Memoradum of Understanding. Through the FDA and AAFCO agreement, AAFCO is provided with the legal responsibility of establishing Nutrient Profiles for all cat and dog foods, the legal requirements for feeding trials, establishing labeling laws, and all of the legal definitions of pet food ingredients. Which leads to the next unique issue that happens ONLY in pet food…
#4 Pet Food/animal feed is the ONLY consumable product where laws are privately owned.
The laws and legal definitions of every consumable product in the U.S. are public information – free for any consumer to read. Any consumer with access to the Internet can read food laws and food ingredient legal definitions in full detail.
With the sole exception of pet food laws.
The same Memorandum of Understanding agreement between FDA and AAFCO that gives law writing privileges to a private organization also allows that organization (AAFCO) to own and sell pet food regulations and legal definitions of ingredients.
AAFCO charges $120.00 per year for pet owners, industry representatives, and even government representatives to read the nutritional requirements of pet food, labeling requirements of pet food and the legal definitions of pet food ingredients. Per AAFCO’s 2016 Form 990 tax return, the organization made $413,978.00 in sales of pet food law. (To view more AAFCO tax information, Click Here. Under “Notable Sources of Revenue” the income stated for “Program Services” is from meetings and sales of laws.)
Without pet owners having public access to pet food regulations and definitions of ingredients, they are denied the opportunity to understand what they are feeding their pet.
#3 Pet Food is the ONLY consumable product where labels are openly allowed to deceive the purchaser.
Human foods are subject to the Fair Packaging and Labeling Act which forbids consumer deception on labels. But once again, not with pet food.
This TV dinner is required by federal law to contain fried chicken because fried chicken is pictured on the label.
But, because no pet food regulatory authority enforces labeling laws – pet foods can display grilled chicken (or steak or prime cuts of meat) on the label when it contains NO grilled chicken (or steak or prime cuts of meat).
This is a significant ‘misrepresentation’ of pet food, misleading millions of pet owners daily.
#2 (Most) Pet Food is the ONLY consumable product that is not actually food.
In no uncertain terms, Federal law considers dog and cat food to be ‘food’.
But…each U.S. state ignores federal law and defines pet foods as “feed” (instead of ‘food’). Providing just a few examples…
All across the U.S., each pet product label declares it to be FOOD – Dog Food and Cat Food – when each of those products are not food – not held to food laws (only a tiny portion are actually food*). While all other products regulated as a “commercial feed” (also using the very same ingredients as used in pet products) transparently term the product as feed – Chicken Feed, Cattle Feed, pet products mislead pet owners being labeled as ‘food’.
*The exception is pet products that are also labeled as “Human Grade”. Human Grade pet products ARE food, meeting every legal requirement of food.
By each state classifying pet ‘foods’ as ‘feed’ – this results in all pet products being regulated as feed, allowing food laws to be ignored. Feed laws are significantly less in quality standards, safety standards and manufacturing standards than food laws.
Which leads to the biggest ONLY in pet food…
#1 Pet Food is the ONLY consumable product openly allowed to violate federal and state law.
Federal law defines an adulterated (illegal) food as (in part):
Many states (Alabama, Connecticut, Florida, Idaho, Indiana, Kansas, Kentucky, Michigan, Minnesota, Missouri, Montana, New Mexico, and North Dakota) have Commercial Feed laws that also declare a commercial feed (including pet foods) to be adulterated if it contains ‘in whole or in part a diseased animal or an animal which has died otherwise than by slaughter’.
But…FDA openly ignores the above federal law and each U.S. state openly ignores their own laws and/or federal laws directly because FDA specifically states diseased animals and non-slaughtered animals are “fit for animal (your pet’s) consumption“.
The above policy is word for word OPPOSITE of federal law (quoted above). The FDA defiantly ignores the very laws they are charged with enforcing in pet food. All U.S. states follow this FDA illegal policy.
All of the above – #1 through #5 – ONLY happens in pet food. No other consumable product allows a private organization to write and own the laws regulating it, no other consumable product is openly allowed to mislead consumers, and no other consumable product labeled as food is actually something very different (feed) and is allowed to violate federal laws.
Angry? Write your state’s Attorney General and demand an investigation into how pet products are regulated in your state. Pet products that are feed should be labeled as feed; Cat Feed, Dog Feed. Pet products that meet the requirements of food law should be the ONLY allowed to be termed Cat Food and Dog Food. Federal law deems a food adulterated that contains a diseased animal or non-slaughtered animal – all pet food should abide by those laws. Pet ‘food’ labels should not mislead pet owners, and all regulations and ingredient definitions should be public information.
Wishing you and your pet(s) the best,
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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