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Pet Food Regulations

We Want More Bang for our Buck

It is estimated that cat and dog food/treats provides State Department of Agriculture with $33 million dollars a year in revenue. What are consumers getting in return for that revenue? Not much.

It is estimated that cat and dog food/treats provides State Department of Agriculture with $33 million dollars a year in revenue. What are consumers getting in return for that revenue? Not much.

Conservatively, there are 30,000 different pet food and treat products (cat and dog only) sold in the U.S. – this is not including bird, hamster, ferret, gerbil, fish foods. These 30,000 pet food and treat products provide an estimated $33 million revenue per year to 23 states that charge a per label registration fee to pet food. And that $33 million is – basically – paid by consumers in the final sales price of the product.

In New York and Maine, as example, each state’s Department of Agriculture earns an estimated $3,000,000.00 revenue a year (based on 30,000 pet foods/treats) charging a $100.00 registration fee per pet food product, per year.

Opposite of New York and Maine, New Mexico charges only $2.00 pet food/treat registration per year, providing the State Department of Agriculture of New Mexico with an estimated $60,000.00 a year income. In Nevada, there is no registration fee charged for any pet product.

With New York and Maine earning significantly more revenue from pet food/treats than New Mexico and Nevada, does this mean pet products are safer in New York or Maine?

No, they are not. The same pet foods/treats that sell in New York and Maine sell in New Mexico and Nevada. And remember, those registration fees are manufacturer expense which ends up added to the final cost of the pet food (which the consumer pays).

Overall, 23 State Department of Agriculture’s earn a conservative $33 million a year revenue on cat and dog food/treats alone. What are pet food consumers getting in return for this $33 million? What information does a pet food company disclose to the states during registration?

DeptofAgRevenue

AAFCO’s Business of Pet Food website tells manufacturers “The registration scheme involves a fee for each product, either annually or bi-annually, filling out an application with the company contact information, sending in a list of products to be registered and their labels. After review of the labels for format and content, they will either be approved or not. If you make the requested changes to the non-approved label, usually it will then be accepted. The label submitted to the regulator must be the same label that will be used in the marketplace.”

As you can see, State Department of Agriculture’s approve pet food labels for “format and content”. There is no mention of approving the pet food for ingredient content. To view an example application (New York’s), Click Here.

With pet food labels…each state duplicates the same label approval. New York Department of Agriculture approves an estimated 30,000 pet food/treat labels. In a different office – in a different state – the very same pet food labels go through the very same approval process. And this same pet food/treat label approval process is repeated in all the other states each year (excluding Nevada, this state requires no registration).

But what about the contents of the pet food, does $33 million dollars a year in registration fees provide the pet food consumer with any assurances to quality or safety of ingredients?

Many states – but not all – will randomly test pet foods each year. The most common testing performed is Guaranteed Analysis – testing to see if the pet food meets the protein, fat, fiber, and moisture content that is stated on the pet food label. In 2013, the Illinois Department of Agriculture (earning an estimated $2.7 million a year in registration fees) tested a variety pet foods finding “failed” results in 16 pet foods. (Not one of these pet foods were recalled even though the pet food label guarantee did not match test results – making the products mislabeled.)

I am told through industry insiders, that the testing performed by the states are very predictable, I am told that large manufacturers of pet food know the annual testing schedule of each state very well. Just as example (not actual information), New York will test for bacteria, guaranteed analysis and some mycotoxins in March and April each year – and only in March and April. The goal of the state is to get their annual duty of testing completed, then move on to other things. Big manufacturers of pet food that distribute to New York know the state’s testing schedule and I am told ‘clean up’ their pet foods during the testing time of year. (Large manufacturers of pet food have multiple plants that sell to specific regions of the country, allowing them to ‘clean up’ foods during the testing time of year.)

With inspections of pet food manufacturing plants, I am told in most all cases the state will give a 2 week or more advance notice an inspector will be coming to the plant – allowing the company to clean and prepare prior to inspection. I am told inspections with no advanced notice rarely – if ever – take place.

And with actual ingredients in pet food…It was brought to the attention of regulatory authorities by consumer advocates that the chicken/poultry ingredients used in pet food – the most commonly used ingredients of pet food – were NOT as the legal definition required them to be. At the August 2015 AAFCO (Association of American Feed Control Officials) meeting, a State Department of Agriculture investigation (at consumer advocate urging) discovered that the current definitions of various chicken/poultry pet food ingredients “did not reflect industry practice”. In other words, for probably decades -the pet food ingredients chicken/poultry meal and by-product meal have not met the legal definition required of them. The ingredient’s legal definition says one thing, what was/is being purchased by pet food was/is something different. And not one State Department of Agriculture knew what was actually included in these ingredients. Not one State Department of Agriculture ever investigated if pet food ingredient suppliers were abiding by the legal definitions.

What are pet food consumers getting for their $33 million paid to State Department of Agriculture(s)? A pet food label that is examined in each state, but each state ignores misleading images found on the products. A pet food label that does NOT tell the consumer if they are purchasing inedible feed grade pet food or edible food grade. A predictable basic testing schedule that many pet foods have learned to work around. Ingredients that each state had not a clue what was really in them.

And by the way, pet food consumers also provide U.S. states a conservative $1.15 billion dollars of sales tax revenue each year (an average of 5% sales tax on $23 billion in sales). We are getting short-changed. Pet food consumers deserve more bang for our buck.

 

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

What’s in Your Pet’s Food?
Is your dog or cat eating risk ingredients?  Chinese imports?  Petsumer Report tells the ‘rest of the story’ on over 3000 cat foods, dog foods,  and pet treats.  30 Day Satisfaction Guarantee. www.PetsumerReport.com


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The 2015 List

Susan’s List of trusted pet foods.  Click Here

 

Have you read Buyer Beware?  Click Here

Cooking for pets made easy, Dinner PAWsible

Find Healthy Pet Foods in Your Area Click Here

3 Comments

3 Comments

  1. Mikel

    August 24, 2015 at 7:22 pm

    Dang but common sense is cool. This is just the kind of meat and potatoes (and I don’t mean the latter in food) info we all can use to help guide our sceptical pet owner friends. These are also the kind of simple to understand numbers we can use in for online petition via Change.org and others.

    Many thanks
    MikeL

  2. Kathryn

    August 25, 2015 at 6:32 am

    just one more reason to purchase the ingredients for your pet foot at the same stores where you purchase for your family. Some state charge a ‘sales tax’ for food – some don’t. But for the states that charge the mfg. for label registration of dog/cat feed you won’t be feeding those corporate monsters

  3. Gina

    August 31, 2015 at 11:11 am

    Don’t forget to count the tonnage fees that some states collect on top of the label registrations. For instance, Alabama charges 25 cents per ton for all types of feed, including pet foods http://www.agi.alabama.gov/forms/feed-forms.

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Human Grade & Feed Grade
Do you know what the differences are between Feed Grade and Human Grade pet food? Click Here.

 

The Regulations
Pet Food is regulated by federal and state authorities. Unfortunately, authorities ignore many safety laws. Click Here to learn more about the failures of the U.S. pet food regulatory system.

 

The Many Styles of Pet Food
An overview of the categories, styles, legal requirements and recall data of commercial pet food in the U.S. Click Here.

 

The Ingredients
Did you know that all pet food ingredients have a separate definition than the same ingredient in human food? Click Here.

Click Here for definitions of animal protein ingredients.

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If your pet has become sick or has died you believe is linked to a pet food, it is important to report the issue to FDA and your State Department of Agriculture.

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