In a recent press release, Mars Petcare announced a new pet food that included a “Human Grade” claim on the label.
The new “Fresh Chef” line of dog foods from Mars Cesar is a refrigerated pet food, available in a roll, that looks remarkably similar to Freshpet dog food.
The marketing images of the two pet foods even included the same white marble background, with food ingredients scattered around and the same cut slices of dog food. BUT…there is one big difference between the pet foods. The Mars Petcare Cesar dog food has a “Human Grade” claim on their label:
Is Mars Petcare making a human grade pet food?
The legal requirements of human grade pet food (see page 10) are very clear. All ingredients (food ingredients and supplements) are required to be human edible, and all manufacturing conditions have to meet human food standards.
Regulations on the claim include a guidance document (see page 5) to clarify the requirements for pet food manufacturers. The document states:
“In the definition, the term “human grade” is false and misleading if the product
as a whole is not human edible. “Human grade” claims may not be made for
individual ingredients in a finished product that does not fully adhere to the
manufacturing and ingredient specifications identified above.”
In other words, regulations consider it false and misleading for a pet food company to make a claim of human grade ingredients (even if it is true) – unless the pet food is also made in a licensed human food facility. Pet food companies are held to an ‘all or nothing’ standard; pet foods must meet all of the legal requirements to make a Human Grade claim, or they cannot make the claim anywhere (label or website).
So, to determine if the Mars Petcare Cesar pet food was potentially misleading pet owners, I asked the company a few questions. Below is the transcript of a chat I had with Mars Petcare Cesar (12/6/21). I gave them my real name and my real email address.
Me: “Hi Ashton – the new Cesar Fresh Chef product – is that a human grade pet food?”
Mars Petcare Cesar: “We can assure you that our animal proteins and ingredients are derived from animals intended for human consumption. For a manufactured pet food, both the individual ingredients and the final product must comply with these standards.
Pet foods have their own set of strict standards and regulations as to what makes a nutritious, balanced meal and what does not. Here at Mars Petcare, we complete over 300 of our own quality checks to ensure that we aren’t giving anything to your pets that we wouldn’t give to our own.”
Me: “Are the foods manufactured in a human food facility or pet food facility?”
Mars Petcare Cesar: “They are manufactured in USDA inspected facilities.”
Me: “A USDA inspected facility – under USDA inspection? Such as what is required of human food?”
Mars Petcare Cesar: “Happy to circle back with you! Any other questions?”
Me: “Yes – my previous question. Are the foods made under USDA inspection?”
Mars Petcare Cesar: “Sounds great. Is susan@truthaboutpetfood.com your correct email?”
Me: “Yes. Does this mean you will email the response to my question?”
Mars Petcare Cesar: “Yes, I will get back to you after connecting with our internal team to verify.”
Trouble is…Mars Petcare Cesar did not answer my question via email.
This was a potential troubling question to Mars. If by chance the pet food is not manufactured in a licensed human food facility as is required to make the label claim of Human Grade, and they admitted that to me – they would be admitting to “false and misleading” labeling.
Does the Mars Petcare Cesar dog food meet the requirements to use the term Human Grade on the label or website? Or are they using the term in a “false and misleading” manner according to the legal guidance?
Because Mars Petcare Cesar did not fully respond to my questions, we don’t know if this dog food meets the requirements to use the term Human Grade on their label and website. Because Mars Petcare Cesar didn’t respond, the label was reported to regulatory authorities for their investigation.
How to protect yourself and your pet from false and misleading Human Grade claims.
Unfortunately for pet owners, because regulatory authorities rarely enforce labeling laws more and more companies are misleading pet owners with claims of Human Grade. Which means pet owners need to be fully aware of the laws in order to determine if a brand is misleading you or abiding by law.
With the human grade claim –
- If the words “Human Grade” (or similar) are used anywhere on the label or on the website, the pet food must use 100% human edible ingredients and supplements, and must be manufactured in a licensed human food facility.
- The legal guidance document for Human Grade pet food clearly states the pet food as a whole has to meet all the human grade requirements, the term cannot be used to reference individual ingredients.
- The legal guidance document states the labeling requirements for Human Grade claims include marketing and/or website claims, “brochures, point of sale materials, websites, etc.”
Here is the legal definition of Human Grade pet food:
“Every ingredient and the resulting product are stored, handled, processed, and transported in a manner that is consistent and compliant with regulations for current good manufacturing practices (cGMPs) for human edible foods as specified in 21 CFR Part 117.” Link to AAFCO document (page 10): https://truthaboutpetfood.com/wp-content/uploads/2021/12/Ingredient_Definitions_Minutes_2016_Midyear_Isle_of_Palms.pdf
Here is the link to the AAFCO guidance document for the Human Grade claim (see page 5): https://truthaboutpetfood.com/wp-content/uploads/2021/12/Pet_Food_Report_20160317_emeeting.pdf
Ask the pet food manufacturer:
- Are all ingredients human edible?
- Are all supplements human edible?
- Are the pet foods manufactured in a licensed human food facility under USDA inspection?
If you find a pet food label or website that is making Human Grade claims, but do not meet the legal requirements – report that pet food company to your State Department of Agriculture and the FDA (AskCVM@fda.hhs.gov). Maybe, with consumer complaints regulatory will begin to enforce Human Grade labeling laws.
Wishing you and your pet(s) the best,
Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
TruthaboutPetFood.com
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Brenda
December 7, 2021 at 10:59 am
This is so disturbing and unsurprising to me. These big food companies don’t really care because they are able to get away with so much falsity. I thank you Susan that there is someone like yourself to oversee these issues. I love how you make it very clear down to showing the products side by side like that. It’s disgusting that the Mars company is able to practically copy the marketing photo of the other food company. I’m grateful for your diligent and hard work to reveal the truth behind our precious family members’ food quality!!!
Love,
Brenda, Phoebe, Tito, and Chewy
Amy Renz
December 7, 2021 at 12:35 pm
Hi Susan,
Thank you for your investigation and alert. I am curious if the regulatory authorities in any state could validate this claim by Mars Petcare. Has, for instance, the NYS Department of Agriculture and Markets, or the Office of Texas State Chemist, or the NH Department of Agriculture reviewed the documentation Mars would needed to have filed to get this label claim approved so that the product could be sold in their respective states? If not, then perhaps those authorities could help protect consumers from potentially misleading claims.
Susan Thixton
December 7, 2021 at 1:14 pm
State authorities should validate the claim – as most states require labels to be submitted to them. The trouble is will they?
T Allen
December 7, 2021 at 1:08 pm
Unfortunately in this case it does not say it is “human grade” on the label. It says “made with human grade ingredients”. Big difference legally. Knowing how the manufacturing plants work I wouldn’t want to eat it or feed it. I’d also be willing to bet the “supplements” are NOT human grade and of course the meat likely isn’t either. Mars is taking a big chance legally on this one. The reps answer, “We can assure you that our animal proteins and ingredients are DERIVED from animals intended for human consumption.” is very telling as well. All that means is there is no dog, cat or roadkill in the product. It doesn’t say that the animals passed USDA inspection before becoming pet food never mind being processed under USDA inspection. Every word and phrase has a meaning in the regulations and if they don’t match exactly then you can assume someone is trying to avoid something. Mars has an army of attorneys and I can guarantee you they think this is iron clad. Time to tighten the regulations! Thanks Susan!
Jane Eagle
December 7, 2021 at 3:43 pm
It may be time to complain to the USDA that this human grade food is making us low-income humans who eat it, sick…
Francine
December 8, 2021 at 4:09 am
It’s gross but so not-surprising, given that this is a US company.
This is what they do – where all the resources, and energy, goes: deceit and covering themselves (for whatever BS they are hawking that day).
Which is why the whole place is tanking.
With this ‘prize’ as “leadership” of this particular sales & marking dumpster fire:
<>
https://www.avma.org/javma-news/2018-12-01/corporatization-veterinary-medicine
Though it pales in comparison to what US pet food companies have done to pets, it is also very depressing to visualize all of these kids — all of the “Austins” — being trained to bullshit people all day long – that is what they learn how to do – nothing else.
Since education – any kind, any area – sux here too.
Other than the “education” they get in how to lie and bullshit people all day long for $$.
Concerned
December 8, 2021 at 9:21 am
Mars to take controlling stake in Vetsource
Clinic pharmacy service is second to be absorbed by a multinational in two years
May 17, 2021 (published)
By Lisa Wogan
[Vetsource email]
Vetsource told its veterinary clients by email on Friday that Mars Petcare is becoming its “lead investor.” The move gives the world’s largest owner of veterinary clinics a controlling interest in a company that had been perceived as a supporter of independent practices.
Mars Inc., the biggest veterinary company in the world, has acquired a controlling interest in Vetsource, an online pharmacy, prescription management and analytics business with more than 9,000 clinic customers.
Concerned
December 8, 2021 at 9:32 am
Corporate Takeover on NPR (audio)
https://www.npr.org/2021/06/22/1009137378/the-vet-clinic-chow-down
Amee R.
December 8, 2021 at 12:26 pm
Most insightful phone transcript I’ve read this year. Seeing the actual words that were (and were not) used is important and telling. When you asked specifically, and your question was… flatly ignored and sidestepped, I gasped. It’s truly chilling. Some people would have become uncomfortable and not pressed further. Can you imagine the gall of leaving a customer with that deceitful impression?
MARS, and others, no doubt will label for our money first and, only after their (expected and assumed) non-compliance with their own “laws” are pointed out (by how many people?), will anything change.
Mars Petfood can certainly afford to make and sell Human Grade the *right way*, but that isn’t possible if they use any of their old methods. I happily invite them to enter the Human Grade pet food market! However, to get our money they have to do things completely separate and apart from what they’re doing everywhere else right now. Because that’s the legal way to do it.
Don’t they have to register their USDA manufacturing facilities? So they’ll have both Feed Facility’s AND Human Food facility’s… Right? And surely you can’t transport human/feed ingredients commingled in the same trucks until it’s a final product. I think Imah call and ask. (¬‿¬)
Harry
December 10, 2021 at 12:59 pm
Someone asked on their Facebook page and it says it’s an FDA and USDA facility and manufactured and stored to human food standards.
Susan Thixton
December 10, 2021 at 1:03 pm
I’m waiting for their response – but I asked for clarification if the pet food is actually made under USDA inspection or if it is made after hours (after the USDA inspector has left the facility). Some pet foods are made at USDA plants, but they are made in off hours which does not meet the legal standards for human grade. When/if they respond – I’ll share that with pet owners.