Who decides what ingredients are used in pet food? You aren’t going to like the answer.
One of you great pet owners sent me the question ‘who decided that peas, chickpeas, and lentils were good for dogs in pet food?’ Great question.
The answer: Industry.
The legal requirements of pet food is: no ingredient can be used in any pet food until the ingredient is defined by AAFCO (Association of American Feed Control Officials). The legally required process is:
- proposed ingredient is submitted to AAFCO Ingredient Definitions Committee typically through a trade association;
- proposed ingredient definition is discussed at an AAFCO meeting – sometimes multiple times at multiple meetings – attendees are welcome to comment pros or cons on the ingredient;
- after all discussion, ingredient definition is approved or denied;
- approved ingredient is added to the AAFCO Official Publication (book of regulations and definitions) most often as “tentative” (allowed to be used in pet food as tentative);
- at follow-up meetings ingredient definition will be approved as official.
Notice in the above, there is no legal requirement for scientific evidence to prove ingredient safety. In fact, often regulatory authorities simply ignore risk.
Example: In August of 2014 the feed ingredient “Zinc Hydroxychloride” was submitted to AAFCO for approval. The ingredient was approved even though 3 veterinarians spoke out against it (Dr. Jean Hofve, Dr. Cathy Alinovi, Dr. Oscar Chavez). Below is a screen shot copy of a segment of the minutes of this meeting approving this ingredient:
Three veterinarians expressed concern and FDA couldn’t respond to the effects of heat on the ingredient…but it still was approved as a feed ingredient. (On a side note, AAFCO has stopped including audience comment in their minutes of meetings. Unless you are at the meetings – which cost $550.00 each to attend – no one knows opposing discussion on any ingredient.)
Back to this pet owner’s question – ‘who decided that peas, chickpeas, and lentils were good for dogs in pet food?’ The answer for these ingredients is solely industry.
Years before the ingredient was legal to use in pet food – manufacturers used the ingredient without caution. In fact, the entire “Grain-Free” pet food segment was built on illegal use of the ingredients pea protein, pea fiber, and pea starch.
The legal definitions of pea fiber, pea protein, and pea flour were “Proposed in 2015” and “Adopted in 2016“. This means that legally – no pea fiber, pea protein or pea flour ingredient should have been used in ANY pet food until 2016. But that’s not what happened. Thanks to the WayBack Machine…
In 2008, Purina ProPlan used the ingredient “pea fiber” in a pet food, eight years before it was legal to use in pet food.
In 2012, Blue Buffalo marketed “Grain-Free” dog foods using the ingredients pea starch and pea fiber.
In 2013, Blue Buffalo Longevity Cat Food included the illegal ingredient “pea protein“.
In 2013, Orijen Adult Dog Food included the illegal ingredient “pea fiber“.
In 2013, Hill’s Science Diet offered a grain free pet food that included the illegal ingredient “pea protein concentrate“
In 2015, Nutro Natural Choice Dog Food included the illegal ingredient “pea protein“.
This is only a small example of the manufacturers that used these ingredients LONG before the ingredients were legal to use. In other words – ‘they’ (industry) did whatever they wanted to (and still do). No regulatory authority (FDA and/or each State’s Department of Agriculture) stopped pet food manufacturers from using illegal ingredients.
This issue could be regulated better if pet owners had public access to pet food ingredient definitions. If there was public access, any pet owner could look up all ingredients listed on a pet food label and report to authorities any illegal use. But…pet owners don’t have public access to pet food ingredient definitions. AAFCO owns them and charges $120 a year to read.
If you see any ingredient on your pet’s food label that you don’t recognize or want to know the definition of – contact your State Department of Agriculture representative and ask them to provide you with the legal definition. Click Here for a map of US pet food regulatory authorities – click on your state.
My thanks to this pet owner for a great question!
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.
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