What’s Really in Pet Food? Part 2 Label basics, standards and regulations

In Part 1 of this series we briefly introduced the subject matter and discussed the major players in the pet food industry. But as we have learned the trend to bigger doesn’t necessarily translate into better and unfortunately we learned, not that it would be anything new, that there are major differences between what pet owners think they are buying and what they are actually getting. This comment focuses in very general terms on the most visible name brands, the pet food labels that are mass-distributed to supermarkets and discount stores. However, just so that we are on the safe side, there are also many highly respected brands that may be guilty of the same offenses. What many pet owners to this day still don’t know is that the pet food industry is an extension of the human food and agriculture industries. Pet food provides a convenient way for slaughterhouse offal, grains considered “unfit for human consumption,” and similar waste products to be turned into profit. In order for the consumer to make an educated decision it is necessary to learn, among many others considerations, how to read pet food labels to begin with.
There are special labeling requirements for pet food, all of which are contained in the annually revised Official Publication of AAFCO.2 While AAFCO does not regulate pet food, it does provide model regulations and standards that are followed by U.S. pet food makers.
The name of the food provides the first indication of the food’s content. The use of the terms “all” or “100%” cannot be used “if the product contains more than one ingredient, not including water sufficient for processing, de-characterizing agents, or trace amounts of preservatives and condiments.”
The “95% Rule” applies when the ingredient(s) derived from animals, poultry, or fish constitutes at least 95% or more of the total weight of the product (or 70% excluding water for processing). Because all-meat diets are not nutritionally balanced and cause severe deficiencies if fed exclusively, they fell out of favor for many years. However, due to rising consumer interest in high quality meat products, several companies are now promoting 95% and 100% canned meats as a supplemental feeding option.
The “dinner” product is defined by the “25% Rule,” which applies when “an ingredient or a combination of ingredients constitutes at least 25% of the weight of the product (excluding water sufficient for processing)”, or at least 10% of the dry matter weight; and a descriptor such as “recipe,” “platter,” “entree,” and “formula.” A combination of ingredients included in the product name is permissible when each ingredient comprises at least 3% of the product weight, excluding water for processing, and the ingredient names appear in descending order by weight.
The “With” rule allows an ingredient name to appear on the label, such as “with real chicken,” as long as each such ingredient constitutes at least 3% of the food by weight, excluding water for processing.
The “flavor” rule allows a food to be designated as a certain flavor as long as the ingredient(s) are sufficient to “impart a distinctive characteristic” to the food. Thus, a “beef flavor” food may contain a small quantity of digest or other extract of tissues from cattle, or even an artificial flavor, without containing any actual beef meat at all.
The ingredient list is the other major key to what’s really in that bag or can. Ingredients must be listed in descending order of weight. The ingredient names are legally defined. For instance, “meat” refers to only cows, pigs, goats and sheep, and only includes specified muscle tissues. Detailed definitions are published in AAFCO’s Official Publication, revised annually, but can also be found in many places online.
The guaranteed analysis provides a very general guide to the composition of the food. Crude protein, fat, and fiber, and total moisture are required to be listed. Some companies also voluntarily list taurine, Omega fatty acids, magnesium, and other items that they deem important, by marketing standards.

Pet Food Standards and Regulations
The National Research Council (NRC) of the Academy of Sciences set the nutritional standards for pet food that were used by the pet food industry until the late 1980s. The original NRC standards were based on purified diets, and required feeding trials for pet foods claimed to be “complete” and “balanced.” The pet food industry found the feeding trials too restrictive and expensive, so AAFCO designed an alternate procedure for claiming the nutritional adequacy of pet food, by testing the food for compliance with “Nutrient Profiles.” AAFCO also created “expert committees” for canine and feline nutrition, which developed separate canine and feline standards.
While feeding trials are sometimes still done, they are expensive and time-consuming. A standard chemical analysis may also be used to make sure that a food meets the profiles. In either case, there will be a statement on the label stating which method was used. However, because of the “family rule” in the AAFCO book, a label can say that feeding tests were done if it is “similar” to a food that was actually tested on live animals. There is no way to distinguish the lead product from its “family members.” The label will also state whether the product is nutritionally adequate (complete and balanced), and what life stage (adult or growth) the food is for. A food that says “all life stages” meets the growth standards and can be fed to all ages.
Chemical analysis, however, does not address the palatability, digestibility, or biological availability of nutrients in pet food. Thus it is unreliable for determining whether a food will provide an animal with sufficient nutrients. To compensate for the limitations of chemical analysis, AAFCO added a “safety factor,” which was to exceed the minimum amount of nutrients required to meet the complete and balanced requirements.
In 2006, new NRC standards were published; but it will take several years for AAFCO’s profiles to be updated and adopted, let alone accepted by the states.
The pet food industry loves to say that it’s more highly regulated than human food, but that’s just not true. Pet food exists in a bit of a regulatory vacuum; laws are on the books, but enforcement is another story. The FDA has nominal authority over pet foods shipped across state lines. But the real “enforcers” are the feed control officials in each state. They are the ones who actually look at the food and, in many instances, run basic tests to make sure the food meets its Guaranteed Analysis, the chart on the label telling how much protein, fat, moisture, and fiber are present. But regulation and enforcement vary tremendously from state to state. Some, like Texas, Minnesota, and Kentucky, run extensive tests and strictly enforce their laws; others, like California, do neither.
Reprinted with permission from and contributed by Born Free USA united with Animal Protection Institute and reprinted with permission. © 2003-2009 - Born Free USA united with Animal Protection Institute - All rights reserved