When a Pet Food is a "Drug"

In my comment Quality assurances on pet food labels – Realistic or marketing as usual? we took a closer look at quality assurances made by manufacturers on their pet food labels and unfortunately came to the conclusion that most of them are nothing else but marketing gigs. Though it has to be said that the marketing people at these companies disserve credit. The bottom line is that stats clearly show their strategy is working, even if the actual claims are totally meaningless. Today I want to take a closer look at another, similar category of pet foods. This one too is experiencing enormous growth rates: Pet nutritional products promising help and cure for health related issues What I find most ironic about these foods is that pretty much most of the health issues we are confronted with these days typically are caused by just the same food now promising to be the cure!? This comment is meant to be a crash course and a quick overview of what you need to know before you purchase pet food labeled with claims falling into any of these categories.

When a 'Food' is a 'Drug'
Statements that a product can treat, prevent or reduce the risk of a disease are considered drug claims and are not allowed on pet food. The FDA’s (Food and Drug Administration) Center of Veterinary Medicine (CVM) also disallows claims such as "improves skin and coat," "prevents dry skin," and "hypoallergenic." Consumers may see phrases such as "promotes healthy skin" and "promotes glossy coat." CVM permits these claims, but any healthy animal that gets adequate nutrition should have these qualities anyway without eating a special food.
Recognizing the close link between diet and disease, CVM does allow certain health related information on labels to help consumers evaluate pet foods. For example, while a product cannot claim to treat feline lower urinary tract disease, a concern for some cat owners, it may make the claim that the food "reduces urine pH to help maintain urinary tract health," provided data generated by the manufacturer and reviewed by CVM support the statement.
CVM permits some dental claims on pet foods. The jaw movement of animals as they chew on certain foods or treats, or some chemicals in foods, can help reduce plaque and tartar, so CVM allows claims such as "helps control plaque" and "helps control tartar." CVM does not allow claims to treat or prevent gingivitis or periodontal disease because these are drug claims.
Pet owners may see claims such as "improves doggie breath" on pet food or treats. These claims have no regulatory meaning; manufacturers use them simply to promote their products.
The phrase "recommended by veterinarians" also has no regulatory meaning, says Rodney Noel, Ph.D., AAFCO's pet food committee chair and a chemist at Purdue University. "There is no minimum number or percentage of veterinarians required for a company to be able to state its product is recommended by vets," Noel says.
CVM provides manufacturers some latitude in making health claims regarding a category of food known as veterinary medical foods, which consumers can obtain only through a veterinarian. Manufacturers design these foods to treat a particular disease or condition. Although not regulated as drugs, these foods may carry health information in promotional materials for the veterinarian to help them treat their patients correctly.

Making Sense of 'Light' and 'Lean' in Pet Food
The calorie and fat contents listed below are the maximum limits allowed in dog and cat food labeled "light" or "lean." These definitions are established by the Association of American Feed Control Officials and authorized by the FDA. Comparisons between products in different categories of moisture content are considered misleading.

Light, lite, or low calorie:
Dry Foods (< 20% moisture): Calories/lbs: Dogs 1,409; cats 1,477
Semi moist food (20 to 75% moisture): Calories/lbs: Dogs 1,136; cats 1,205
Moist food (> 65% moisture): Calories/lbs: Dogs 409; cats 432

Lean or low fat
Dry Foods (< 20% moisture): Dogs 9% fat, cats 10% fat
Semi moist food (20 to 75% moisture): Dogs 7% fat, cats 8% fat
Moist food (> 65% moisture): Dogs 4% fat, cats 5% fat

Stay tuned for the conclusion with consumer information on how to interpret pet food labels for “Special use food”.