Thursday, June 18, 2009

Pet Food Labels 101: Net Quantity Statement

Pet food labeling is regulated at two levels. The Federal regulations, enforced by the FDA's Center for Veterinary Medicine (CVM), establish standards applicable for all animal feeds: proper identification of product, net quantity statement, manufacturer's address, and proper listing of ingredients. Some States also enforce their own labeling regulations. Many of these have adopted the model pet food regulations established by the Association of American Feed Control Officials (AAFCO). These regulations are more specific in nature, covering aspects of labeling such as the product name, the guaranteed analysis, the nutritional adequacy statement, feeding directions, and calorie statements.

The net quantity statement tells you how much product is in the container. There are many FDA regulations dictating the format, size and placement of the net quantity statement. None of these do any good if the consumer does not check the quantity statements, especially when comparing the cost of products. For example, a 14-ounce can of food may look identical to the one-pound can of food right next to it. Also, dry products may differ greatly in density, especially some of the "lite" products. Thus, a bag that may typically hold 40 pounds of food may only hold 35 pounds of a food that is "puffed up." A cost-per-ounce or per-pound comparison between products is always prudent. Manufacturer's Name and Address The "manufactured by..." statement identifies the party responsible for the quality and safety of the product and its location. If the label says "manufactured for..." or "distributed by...," the food was manufactured by an outside manufacturer, but the name on the label still designates the responsible party. Not all labels include a street address along with the city, State, and zip code, but by law, it should be listed in either a city directory or a telephone directory. Many manufacturers also include a toll-free number on the label for consumer inquiries. If a consumer has a question or complaint about the product, he or she should not hesitate to use this information to contact the responsible party. Ingredient List All ingredients are required to be listed in order of predominance by weight. The weights of ingredients are determined as they are added in the formulation, including their inherent water content. This latter fact is important when evaluating relative quantity claims, especially when ingredients of different moisture contents are compared.

For example, one pet food may list "meat" as its first ingredient, and "corn" as its second. The manufacturer doesn't hesitate to point out that its competitor lists "corn" first ("meat meal" is second), suggesting the competitor's product has less animal-source protein than its own. However, meat is very high in moisture (approximately 75% water). On the other hand, water and fat are removed from meat meal, so it is only 10% moisture (what's left is mostly protein and minerals). If we could compare both products on a dry matter basis (mathematically "remove" the water from both ingredients), one could see that the second product had more animal-source protein from meat meal than the first product had from meat, even though the ingredient list suggests otherwise.

That is not to say that the second product has more "meat" than the first, or in fact, any meat at all. Meat meal is not meat per se, since most of the fat and water have been removed by rendering. Ingredients must be listed by their "common or usual" name. Most ingredients on pet food labels have a corresponding definition in the AAFCO Official Publication. For example, "meat" is defined as the "clean flesh of slaughtered mammals and is limited to...the striate muscle...with or without the accompanying and overlying fat and the portions of the skin, sinew, nerve and blood vessels which normally accompany the flesh." On the other hand, "meat meal" is "the rendered product from mammal tissues, exclusive of any added blood, hair, horn, hide trimmings, manure, stomach and rumen contents." Thus, in addition to the processing, it could also contain parts of animals one would not think of as "meat." Meat meal may not be very pleasing to think about eating yourself, even though it's probably more nutritious. Animals do not share in people's aesthetic concerns about the source and composition of their food. Regardless, the distinction must be made in the ingredient list (and in the product name). For this reason, a product containing "lamb meal" cannot be named a "Lamb Dinner."

Further down the ingredient list, the "common or usual" names become less common or usual to most consumers. The majority of ingredients with chemical-sounding names are, in fact, vitamins, minerals, or other nutrients. Other possible ingredients may include artificial colors, stabilizers, and preservatives. All should be either "Generally Recognized As Safe (GRAS)" or approved food additives for their intended uses.

If scientific data are presented that show a health risk to animals of an ingredient or additive, CVM can act to prohibit or modify its use in pet food. For example, propylene glycol was used as a humectant in soft-moist pet foods, which helps retain water and gives these products their unique texture and taste. It was affirmed Generally Recognized As Safe (GRAS) for use in human and animal food before the advent of soft-moist foods. It was known for some time that propylene glycol caused Heinz Body formation in the red blood cells of cats (small clumps of proteins seen in the cells when viewed under the microscope), but it could not be shown to cause overt anemia or other clinical effects. However, recent reports in the veterinary literature of scientifically sound studies have shown that propylene glycol reduces the red blood cell survival time, renders red blood cells more susceptible to oxidative damage, and has other adverse effects in cats consuming the substance at levels found in soft-moist food. In light of this new data, CVM amended the regulations to expressly prohibit the use of propylene glycol in cat foods.
Another pet food additive of some controversy is ethoxyquin, which was approved as a food additive over thirty-five years ago for use as an antioxidant chemical preservative in animal feeds. Approximately ten years ago, CVM began receiving reports from dog owners attributing the presence of ethoxyquin in the dog food with a myriad of adverse effects, such as allergic reactions, skin problems, major organ failure, behavior problems, and cancer. However, there was a paucity of available scientific data to support these contentions, or to show other adverse effects in dogs at levels approved for use in dog foods. More recent studies by the manufacturer of ethoxyquin showed a dose-dependent accumulation of a hemoglobin-related pigment in the liver, as well as increases in the levels of liver-related enzymes in the blood. Although these changes are due to ethoxyquin in the diet, the pigment is not made from ethoxyquin itself, and the health significance of these findings is unknown. More information on the utility of ethoxyquin is still needed in order for CVM to amend the maximum allowable level to below that which would cause these effects, but which still would be useful in preserving the food. While studies are being conducted to ascertain a more accurate minimum effective level of ethoxyquin in dog foods, CVM has asked the pet food industry to voluntarily lower the maximum level of use of ethoxyquin in dog foods from 150 ppm (0.015%) to 75 ppm. Regardless, most pet foods that contained ethoxyquin never exceeded the lower amount, even before this recommended change.

Pet owners and veterinary professionals have a right to know what they are feeding their animals. The pet food label contains a wealth of information, if one knows how to read it. Do not be swayed by the many marketing gimmicks or eye catching claims. If there is a question about the product, contact the manufacturer or ask an appropriate regulatory agency.

FDA Animal & Veterinary Resources Pet Food Labels - General Consumer information provided by David A. Dzanis, DVM, Ph.D., DACVN.

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