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Pet Food Labeling Requirements: Why the Industry Needs New Standards

Posted by Jim Galovski on
Pet Food Labeling Requirements: Why the Industry Needs New Standards - NOBL Foods


This article first appeared on LinkedIn



"Nothing is more powerful than an idea whose time has come." - Victor Hugo

I know...this topic has been addressed before (but only a few hundred times). Lately I have witnessed a lot of people referencing AAFCO and the FDA in pet food but not actually understanding their roles, history and limitations. The biggest misunderstandings come from pet food labeling. Like everything these days, opinions are quite polarized. After a quick "Cliff Notes" recap, I'll share each labeling requirement and the problems that I see with them. Each section from the FDA site is linked so you can see the exact comments and regulations.


The FDA, under the Federal Food, Drug and Cosmetic Act (FFDCA), requires that, " food is safe to eat, produced under sanitary conditions, contain no harmful substances and be truthfully labeled." They also ensure that ingredients are both safe and actually "have an appropriate function in the pet food." While the FDA regulates the industry, their work is based on a model provided by AAFCO (Association of American Feed Control Officers); a voluntary group of local, state and federal agencies. AAFCO was founded in 1906 to regulate animal feeds. Canine nutrient profiles were not created until 1991 (feline followed in 1992). As "new, science based" knowledge becomes available, the profiles are updated. The most recent update occurred in 2016. What is important to note here is that AAFCO created "Nutrient Expert Subcommittees" in response to the National Research Council (NRC) and their Nutrient Requirements of Dogs and Cats (1985 and 1986, respectively). The problem with the NRC requirement was that manufacturers didn't feel it had practical application in making pet food. NRC's latest update happened in 2006 and did usher in several changes at both AAFCO and FEDIAF (The European Pet Food Industry Federation). In summary, NRC is a detailed, scientific guideline of physiology with consideration given to the multiple variables that impact nutrient requirements. AAFCO is 1) an "industry friendly" interpretation of those guidelines and 2) a consistent, yet minimal, level for manufacturers to attain. As you look at each section below, keep in mind that these are MINIMAL requirements that are industry friendly. They are not meant to represent cutting edge science, just minimally consistent targets.

Manufacturer's Name and Address

You should know who is responsible for the new brand (or old favorite) you're buying. If the label says, "manufactured for..." or "distributed by...", it has been produced by a third party but the named company is still THE responsible party. For manufacturers that have multiple production sites, this won't tell you where it was made. For that, you would need to look at the Lot Code and have the manufacturer's "key" to decipher the letters and numbers.

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Net Quantity Statement

You need to tell people how much is in your bag so as to avoid the "potato chip" illusion. Size (of the bag) doesn't matter. The bag with kibble weighs 4.5lbs (72oz) while the freeze dried bag is 13.5oz. Without this requirement, someone (I guess) may think that both bags contain roughly the same quantity of food.

Product Name

This is the first area that needs to be understood better and put under greater scrutiny. Often referred to as the "95-25-3 Rule", there is far too much room for marketing ploys. For example, if you are looking at Beef Dog Food, Beef Recipe for Dogs, Dog Food with Beef and Beef Flavored Dog Food, it isn't very apparent what you are getting.

  • Beef Dog Food requires that, "Beef" is, at a minimum, 95% or more in weight of the ingredient total. If the formula is "Beef and Liver" then those two ingredients combined must total 95% or more.
  • The 25% rule requires the named ingredient to be at least 25% of the total ingredient weight (e.g. Beef Recipe for Dogs). These diets can also be named "Dinner," "Platter," "Entree," "Nuggets" and "Formula" to give just a few naming options. If the manufacturer uses two named ingredients, the total of both must be 25% or more with both ingredients being at least 3%. The span from 25-94% is pretty extreme. A diet that contains 45% Beef and 45% Chicken MUST be named similarly to a diet with 22% Beef and 3% Chicken.
  • The 3% Rule is used for diets that utilize "with" in their name (e.g. Dog Food with Beef).
  • As for Beef Flavored Dog Food, it doesn't require any "Beef" to actually be in the product!

Nutritional Adequacy Statement

This section requires a significant overhaul! No one is going to put out a product that claims "Barely enough nutrients to keep your pet alive" yet that same company can proudly state "(Name of product) is formulated to meet the nutritional levels established by the AAFCO (Dog/Cat) Food Nutrient Profiles." AAFCO allows for two different methods to be used to "prove" the statement. The first (and most used method) is "Formulated to meet..." and the second (and more expensive method) is "Animal feeding tests using AAFCO procedures substantiate..."!

  • In order to receive the "Formulated" designation, a company simply needs to show that their product was formulated to meet the minimum levels of nutrients based on AAFCO guidelines. This can be done through industry recognized software or through lab testing/analysis. The latter is required for the Guaranteed Analysis. Sadly, there are smaller and mid-sized companies that only do computer based formulations and NEVER test the finished goods. Want to know who they are? Ask your pet food company if they can share their AAFCO panel on the diet you feed. Most will tell you, "Its proprietary, we can't share it." If that happens, just ask them to share actual levels of a few amino acids, vitamins and/or trade secret giveaway there!
  • Under AAFCO feeding trials, the animal is given a physical exam by a veterinarian before and after the 26 week trial period. During the exam, the animal is evaluated for general health, body and hair coat condition. The diet being tested fails if any animal shows clinical or pathological signs of nutritional deficiency or excess. No dog or cat is allowed to lose more than 15% of its starting body weight. AFTER the trial, four (4) blood values are measured and recorded: hemoglobin, packed cell volume, serum alkaline phosphatase, and serum albumin. While manufacturers do BEFORE blood work, those results aren't required so you can't do a pre/post comparison. Why? A manufacturer will screen the animals before so as to give their diet the best chance for success. For example, on serum levels, they may pre-test 15 dogs and pick the 8 with the lowest alkaline phosphatase for the trial. If the levels increase, they still are within "normal" and the diet "passes"!

Touting AAFCO can be manipulated in to a marketing tool. "We perform AAFCO feeding trials and formulate all of our products to meet or exceed required levels." Sounds great, right? The system can be gigged and the deck stacked. I could run three iterations of a diet simultaneously through the trial and in the end, select the one that passes with the lowest possible cost, not necessarily the best nutrition. I also only have to run one trial for a "product family" but all of the SKUs will get the same "feeding" designation. As we've seen with the current Hills recall, a company that "meets/exceeds" AAFCO guidelines doesn't mean anything if they don't follow proper procedures and protocols.

Ingredient List

Far too many people consider this to be the holy grail and definitive source of what is and what isn't a "good" pet food. I'm here to tell you that while it is nice, it is useless! The ingredients are listed in order of wet weight. So while named "meals" are often maligned, they tend to offer higher nutritional values on a per gram basis than their "whole" alternatives. Unfortunately they are found further down the deck as they don't contain the 70-80% moisture levels (and weight) of named "meats". The ingredient deck is by far the most manipulated document in pet food! Some specific watch outs: Rank/Ordering, Ingredient Splitting and Window Dressing. These are ALL driven by consumer trends and marketing!

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The ONLY thing you can ascertain from the ingredient deck is the relative weight of the ingredients to one another. The deck above just shows the first 7 ingredients of a popular dog food. The only thing you "know" is that from left to right, the ingredients weigh more than the next ingredient. You have NO IDEA the inclusion rate (%age), the quality, digestibility, bio-availability...nothing!

  • Rank/Ordering - If these first 7 ingredients make up 55% of the total, it is quite possible (and plausible) that the %ages could be 20, 10, 5, 5, 5, 5, 5. Ingredients 3-7 have the same inclusion rate so their order is determined by the manufacturer. If Pea Protein gets a bad rap, we put it in the 7th position. The manufacturer can adjust the ingredient inclusion rates regularly in an effort to sell the story that consumers want to hear.
  • Ingredient Splitting - Using the same 7 ingredients, you can see this manufacturer has split potatoes and peas. If Peas are suddenly hailed as a wonder ingredient, we can combine Peas and Pea Protein and move it up to the 2nd ingredient on the deck (at 10%, it is equal to Lamb Meal's inclusion therefore the order is up to the manufacturer)!
  • Window Dressing - Manufacturers often do this to say they have some healthy fruits and veggies or yeast culture/probiotic. An example is when you see the 67th ingredient listed as "carrots" but the 23rd ingredient is ascorbic acid. In the extrusion process, there is nothing of the carrot that remains intact and usable. The Vitamin C is being provided by ascorbic acid, NOT the carrot but boy does it look good on the packaging and in the sales materials!

Guaranteed Analysis

The only things that are required in the GA are the Minimum %ages for Crude Protein and Crude Fat and the Maximum %ages for Crude Fiber and Moisture. Manufacturers can add additional items to the GA but they must have an asterisk that says "Not recognized as an essential nutrient by the AAFCO Dog/Cat Food Nutrient Profiles." The GAs are also reported on an "as is"/"as fed" basis which makes easy comparisons difficult because of varying moisture levels. A top selling 12.5oz can of dog food has a GA of 8.5% protein and 78% moisture. If you remove the moisture from the weight you are left with 2.75oz of "dry matter" and a 38.6% protein in the GA! While using Dry Matter Basis as a means of reporting the GA seems like a good idea, it can't be done in a vacuum. The Feeding Guidelines for that can of dog food show that a 40lb dog should be fed 3 cans (37.5oz)/day and that the food will deliver 444kcal. The problem is, a typical 40lb dog needs between 800-1200 kcal daily. The chances that our dog will be able to put away nearly 80oz of canned food each and every day is slim (which the dog will NOT be). It is equivalent to a 200lb man consuming 25lbs of food EVERY DAY.

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Feeding Directions

The guidelines are just that - guides! The NRC shows a multitude of variables that influence an animals caloric needs - (e.g. breed, temperament, environment, age, pregnant/nursing, intact/neutered, etc.) but they all can't be accounted for in the chart and consumers need to know how and why servings should be adjusted. When I hear someone say they will simply feed their puppy 2x the guidelines of an Adult Food, it is like nails on a chalkboard! To further complicate/confuse, most manufacturers call for servings using a standard 8oz cup. A standard measuring cup holds between 3.6-4.4oz of kibble, freeze-dried SIGNIFICANTLY less. Some companies (Purina and Royal Canin) are putting serving sizes in grams and cups to help. If I don't precisely weigh out the food and serve "rounded" cups, my dog can get up to 20% MORE food EVERY DAY. Did I mention that more than 56% of dogs and cats in the US are considered obese? Beyond the serving size, WHERE the pet is getting their calories from is also a big concern.

Calorie Statement

The brand above lists 3,613 kcal/kg, 377 kcal/cup. What does that actually tell you? Well, if you do the math, it says 1 cup is equal to 104 g of food (or 3.67oz). That is it. We have no idea where the calories come from. Despite what many consumers believe, the GA does NOT show this information. What is shown there is the "Crude Protein" which is just a reference to the chemical analysis. This analysis measures the amount of nitrogen that is present in the diet. What is really needed is the caloric distribution by macronutrient (Protein, Fat or Carbohydrate (Nitrogen Free Extract)). Using the same 377 kcal/cup food, we can calculate that 44% (166kcal) of the calories come from Carbs, 33% (124kcal) from Fat and 23% (87kcal) from Protein. Armed with this data the consumer and/or veterinarian can make better informed decisions for the health of the pet. Think about it; protein provides amino acids that helps build, replenish and repair the systems within the body (3.5kcal/gram). Fat is the easiest/fastest conversion to energy. Unlike in humans, fat doesn't clog the animals arteries and has 8.5kcal/gram. As for carbs, they also provide energy (3.5kcal/gram) but slower, over a longer period of time. When not immediately used, it is the carbs that are readily converted to body fat on our pets.

"Do not be swayed by the many marketing gimmicks or eye-catching claims." - FDA on pet food


You know when the governing body for the industry posts a comment like that on its website, marketing has run amok in the industry. The only way things will change is if we as consumers demand change from the industry and make our voices heard through the almighty dollar. Rather than fall for marketing claims, ask Pet Plate for proof on their longevity claims (since removed). Ask the FDA and AAFCO to 1) enforce the regulations so that everyone adheres to the guidelines. If aspergillus orzyae is only accepted as a digestive enzyme, DON'T let Wild Earth call it a "clean protein" without changing the definition/usage. If crickets are not an approved ingredient, don't let Purina sell it under the RootLabs brand name unless they get ingredient approval and 2) update and improve the requirements in an effort to achieve optimal nutrition NOT minimal, standards. We have several health issues that are reaching epidemic proportions. Pet obesity leads to dozens of avoidable problems. Not understanding/testing different formulations, interactions of ingredients and their synthesis and digestibility has potentially created an increase in nutritionally-mediated dilated cardiomyopathy cases. If you don't think your guidelines play a role, then why have them. Don't misunderstand me, AAFCO and the FDA are critical to the long term health of our pets and our industry. It has been shown time and time again that business struggles to self-regulate. I'm not a proponent for MORE regulations, just BETTER ones that put our pets first!

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