Roasted Chicken for Dinner?
It is what pet parents want. It is what we think / assume we are buying – those colourful pics on the packaging – human grade ingredient pet food yes? The pictures on the label show images of fresh meat and vegetables. The name of the pet feed includes human food words such as “sirloin” or “roasted chicken“. Of course, pet parents would assume from the pictures and the wording on the pet feed that this is what is inside the bag or can of pet feed. However, truth behold, this is far from what the pet feed name and/or picture imply. Pet feed meat ingredients (and essentially all other ingredients) are separated by some (and legislation) into two categories: human grade and pet grade ingredients.
Based on current regulations, a manufacturer that searches high and low for the highest quality / grade of ingredients, human grade, cannot legally claim the ingredients in advertising or on product labels. Even if all human grade ingredients are used in a pet food, once those ingredients enter a “pet feed plant“, they become “pet grade ingredients“. So, the only way to enable such a claim, is to produce your product in a “human grade food plant“, add much cost and expense to your product.
Some manufacturers label their products with terms of “premium,” “ultra premium”, and “holistic”. Such concepts currently have no official AAFCO definitions, although that is under consideration. The expressions “human grade ingredients” or “USDA inspected” are completely meaningless – which is why McKibble may use them.
However, the terms “natural” and “organic” do have definitions: organic products must meet the same USDA regulations as for organic human food. Organic agriculture is conducted according to certain standards, especially the use of only naturally produced fertilizers and non-chemical means of pest control. According to the USDA, a food can only be labelled “natural” if it contains no artificial ingredients or added colours and is minimally processed. Labelling must plainly define this aspect of the product, so that consumers are not misled by the “natural” label.
Still, it is important to understand what the “natural” label does not mean: for example, animal products used in dog food that were raised with the use of artificial hormones can be labelled “natural”; as can genetically modified organisms (GMOs). Although it is true that as a profit objective, aminopterin (rat poison), melamine and probably cyanuric acid were improperly substituted as protein sources by unscrupulous suppliers, investigations of the 2007 pet food recalls (thousands of dogs and cats killed and injured) have led researchers to theorize that genetically modified vegetables may also have been important, because they may not, in fact, combine in a recipe in the same ways that unaltered (conventional) vegetables would. (1, 2, 3)
Most immediately, natural does not mean organic, although many companies rely on consumer confusion to market products. The opportunities for abuse abound: “Natural Chicken Flavour” can be realized by adding a few drops of rancid restaurant grease, or fats or oils from the rendering process… (and subsequently, that natural flavouring may be artificially preserved). Interestingly, in 2004, the USDA organized the Organic Pet Food Task Force, as part of its US National Organic Program (NOP) “to prevent any disruption to the growing market for organic pet food.” Charged with developing labelling standards for organic pet food (that is: recommending US federal regulatory change), the Chair of this committee was the Vice President of The US Pet Food Institute.
Today, it is generally accepted that the standards for organic certification are under-enforced to the extent of making the term voluntary, and therefore, essentially meaningless for the consumer. Because words such as “natural”, “holistic”, “premium”, “gourmet” and “fresh” do not have a standard definition according to the US FDA or to AAFCO, they should be ignored.
The point is that there is no official AAFCO (or local) definition or acceptance of the “human grade” term, but we can use marketing concepts such as “#1 ingredient is “REAL CHICKEN” .. or “FRESH LAMB” or et al. We will unpack some of these deceits for you …
Act 36 of 1947, Regulations R. 1087, Clause 22, sub-clause 2 (q) states “Statements of energy content shall not be permitted on labels; “. Clause 22, sub-clause 2 (r) states “Statements of digestibility of nutrients or dry matter content shall not be permitted on labels; “. Clause 22, sub-clause 2 (s) states “Claims such as premium, super premium, high digestibility or claims with a similar connotation must be scientifically substantiated by the manufacturer against standard or base line products within the manufacturer’s own product range; “. Clause 22, sub-clause 2 (t) states “No reference to quality or grade of an ingredient shall appear in the ingredient statement of a pet food; “.
Clause 22, sub-clause 2 (w) states “Label claims using the term “natural” shall conform to the following rules-“
- i) The use of the term “natural” is only acceptable in reference to the product as a whole without the use of a disclaimer when all of the ingredients and components of ingredients meet the definition for “natural”;
- (ii) The use of the term “natural” in reference to the product as a whole is false and misleading if any chemically synthesised ingredients are present in the product either by way of direct inclusion or as part of an ingredient included in the product;
- (iii) A disclaimer may be used with the use of “natural” such as “Natural with added vitamins, minerals, and other trace minerals” where the “with” disclaimer includes all the items as appropriate to match the chemically synthesised ingredients included directly or indirectly when juxtaposed with the term “natural”;
- (iv) The disclaimer must appear with the largest or most prominent use of the term “natural” on each panel of the label on which the term appears, in the same style and color print and at least one-half the size of the term “natural”;
- (v) Where a disclaimer is used juxtaposed with the term “natural”, all other ingredients and components of ingredients in the product must meet the definition of “natural”;
- (vi) If the disclaimer that is juxtaposed with the term “natural” is used only to identify in generic terms those vitamins, minerals and other trace nutrients which are not natural, then the disclaimer is not a nutrient claim;
- (vii) If the disclaimer makes reference to a specific nutrient (e.g. “with added calcium”) then the nutrient referred to by the disclaimer must be included in the Guaranteed Analysis statement;
- (viii) When the term “natural’ is used only in reference to a specific ingredient, when other ingredients used in the product are not natural then the term “natural” must not be used in such a way as to imply that the product as a whole is “natural”;
- (ix) Products (mixed food) should not be described directly or by implication as “natural” but as “made from natural ingredients” even if all the ingredients meet the criteria for natural and particularly where the use of a disclaimer is also necessary;
- (x) Products (mixed food) which cannot meet the criteria for natural may not be claimed to have a “natural” taste, flavour, or, colour;
- (xi) “Natural” or its derivatives, may not be included in brand or fancy names nor in coined or meaningless phrases in such a way as to imply that a food which does not meet the natural criteria is natural or made from natural ingredients.
And the definition of “natural“: a feed or ingredient derived solely from plant, animal or mined sources, either in its unprocessed state or having been subject to physical processing, heat processing, rendering, purification, extraction, hydrolysis, enzymolysis, or fermentation, but not having been produced by or subject to a chemical synthetic process and not containing any additives or processing aids that are chemically synthetic except in amounts as might occur unavoidably in good manufacturing practices;
Still think that bag of McKibble or tin of McCan is “natural“, as implied on the label or by the graphics?
References
- https://www.fda.gov/animalveterinary/safetyhealth/recallswithdrawals/ucm129575.htm
- https://en.wikipedia.org/wiki/2007_pet_food_recalls
- https://www.animallaw.info/sites/default/files/lralvol15_1_113.pdf
