The Caped Crusader for Safe Pet Food
Susan Thixton is a pet food consumer, the Caped Crusader for Safe Pet Food, author, and runs a website called TruthAboutPetFood.com. She wrote a book titled “Buyer Beware, The Crimes, Lies and Truth About Pet Food” about the state of the Pet Food business in the United States. It inspired us to thoroughly research the claims for our business initially.
The United States employee a complex system of law making – the US Food & Drug Administration (FDA), the US Department of Agriculture (USDA), and the US Federal Trade Commission (FTC) “regulate” manufacture and labelling of dog food at the federal level; with further oversight conducted at the state level.
The US Association of American Feed Control Officials (AAFCO) is a voluntary commercial enterprise (listed as a not-for-profit corporation) that attempts to regulate the quality and safety of fodder (livestock feed) and (secondarily) pet food in the US.
The AAFCO itself has no regulatory authority but establishes standards on which states base their feed laws and regulations, in part, to “Provide a level playing field of orderly commerce for the animal feed industry.” These regulations are more specific in nature, covering aspects of labelling such as the product name, ingredient definitions, the guaranteed analysis, the nutritional adequacy statement, feeding directions, and calorie statements. It’s important to understand that AAFCO does not determine permissible sources of protein or other essential nutrients: AAFCO’s only requirement is that the manufacturer comply with AAFCO’s extensive list of ingredient definitions.
That the organization sets standards for nutritional adequacy needs an important clarification: focused on the term “adequacy.” AAFCO regulations deal with the maximum and/or minimum levels (not the ideal levels) of only the nutrients that AAFCO deems essential to a pet’s health… through advice from pet food manufacturing representatives.
For example, AAFCO requires that an adult dog food must contain at least 18 percent protein if the manufacturer is going to call it “complete and balanced.” But this does not mean that 18 percent protein is an ideal amount for dogs: only that less than that could make a dog fall ill. Neither does AAFCO concern itself with the source of that claimed protein, or, focus on important aspects of canine nutrition: the levels of some very important nutrients, such as omega 3 and omega 6 fatty acids, are completely left to the discretion of the manufacturer.
Members of AAFCO are employees of states Department of Agriculture (though not all states participate). That means they are state and federal employees (with regulatory authorities) in their “day jobs.” US FDA representatives participate at all AAFCO meetings, and three US FDA employees sit on the Board of Directors of AAFCO.
We document these items in both international context (US & Canada as regulated through the US AAFCO guidelines and regulations) as well as our local legislation from The Department of Agriculture (Act 36 of 1947) and the Advertising Association of South Africa (ASASA) regulations and guidelines (now defunct) that apply to Pet Food Advertising (Appendix I of said code of practice (COP)).
AAFCO Regulation PF7. Nutritional Adequacy
“The label of a pet food or specialty pet food which is intended for all life stages of the pet or specialty pet may include an unqualified claim, either directly, or indirectly …” on pet food labels.
Act 36 of 1947 / COP. Nutritional Adequacy
- Not defined. The COP states (clause 5)
“Pet foods that deviate from the nutritional adequacy requirements specified in the guidelines shall be registered only if, in the opinion of the Registrar, their nutritional adequacy has been substantiated by scientific trials and/or scientific data and they are fit to be placed on the market.”
- COP (clause 7, sub-clause 3)
“The label of a pet food shall not contain an unqualified representation or claim, directly or indirectly, that the pet food therein contained or a recommended feeding thereof is or meets the requisites of a complete, scientific or balanced ration for dogs or cats unless such product or feeding complies with the requirements of item 5 above.”
When you walk into a pet store and read the labels of the hundreds of dog or cat foods available, realise that just about anything written on the label can be a “direct unqualified claim”.
AAFCO Regulation PF5. Ingredients
(d)(3) “A reference to quality or grade of the ingredient does not appear in the ingredient statement.”
- COP (clause 7, sub-clause 21)
“No reference to quality or grade of an ingredient shall appear in the ingredient statement of a pet food.”
These regulations deny pet food manufacturers that use only the highest quality ingredients from separating themselves from pet feed manufacturers that use inferior, poor quality ingredients.
When you walk into a pet store hoping to find a safe, healthy food for your cat or dog, remember, every pet food label can lie to you and those that want to tell you the truth about the quality of their ingredients cannot.
References and Articles
- Natural pet food: A review of natural diets and their impact on canine and feline physiology – https://academic.oup.com/jas/article/92/9/3781/4702209?searchresult=1
The natural pet food trend has focused on the inclusion of whole ingredients, including meats, fruits, and vegetables; avoiding ingredients perceived as heavily processed, including refined grains, fiber sources, and byproducts; and feeding according to ancestral or instinctual nutritional philosophies. Current scientific evidence supporting nutritional benefits of natural pet food products is limited to evaluations of dietary macronutrient profiles, fractionation of ingredients, and the processing of ingredients and final product. Future opportunities exist to better understand the effect of natural diets on health and nutrition outcomes and to better integrate sustainable practices in the production of natural pet foods.
