The 102nd Annual Convention of the Association of American Feed
Control Officials was held July 30 to August 1, 2011, in Austin, Texas,
USA. There were some, but not very many, items directly affecting petfood.
Since the AAFCO recently changed its procedures so the membership now
votes at both the annual and midyear meetings, the number of items up for consideration
in the general session seemed fewer this year than at annual meetings past. In
fact, most of the committees, including the Pet Food Committee, had no
actionable items up for vote.
The AAFCO membership did vote to accept changes to the regulations
affecting the label declaration of guarantees for specialty petfoods as brought
forth by the Model Legislation & Regulation Committee. The guaranteed
analysis on bird, reptile, fish and small mammal food labels now must appear in
the same format as guarantees for dog and cat foods instead of that for livestock
feeds. Manufacturers will have until January 2013 to revise their labels.
Among the items up for vote from the Ingredient Definitions
Committee, the item of most impact on the petfood industry is the definition
for L-carnitine. As revised, the definition now makes clear that it may be
added to any dog and cat food, including treats and supplements, not just
complete and balanced foods. The maximum inclusion rate of 750 mg/kg dry matter
for dog foods and 1,000 mg/kg dry matter for adult cat foods still applies to
all types of food.
The Pet Food Committee session covered many items, but in most cases
action was deferred to the midyear meeting in January 2012. The expert panel
for the AAFCO Dog and Cat Food Nutrient Profiles and feeding trial protocols
will review the comments received on its draft recommendations and provide a
final version for consideration by the Committee at the next meeting. The
Carbohydrate Working Group will also provide its recommendations in January.
Over the next few months, a small group of regulators will put the final
touches on the revised affidavit for calorie content statements to be
consistent with the Regulation PF9 (passed by the Committee at the last meeting, which
in part mandates calorie content statements on all dog and cat food labels) as
well as the proposed amendments to Regulation PF10 (which would set
requirements for “weight control” and similar claims). That should provide
enough time for review of these documents by interested parties before
discussion and possible action at the midyear meeting.
brought to the Pet Food Committee included the revision to the committee’s
purpose statement as suggested by the AAFCO Board of Directors (AAFCO Official Publication, 2011). Since the
time frame to get back to the board is short, the comment period will have
closed before this column is published. Also discussed was the development of
an AAFCO statement expressly objecting to claims such as “AAFCO approved” on
pet product labels. The matter will be open for a few months for comment on
discussion, there was consensus in the committee that allowing minimum and/or
maximum voluntary guarantees for some nutrients did not conflict with the
general model feed regulations. A small working group was formed to investigate
concerns expressed by an outside organization that the AAFCO’s guidelines for
plaque and tartar control claims were inconsistent with Food and Drug
The Ingredient Definitions Committee accepted proposed changes to
the definitions to better distinguish meat meal from meat and bone meal on the
basis of phosphorus content, with some overlap (meat meal <4.5% P, meat and
bone meal >3.5% P). It also discussed some new feed terms that could affect
petfoods, such as “popped” and “puffed,” but the investigator withdrew the
items from further consideration at this time. On the other hand, “powdered”
was accepted by the committee as a new feed term.
The Model Legislation & Regulation Committee is still waiting to
receive a charge by the board to review the amendments to Regulation PF9 as
previously passed by the Pet Food Committee. The Feed Labeling Committee has
formed working groups to consider a requirement for minimum and maximum
selenium guarantees for feeds containing over 0.5 parts per million selenium
and a maximum sulfur guarantee for feeds containing more than 0.5% sulfur. It
is unclear whether these items could apply to petfood labels at this time.
A proposal to the Feed Labeling Committee to require phone numbers
to accompany the guarantor’s name and address was dropped after discussion.
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