In 2006, a task force under the National Organic Standards Board made recommendations to amend the organic livestock feed regulations to include petfood-specific rules.
The organic petfood market has grown considerably over the
past decade. Admittedly, when I first was introduced to the
concept, I wasn't convinced that many pet owners would be
willing to pay the significantly higher costs associated with
organic production compared to its less tangible benefits. It
is now clear that a significant segment of the public finds
organic petfoods to be an attractive offering. However, a
recent directive by the
US Department of Agriculture
National Organic Program
may adversely impact this growing market.
Presently, organic food regulations under NOP apply only to
foods for human consumption and livestock feeds. The rules for
livestock feeds were very important to establish early in the
process, since animals intended to be the sources of organic
meat, milk and eggs for human consumption must be fed organic
feed. Establishing rules for organic petfoods, however, has
been considered by NOP to be a less critical need.
Unfortunately, neither the existing regulations for human
foods nor those for livestock feeds are a good fit when it
comes to petfoods, making compliance with the rules confusing
at best. At first, USDA told the
American Feed Control Officials
in a 2002 letter that the organic regulations would
apply. A couple of years later, it issued a statement saying
products that were not subject to specifically applicable USDA
regulations (including petfoods) could not bear the USDA
Organic Seal or otherwise imply compliance with the organic
regulations--only to rescind that statement soon after.
In 2006, a task force under the
National Organic Standards Board
made recommendations to amend the organic livestock feed
regulations to include petfood-specific rules. At the time, I
had a few comments I believed would improve the draft
regulations, but in general I thought they were appropriate and
sorely needed. While NOSB accepted the recommendations of the
task force in 2008, there has not appeared to be any further
action on the part of NOP to promulgate these new
Although NOP's 2002 letter to AAFCO is not clear on this
point, the implication has always been that organic petfoods
needed to follow the human food rules. In practice, though,
there appeared to be some wiggle room, particularly with regard
to including vitamins and minerals.
To be certified as organic, all synthetic ingredients in
foods or feeds must be expressly on the National List. The list
allows inclusion of
Food and Drug
approved vitamins and minerals for livestock feeds, but
historically certifiers did not appear to have any
consternation in extending the provision for use of these
ingredients in petfoods as well. There remained issues with
nutrients that were neither vitamins nor minerals (e.g.,
taurine), but for the most part there have been minimal
problems with selling a complete and balanced organic
However, in a new public comment from NOP, it notes that
pets are not livestock; hence, petfoods may not in any fashion
be certified under the livestock feed rules. Unfortunately, the
only reference to permissible micronutrients in the human food
rules is an FDA regulation that is specific to human foods.
Thus, NOP concludes that neither the vitamins and minerals
permitted in organic human foods nor those in livestock feeds
are acceptable for use in organic petfoods. So, any petfood
containing added vitamins and minerals cannot be certified.
This ruling is not an issue for non-fortified snacks and
treats, but is a major problem for complete and balanced
products. While it is technically possible to formulate a
complete and balanced petfood without the use of synthetic
micronutrients, it is extremely difficult in practice, and
because of normal variability in incoming ingredients, the
resulting product may not consistently meet AAFCO requirements
for nutritional adequacy. Essentially, then, this finding by
NOP virtually eliminates the possibility of certifying a
complete and balanced petfood as organic.
A major organic certifier indicates in a letter to a petfood
manufacturer that products must be brought into compliance by
September or their certification will be revoked. The
certifiers are not to blame. They must comply with NOP's
directives or risk facing severe penalties themselves
(including loss of accreditation).
As I understand it, efforts are being made by trade
associations to get NOP to reconsider this ruling, and
hopefully, the matter will be resolved soon. However, unless
and until new petfood-specific organic rules are enacted, these
types of issues are bound to recur.
The mid-year meeting addressed several regulatory matters affecting petfoods
Public meetings invited comments and provided updates
Committees discussed key proposals such as a possible shift in the oversight of animal feeds
It gives more direct control to CVM in establishing and maintaining ingredient definitions
The latest data from Packaged Facts on hot trends and what the future holds for the US natural and organic pet market
What does the new economic reality mean for petfood manufacturers, especially small- to medium-sized companies?
Are key drivers of new product development for petfood and pet treats changing?
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