Pet Food Regulations / Pet Food Labeling
On January 7, 2013

Petfood predictions for 2013

Regulation amendments and labeling changes may be ahead in the new year.

["The grass-roots movement to require GMO labeling of foods is growing, so it would not be surprising to see similar initiatives pop up in California or other states in 2013.", "The Food Safety Modernization Act of 2011 represents a sea of change in food and feed regulation."]

What's ahead in the new year for petfoods? A number of issues, both at the US Food and Drug Administration (FDA) and the Association of American Feed Control Officials (AAFCO) levels, seem to have lingered on for years. That's not terribly surprising, as by its nature the regulatory process is "deliberate" (i.e., slow). However, 2013 looks promising for final resolution (or at least notable advancement) on several fronts.

Regarding nutrition-related matters, an amendment to AAFCO Model Regulation PF9 was first proposed by the American College of Veterinary Nutrition in 2005 that would require, among other things, a calorie content statement on all dog and cat food labels. Now, going on eight years and after much deliberation, the proposal should have come up for final vote by the AAFCO membership at the "mid-year" meeting in January. Assuming it does pass, it may take a few years for the new requirements to be phased in, but at least we'll know they're definitely coming.

The AAFCO Dog and Cat Food Nutrient Profiles and feeding trial protocols were last revised in 1996. An expert panel was convened shortly after the publication of the National Research Council (NRC) Nutrient Requirements of Dogs and Cats in 2006, with a charge to consider the NRC report and other new information in updating the AAFCO methods of nutritional adequacy substantiation. The expert panel report took a bit longer than anticipated, but the AAFCO Pet Food Committee was finally scheduled to act on the panel's recommendations at the mid-year meeting.

The FDA Amendments  Act of 2007 required, among other things, the promulgation of federal petfood labeling standards by September 2009. That deadline came and went, and while FDA has been promising to publish proposed regulations in response to FDAAA for several years, nothing has been made public to date. The matter is critical to future planning by petfood manufacturers, as the new FDA rules may or may not follow AAFCO models.

For example, there has been talk of instituting a "Nutrition Facts Box" format similar to what is required on human food labels, rather than a guaranteed analysis. Regardless, at this juncture no one knows. At this time FDA has reportedly finished its draft and it is out for review by other federal agencies. Perhaps 2013 will be the year we will finally get a glimpse at how FDA intends to proceed in this matter.

The Food Safety Modernization Act of 2011 represents a sea of change in food and feed regulation. Proposed rules for good manufacturing practices for foods for human consumption were scheduled to be published in the Federal Register in January. Hopefully, proposed regulations for animal feeds (including petfoods) will soon follow.

Regulations promulgated by  the US Department of Agriculture under the Organic Food Production Act of 1990 provide for labeling of foods for human consumption and feeds for livestock as "organic." However, there are no regulations specifically applicable to petfoods, which has caused much confusion in the market over the years. A task force under the National Organic Standards Board made recommendations as to suitable organic regulations for petfoods in 2008, but movement forward since then seems to have stalled. I was told recently that publication of proposed regulations will likely occur in spring 2013.

A California initiative that would have required warning statements such as "may be partially produced with genetic engineering" on petfood labels of products that were not documented to be GMO-free (free of genetically modified organisms) was narrowly defeated in November 2012. However, the grass-roots movement to require GMO labeling of foods is growing, so it would not be surprising to see similar initiatives to pop up in California or other states in 2013.

One issue most likely not  to go anywhere in 2013 is the matter of carbohydrate-related labeling. A working group under the AAFCO Pet Food Committee was set to recommend allowance of maximum dietary starch and sugars guarantees on petfood labels. However, before that could happen, it was discovered that the laboratory methods needed to verify such guarantees have yet to be validated, and further they were unlikely to be validated in the near future. Until that matter is resolved, it would be difficult to move forward on any petfood label recommendations for carbohydrates.

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