Pet Food Ingredients / Pet Food Regulations
On February 5, 2013

New calorie regulations approved by Association of American Feed Control Officials

Group holds “mid-year” meeting, passes 95% Rule amendment and expands xanthan gum use

["Approval of the calorie content statement regulations culminates eight years of debate.", "The new uses of xanthan gum will require further AAFCO action before it becomes official."]

The Association of American Feed Control Officials (AAFCO) held its "mid-year" meeting January 22-24 in Albuquerque, New Mexico, USA.

By far the biggest news was the vote in the General Session to approve the proposed changes to AAFCO Model Regulation PF9 that would require calorie content statements on ALL (not just "lite" and "reduced calorie") dog and cat food labels. Other new requirements include the need to express calories in terms of both per-kilogram and per-common unit (e.g., cans, cups, pieces) and to identify the method of determination ("calculated" vs. "fed").

Gone, though, are the expressed requirements for analysis of at least four production batches from which to derive the calculated value and the need to limit values declared for those determined by the feeding trial method to within 15% of the calculation method value. Removal of these restrictions should make it easier for companies to comply and states to verify.

Approval of the amended  calorie content statement regulations culminates eight years of sometimes very lively debate. Still under discussion is the matter of an appropriate grace period for compliance. The Pet Food Committee and the board of directors both offered a recommended delay of enforcement action for 18 months for new products and three years for existing products.

The distinction is whether the clock starts when the amended rule is published in the 2014 AAFCO Official Publication (as the committee recommended) or now (as the board prefers). The merit of the board's proposal was questioned on procedural grounds. The day after the General Session, the Pet Food Committee voted to reiterate its recommendation. The issue will likely be resolved at the annual meeting in August.

Another long-term matter  hopefully coming to fruition in 2013 is the revision to the AAFCO Dog and Cat Food Nutrient Profiles and feeding trial protocols. The Pet Food Committee accepted the expert panel recommendations (formed in 2007) for changes to both documents with minor amendment. Among the changes to the profiles will be new minimum requirements for the omega-3 fatty acids alpha linolenic acid (ALA), eicosapentaenoic acid (EPA) and docosahexaenoic acid (DHA) for growth and reproduction in both dog and cat foods.

This means that label guarantees for these fatty acids will no longer need to be disclaimed as "not recognized as essential." If these new changes clear the board and full AAFCO membership in August as expected, they will appear in the 2014 AAFCO Official Publication.

An American Pet Product  Association-sponsored amendment to the "95% Rule" was accepted by the AAFCO Pet Food Committee on its first pass. The amendment would remove the ingredient restrictions that currently limit product names under the rule to those containing animal, poultry or fish-based ingredients. This would make the 95% Rule consistent with other AAFCO naming regulations and allow companies to call out a broader range of ingredients in the product names. It still has to go through the Model Bill and Regulations Committee and then the board and membership before the amendment becomes enacted, though.

In other activities, the Ingredient Definitions Committee accepted an additional use of xanthan gum in canned dog and cat foods not to exceed 0.25%. Previously, by federal regulation its use was restricted to calf milk replacers and liquid feed supplements for ruminants, although the Food & Drug Administration (FDA) already allows very broad use in human food products. FDA indicated its support for this new use in dog and cat foods, though it doesn't intend to amend its animal feed regulation. This would be similar to the AAFCO ingredient definition for taurine, which provides for uses in dog and cat food despite the fact that FDA never amended its food additive regulation to allow for the use of taurine in feeds other than for chickens. The new uses of xanthan gum will require further action by AAFCO before it becomes official, though.

Also within the Ingredient Definitions Committee was discussion of a proposed header for the Feed Terms section of the Official Publication. AAFCO is concerned that some of the terms, particularly those related to ingredient parts or fractions, are being used to generate novel ingredient names, e.g., "pea protein" and "wheat gluten."

Language is being drafted to clarify that this practice is not the intended use of the feed terms and that any such ingredient name derived in this matter should be AAFCO-defined or otherwise sanctioned for use in animal feed. Care has to be taken not to exclude process feed terms (e.g., "ground") that legitimately can be used in conjunction with existing definitions, or to exclude use of an ingredient that may not be defined by AAFCO but has a common or usual use in foods/feeds, e.g., cornstarch.

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