The Association of American Feed Control Officials (AAFCO) shared its concerns for the current version of the proposed federal legislation that would reduce state oversight and authority to review the marketing or labeling of pet food.
H.R.7380, the Pet Food Uniform Regulatory Reform Act of 2024, or the PURR Act, was introduced in Congress on February 15, 2024, with the intention of creating a more streamlined federal regulatory process that would prohibit state governments from directly or indirectly establishing, maintaining, implementing or enforcing any authority or requirement relating to the marketing or labeling of pet food.
AAFCO is concerned the proposed legislation, as it’s currently presented, could have negative ramifications for consumer protection, reduce pet food label transparency and jeopardize the safe advancement of pet food products.
“State feed programs are the first line of defense protecting consumers from misleading or mislabeled pet food products,” said Austin Therrell, executive director of AAFCO. “Today, many state regulators proactively inspect pet food labeling before products hit the market to ensure that any marketing claims on the label or packaging are accurate and have the necessary scientific data to validate the statements. Under the new PURR Act, this important layer of consumer protection would completely go away.”
Lack of transparency
Most state feed programs in the U.S. support the Food and Drug Administration (FDA) by providing premarket reviews of pet food labels to ensure that permissible marketing claims are substantiated by data and are not false or misleading to the consumer. H.R.7380 would allow pet food manufacturers to distribute pet food products “self-proclaimed” as safe without the ingredients or nutritional statements being verified by a government authority prior to the product being available for sale and consumption.
AAFCO is also concerned with the “ingredients sometimes present” language currently included in H.R.7380, which states that manufacturers may use words on packaging such as “and/or,” “contains one or more of the following,” or other words indicating that an ingredient may not be present in the pet food. If passed, this would allow manufacturers to change or omit ingredients without disclosing this information to consumers.
“Many consumers purchase pet foods and treats based on the dietary needs or allergen requirements of their pets. Lack of transparency would leave consumers unable to know for certain which ingredients their pets may or may not be consuming, leading to potential health risks,” added Therrell.
Currently the FDA and state governments work in partnership under a national integrated food safety system that allows the FDA to utilize the expertise and resources of state feed programs to strengthen pet food safety inspections and protect consumers against unsafe, fraudulent or misleading advertising and labeling practices.
“While there are certainly opportunities to improve efficiency and bring more innovation to the marketplace, it must be done in a safe and transparent manner," said Therrell. "Engaging states and those intimately involved in the day-to-day oversight of pet food products is imperative to truly creating a modernized regulatory system."
