Using a publicly available “dog years” calculator, I recently determined that Sherman, my 94-pound Weimaraner cross, is the same age as me. Like many good friends, we enjoy sharing activities, including hours-long horse rides and miles of cross-country skiing. We even experience similar “senior years” joint and muscle aches when we push our limits on especially active days. And for both of us, in addition to exercise, our diets are an important part of life-long wellness.
But the similarity stops there. Policy choices at the U.S. Food and Drug Administration (FDA)’s Center for Veterinary Medicine (CVM) limit the use of many effective and safe wellness-supporting animal food additives in Sherman’s food. Some of the very same additives that I can legally and safely use to maintain my active body are not available for legal use in pet food, and the reason is policy, not statute or safety or efficacy.
Global availability of animal food additives
Animal food additives with proven efficacy and safety are available around the world to senior dogs like Sherman to support joint health, digestive health, cognitive function and general wellness. U.S. pet food manufacturers include many innovative products in commercial diets, but they are hampered by federal policy from the use of dozens of progressive ingredients to maintain pets throughout their lives and support them as they age. The manufacturer of Sherman’s food cannot use some of the beneficial ingredients available to pet owners in other countries.
Globally, animal food additives are marketed for their varied benefits to pets and livestock, including improving production, providing immunity and boosting the intestinal presence of immunoglobulins for mucosal health. As our understanding of health and nutrition progresses, U.S. pet food manufacturers and ingredient suppliers are developing new products that support longer, healthier lives for dogs and cats. Many ingredients with scientifically validated safety and efficacy are denied to animals in the U.S. but are available to humans. It is essential that we have a credible regulatory structure that keeps pace with these scientific developments, so that we can continue to advance the use of beneficial ingredients in our pets’ diets.
Narrow definitions hamper progress
U.S. pet food manufacturers have limited access to new developments in pet nutrition because of CVM’s narrow definition of what is considered a “food” versus a “drug.” Review of the Federal Food, Drug and Cosmetic Act confirms that animal food products can legally be considered both. Guide 1240.3605 in the CVM Program Policy and Procedures Manual is as limiting to permissible marketing claims for animal food ingredient labels as a stiff joint is to joyful play for a senior dog.
Specifically, Guide 1240.3605 states “…while the guidance is intended to assist in consistent or uniform regulation, it is not intended to be inflexible but is to be regarded as guidance to be followed in most instances for uniformity.” The wording implies flexibility, but the reality is it is as creaky as an achy hip on a cold morning.
Revising the guide to allow animal wellness claims in association with pet food and nutritional ingredients will move the U.S. toward policy adopted worldwide, and will support the health and well-being of long-lived and active pets. It is time to broaden the regulatory roadway for animal food marketing claims to accommodate the expanded understanding of the physiology of the gastrointestinal tract. CVM is long overdue in revisiting its narrow path for regulatory approval of animal food ingredients, and the well-being of companion animals is being hampered as a result.
The international market for feed additives is expanding, and some industry reports predict that the market will grow 6.1% between 2020 and 2027, reaching a value of US$56.22 billion by 2027. Sadly, due to outdated policies developed by CVM, the U.S. is not part of the exciting global market that supports healthy and active companion animals using proven animal food additives.
Modernizing the nearly 25-year-old policy at CVM is a top priority for the American Feed Industry Association (AFIA) and can be implemented without amending the Federal Food Drug and Cosmetic Act or FDA regulations. We shared our position during the FDA’s October 2022 listening session on the regulation of animal foods with certain types of claims, and we encourage pet food and pet food ingredient manufacturers to submit written comments to the FDA before November 17, 2022.
By updating Guide 1240.3605, CVM can modernize its approach for regulating claims for animal food ingredients and keep pace with science and the international community. Policy changes to allow these ingredients to be added to pet food diets will afford pet owners many more years of keeping pace with agile and energetic furry friends.
Learn more and comment on animal food claims regulations
Briefly: Top 5 takeaways
- Policy choices at the FDA’s Center for Veterinary Medicine limit the use of many effective and safe wellness-supporting animal food additives.
- Animal food additives are marketed for their varied benefits to pets and livestock, including improving production, providing immunity and boosting the intestinal presence of immunoglobulins for mucosal health.
- U.S. pet food manufacturers have limited access to new developments in pet nutrition because of CVM’s narrow definition of what is considered a “food” versus a “drug.”
- Revising current guidelines to allow animal wellness claims in association with pet food and nutritional ingredients will move the U.S. toward policy adopted worldwide.
- Modernizing the nearly 25-year-old policy at CVM is a top priority for AFIA and can be implemented without amending the Federal Food Drug and Cosmetic Act or FDA regulations.
