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Pet Food Regulations
0910PETinsight2
During its 100th anniversary meeting, AAFCO unveiled a new logo.
on October 1, 2009

AAFCO marks 100th year, passes new regulations

New model GMP regulations will have the greatest impact on petfood

In August the Association of American Feed Control Officials (AAFCO) commemorated its 100th anniversary with its annual meeting, held in Washington, DC, USA, the same location as the first meeting in 1909. The meeting included events to mark the milestone, the introduction of a new AAFCO logo and important votes, such as passage of several new model regulations.

New manufacturing regulations are key

The General Session is where the AAFCO membership has the opportunity to vote on all the issues put forth by the various committees during the previous year. New Model Pet Food Regulations regarding labeling and other requirements for raw milk products distributed as petfood were passed, along with changes to the requirements for net content declarations to more closely follow the Fair Packaging and Labeling Act .

These amendments will appear in the 2010 AAFCO Official Publication.

However, the vote of greatest impact on the petfood industry was the passage of new Model Good Manufacturing Practice (GMP) Regulations for Feed and Feed Ingredients, which set forth requirements for manufacturing, storage and transport of feeds, sanitation of facilities and equipment and other procedures necessary to minimize the risk of adulteration. I'll discuss the effect of mandatory GMPs on the manufacture of petfoods in detail in next month's column.

Pet Food Committee work

Reports from several working groups under the Pet Food Committee noted continued progress. These include:

  • The group deliberating on the American College of Veterinary Nutrition proposal, introduced in 2005, that would mandate calorie content statements on all dog and cat food labels;
  • An expert panel reviewing the AAFCO Dog and Cat Food Nutrient Profiles and feeding trial protocols, which is nearing completion of at least some sections; and
  • A working group looking at means to facilitate compliance by small treat manufacturers with state registration and labeling requirements, now reorganized to overcome a slow start and hoping to make significant progress in the coming months.

It is anticipated each of these groups will have recommendations for the committee to consider in time for its next meeting in January 2010.

The committee also discussed proposed changes to the requirements for guarantees for specialty petfoods to make them more akin to the requirements for dog and cat food guarantees. Presently, guarantees for specialty petfoods must follow the format required for livestock feeds, which can be confusing for the manufacturer, regulator and public.

A question was raised regarding the requirements for the placement of the non-essential nutrient guarantees, and a suggested amendment to the proposal would affect foods for both specialty pets and dogs/cats. Also discussed was the definition for the feed term "natural" and whether irradiation should be considered one of the permitted processes for foods so claimed. Both of these issues are now open for comment to be discussed further in January.

Only act: camelina meal

Usually, the Pet Food Committee has at least one or two proposed regulations for the Model Bill & Regulations Committee (MBRC) to review, but not at this meeting. In fact, for the first time in recent memory, MBRC had no active items on its agenda! The Ingredient Definitions Committee acted on a few procedural items and one new definition (camelina meal), but its actions at this meeting will not have a great impact on petfoods.

The Carbohydrate Working Group under the Feed Labeling Committee did not reach a consensus regarding carbohydrate-related claims for petfoods, so no recommendations were forwarded to the committee for consideration at this meeting. The group did make recommendations for new regulations regarding "less (sugars, dietary starch and/or fructans)" claims for horse feeds.

Also, motions were made to consider mandatory guarantees for carbohydrate fractions on both horse feed and petfood labels. However, after some discussion, all motions were sent back to the working group for further deliberation.

The Feed Manufacturing Committee accepted recommendations to amend the Model Bill to better coincide with the existing provisions in the Federal Food, Drug and Cosmetic Act with regard to exported animal feeds and petfoods. Under this amendment, products that did not necessarily meet US requirements but were expressly intended for export only and met the requirements of the importing country would not be considered adulterated or misbranded. This amendment still has to undergo several more steps in the AAFCO process before it can come to a vote by the membership.

Other items of note

AAFCO is considering establishing an executive director position to provide management in support of organizational functions and represent the association in its external affairs. The January 2010 "mid-year" meeting will be held in warm and (usually) sunny Redondo Beach, California, USA, very close to Los Angeles.

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