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on May 13, 2009

Re: Are your labels legal?

Natural and organic label claims, according to the Pet Food Institute

We at Pet Food Institute read with great interest two features in the March 2009 issue of Petfood Industry on labels. "Editorial Notes" and the article "Are your labels legal?" address some of the most complex and least understood aspects of petfood products, particularly the distinction between products identified as natural or organic.

Having worked within the Association of American Feed Control Officials (AAFCO) on petfood regulations for years and having chaired the National Organic Standards Board (NOSB) Pet Food Task Force, I am well versed in the distinctions between these two categories of products. Unfortunately, both articles miss the mark in their attempts to provide clarity.

Contrary to the assertion in the articles, there is a very clear and definite regulatory meaning for natural petfoods and ingredients. AAFCO established guidelines for natural claims for petfood and specialty petfood products some years ago. These guidelines are used by state regulators in their enforcement activities and can be found in the 2009 AAFCO Official Publication on page 135. The AAFCO guidelines for natural claims ensure consumers can feel confident that the petfood products and ingredients within products labeled natural are what they expect.

In contrast, no specific rules currently exist for organic petfood products. However, last November the NOSB accepted proposed rules for petfood that have been in development since 2005. The NOSB transmitted those rules to the US Department of Agriculture National Organic Program with the recommendation that federal rulemaking begin for organic petfood standards.

We anticipate federal standards for organic petfood products will be in place in the near future. Once implemented, those rules will add the term organic to the already long list of petfood labeling terms and conceptsincluding complete and balanced, natural, lite and tartar controlthat have strong regulatory meaning and enable consumers to buy with confidence.

Nancy K. Cook

Vice president, Pet Food Institute

Washington, DC, USA

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