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Pet Food Regulations
on September 1, 2015

AAFCO accepts revised Dog and Cat Nutrient Profiles

Definitions, ingredients, available educational resources discussed during Denver meeting

The Association of American Feed Control Officials (AAFCO) held its annual meeting in Denver, Colorado, USA on August 3–5, 2015. As usual, many items affecting pet foods were discussed.

After eight years of deliberation, the revised AAFCO Dog and Cat Food Nutrient Profiles (along with some amendments to the Model Regulations to accommodate different maximum allowed calcium levels for large-sized puppies) were accepted by the full membership and will be published in the 2016 Official Publication. Some of the changes in the Profiles were discussed in previous columns (see Petfood Industry magazine, April and May 2015). Pet food companies will have one to two years (for new and existing products, respectively) from time of publication to confirm compliance with the new requirements or reformulate and/or relabel accordingly.

A notable topic of discussion during the Pet Food Committee session was in regard to use of the term "human grade." Currently, AAFCO offers minimal insight on what it considers appropriate use of the term on its "Business of Pet Food" website (www.petfood.aafco.org), so many who want to make the claim remain confused as to what is acceptable. Because of the substantial documentation required to verify the claim, the Food and Drug Administration (FDA) had been offering pre-market reviews of petfood labels from the industry. This effort helped state feed control officials as much as if not more than pet food companies. 

However, FDA announced at the meeting that it would no longer accept any further submissions of this type, as it considers other matters to be of higher priority. Rather, it is now solely left up to states to determine acceptability of "human grade" claims and whether they are properly substantiated. An AAFCO working group has been formed to develop more substantive guidance for states and industry, but these types of deliberations can take at least a year, and sometimes much longer. In the interim, pet food manufacturers can expect even less consistency in enforcement when it comes to these types of claims.

Also discussed (although this time in the Enforcement Committee session) were some recently published scientific studies showing high incidence of inaccuracies in ingredient declarations on pet food labels. This includes both failure to find evidence of the inclusion of declared ingredients as well as the detection of protein sources from species not declared on the label. Some of these studies were previously discussed (see Petfood Industry magazine, December 2014). After the open discussion, the Committee went into private session, so it is difficult to know what conclusions, if any, were drawn by regulators. However, increased scrutiny of the veracity of ingredient declarations by feed control officials in the future should be anticipated. 

On the ingredient front, amendments to the pulse fractions (e.g., protein, starch, fiber) definitions now list lentils as well as peas as acceptable sources. New amendments to these definitions to provide for additional processes (e.g., water separation) are moving forward. Also, the Ingredient Definitions Committee passed the proposal to delete the definition for feed-grade fat product (AAFCO #33.5). This definition was intended as a means to allow for fat ingredients that would substantially meet another existing definition but would not meet all its specifications. For example, a vegetable oil that failed to meet the limit on unsaponifiable matter but was otherwise suitable for use in animal feed could be offered for distribution under this alternative name.

 However, FDA reported of gross misuse of the terminology, with some suppliers distributing fats and oils from sources that definitely would not be suitable or safe but whose origins were obfuscated by use of the name. While an appeal was made to modify the definition to exclude this from happening but still allow for legitimate use of the ingredient name, the Committee voted to accept the motion to delete the definition. While this matter still has to go before the full membership before action is taken, this move may have serious consequences. At minimum, there would need to be a scramble for establishment of new definitions to cover legitimate sources of fat products or the industry could face a serious shortage of available fat ingredients.                                                                                                                                           

 In other pet food news, the process of updating the "Pet Food and Specialty Pet Food Labeling Guide," which augments the Official Publication and explains many aspects of pet food regulation in detail, is nearing completion and likely will be open for comment by the January "mid-year" meeting. AAFCO is also planning a Pet Food Labeling Workshop in conjunction with the annual meeting in 2017. Pet food manufacturers will find both the Labeling Guide and the Workshop to be invaluable in helping ensure compliance with current labeling requirements. Also, similar in intent to the "Business of Pet Food" site for small or new petfood companies, AAFCO has gone "live" with a new web site ("AAFCO Talks Pet Food") designed to help address consumer questions and concerns. Industry members are encouraged to provide a link to the site (http://talkspetfood.aafco.org/).    

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