Dzanis: For me, as the AAFCO Pet Food Committee Advisor for
the American College of Veterinary Nutrition, the single
specific issue has been the College's proposed amendment of
AAFCO PF9 to require calorie content statements on all dog and
cat foods. The calorie content statement is arguably the most
important individual piece of nutritional information on the
label, not only for dogs and cats with "weight issues."
Requiring such information will help pet owners and
veterinarians choose the most appropriate product for an
individual animal. Petfood companies will benefit by creation
of a level playing field and generation of goodwill with
Ekedahl: The continued problem with exporting US-made
petfood into China, due to that country's registration
requirements. PFI has also been working to correct ingredient
prohibitions in a variety of countries stemming from the
discovery of BSE in North America. Domestically, PFI continues
to work with AAFCO and FDA on labeling and product claim
issues. We have spent a great deal of time combating unfair and
potentially damaging petfood tax proposals in some states, none
of which passed during last year's legislative sessions.
PFI's work with AAFCO on petfood labeling issues resists
those that are not needed to show the safety of petfood
productssuch as the request for mandatory calorie statements on
all petfood and treats.
Harrison: Review of Animal By-Products Regulation 1774/2002
(ABPR) has been an important issue for us (PFMA) over the last
few months, as it regulates the use of animal-based raw
materials for the production of petfood. Since ABPR came into
effect in 2003, industry and regulators have worked to reduce
the anomalies and inconsistencies in the existing legislation.
The European Union (EU) Commission has decided to rewrite the
PFMA has also been working with FEDIAF (the European Pet
Food Federation) on the Guide to Good Practice for the
Manufacture of Safe Pet Foods. The guide will support petfood
manufacturers in complying with requirements in Feed Hygiene
Regulation 183/2005 EC, which came into effect in January
The EU Commission has promised to deliver the first draft of
the review of the new Marketing Directive. This review will
impact the marketing of animal feed, including petfood, and it
is important we work with the Commission and national
authorities to achieve a workable solution. The industry is
concerned that certain ideas designed for farm animal feed
could have a negative impact on the labeling of petfood. We
need to ensure the unique position of petfood is recognized and
reflected in the labeling requirements.
Plant: One of the major concerns for new businesses in
Europe is the new set of EU Feed Hygiene Regulations
(183/2005/EC). The interrelationship between this regulation
and the Marketing Di-rective (79/373/EEC, as amended) requires
the plant/business registration/approval number to be included
in the statutory declaration.
The new regulations apply to all feed businesses (including
petfoods) that are manufacturing, importing, storing,
transporting and selling (excluding actual retailing) products,
while its predecessors (Directives 95/69/EC and 98/51/EC) only
applied to manufacturers handling particular additives or
premixes of certain additives (in petfoods).
The difficulty has been in identifying which registration or
approval number should be declared on the package. This is
particularly an issue when considering that many new and
existing businesses are importing products from plants not
previously requiring registration/approval under 95/69/EC or
98/51/EC. Further clarification of the rules for compliance
with EU Feed Hygiene Regulations for non-EU-based manufacturing
plants importing into the EU are expected during 2007.
Sellers: Issues include recordkeeping for the Bioterrorism
Act; the animal disposal effects of potential BSE rule changes;
glycerin and distiller's dried grains with solubles use in feed
and petfood; cloning; dioxin findings and conferences;
ingredient approval slowdown; and EU feed hygiene
regulationamong others. These issues play a role in market
demands, as well as potential and new regulation changes.
Syverson: First, the use of illegal/unapproved substances in
animal feed, rendering the product misbranded and/or
adulterated. A subset of this type of violation is the use of
approved substances for unapproved purposes. Second, claims
made in labeling, or established by the intended uses of
additives, which define the product as a drug where the
additive is not an approved new animal drugthereby rendering
the product misbranded and/or adulterated.
These issues are important because safety, efficacy and
utility are paramount to proper nutrition. Performance claims
and any indication that a petfood product is intended or
implied to treat, mitigate, prevent or improve conditions or
diseases where the product is not approved for these purposes
can lead to inappropriate customer diagnosis, misdiagnosis and
In many cases, basic consumer fraud is the issue where
misbranding occurs. Another aspect would be an issue for
responsible businesses. A manufacturer, distributor or
guarantor is incurring some risks in using unapproved
substances, or making inappropriate claims, with regard to
product liability and their relationship with their product
liability insurance carrier. Self preservation includes being
in compliance with the applicable regulations.
Wilder: Since 2003, when Canada had its first case of BSE,
many markets have been closed to Canadian petfoods, or if open,
have had rigorous export rules. As a result, Canada has made
some significant announcements during the past year, including
enhancements to our Feed Ban, which will include, for the first
New BSE import rules will require exporters to meet import
criteria that will include import permits and health
certificates. Since a very large volume of petfood comes into
Canada from the USA, the new requirements place significant
strains on both industry and government, which must take on a
new inspection role as well as sign health certificates.
The costs of meeting these new BSE rules are significant.
Also, the level of inspections and paperwork required will rise
dramatically. Whether these changes will result in a disruption
of trade is always a concern.
Dzanis: With publication of the new NRC recommendations,
revision of the AAFCO Dog and Cat Food Nutrient Profiles is
anticipated. New feed safety initiatives from AAFCO and FDA
will also greatly impact petfood manufacturers.
Ekedahl: We will no doubt see more in terms of organics,
natural products and novel materials. We are fortunate to have
Nancy K. Cook, PFI's vice president of technical and regulatory
affairs, chairing the group working on the USDA organic petfood
rules. As this group's work proceeds, PFI and its members will
have direct involvement in the formulation of the organic
rules, since this is such a growing segment.
Harrison: The Marketing Directive is the last major piece of
legislation to be reviewed under the European Commission's
white paper on food safety published in 2000. This review will
keep industry busy for the coming months or even years.
Thereafter, we will work to ensure existing legislation is
correctly enforced across Europe.
Plant: The development of new regulations will be an area of
major activity throughout 2007. Other major changes expected
are a rewrite of the Animal By-Products Regulation
1774/2002/EC. This could lead to a number of modifications to
definitions, particularly concerning the categories of raw
materials (I, II and III).
Other aspects that may change include the introduction of
new veterinary health certificates for the import of animal
materials and products containing animal materials into the
It is also anticipated that the procedure for applying for
the continued use of additives will be published. This will be
a major activity area over the coming years for those involved
in supplying or using additives in the manufacture of
Sellers: Other than the Bioterrorism Act, which is fully
implemented, all the others I mentioned will continue to be of
Syverson: Regulators see trends come and go all the time.
Regulation is primarily reactive. Laws are written and rules
are promulgated as the result of someone doing something that
they should not have. The degree to which the industry decides
to comply with the laws and regulations will determine what
happens in the future.
Wilder: The volume of regulatory issues we are dealing with
has risen so drastically in the last three years that there is
hardly a moment when we're not seeing something new and of
concern to our industry. Often, our industry is pulled into the
scope of regulations, even though all common sense would remind
regulators of the minimal riskand the long record of safetyour
products represent. Getting that message through often takes a
great deal of time and effort by our industry.
Petfood products are closely regulated by
government agencies around the globe. Regulations are
continually being created and modified, which can present a
challenge when it comes to keeping track of all the main issues
of concern. Petfood Industry asked several groups what
regulatory issues topped their list of current concerns and
why. We talked to private consultants, manufacturer's
associations, government agencies and industry associations to
get their input (see p. 32). Their answers to two questions
David Dzanis, DVM, PhD, DACVN: founder of Dzanis
Consulting and an independent consultant on veterinary
nutrition, labeling and regulation.
Duane Ekedahl: executive director of the Pet Food
Nicole Harrison: Pet Food Manufacturers' Association of
the UK (www.pfma.org.uk).
Terry Plant: founder of TA Plant Consulting.
Richard Sellers: vice president of feed regulatory and
nutrition for the American Feed Industry Association
David Syverson: chair of the Association of American
Feed Control Officials (www.aafco.org) Pet Food
Marty Wilder: executive director of the Pet Food
Association of Canada (www.pfac.com).