AAFCO mid-year report: new ingredients and label terms
Also on the agenda: modified GMPs and foods for pets other than cats and dogs
Because of budget restrictions for various states in the US, attendance was down at the Association of American Feed Control Officials' (AAFCO) mid-year meeting in January. (AAFCO holds its annual meeting every August, so the January one is referred to as mid-year.) But important work was accomplished, and people from the northern US who were able to attend reveled in the warmer weather of Tuscon, Arizona, USA.
Most of the pending items for the Pet Food Committee's (PFC) consideration are still being discussed by various working groups:
- The group working on regulatory language for calorie content statements and weight-related terms on dog and cat food labels is still deliberating;
- The expert panel reviewing the AAFCO Dog and Cat Food Nutrient Profiles and feeding trial protocols reported good progress but had nothing for public dissemination yet;
- The group looking at issues related to possibly exempting very small treat producers from rules or fees on local sales had no report; and
- The Food and Drug Administration (FDA) reported it is working daily on developing the new federal petfood regulations mandated by the FDA Amendments Act of 2007 but cannot release details until a notice is published in the Federal Register .
Guinea pigs, not pigs
An item introduced for PFC consideration was a proposal to change AAFCO PF4 with regard to guarantees for specialty petfoods-those for birds, reptiles, hamsters and other species besides dogs and cats. Currently, the regulation refers back to the AAFCO Model Regulations for livestock feeds, a poor fit when labeling a specialty petfood.
For example, minimum and maximum salt guarantees may make sense for cattle feed but not for a food for iguanas or guinea pigs. Expressing guarantees in terms of mg/lb while dog and cat food labels guarantee the same nutrients in mg/kg is also confusing.
The amendments to the regulation would allow specialty petfood guarantees to follow the same format and units as ones for dog and cat foods. This language actually was proposed a few years ago, along with other changes to PF4, but when that latter issue was dropped, so was this language. More discussion is expected at the annual meeting.
Edited GMP regulations
After several years of deliberation between the Model Bill and Regulations Committee (MBRC) and the Feed Manufacturing Committee, final editing of the Model Good Manufacturing Practice (GMP) Regulations for Feed and Feed Ingredients was completed and is moving to the AAFCO board. When eventually enacted, these regulations will impose additional requirements on animal feed-including petfood-manufacturers to comply with handling, processing, transportation and record-keeping provisions.
The recommendations from PFC regarding new regulations for raw milk products were accepted by MBRC. These now need to go to the AAFCO board and membership for final action.
The new rules will have minimal impact on petfood products. Rather, they are designed to address raw milk products that are sold under the guise of animal feed to elude state human health regulations but in reality are intended for human consumption.
New fiber source
Most of the items discussed in the Ingredient Definitions Committee (IDC) had little bearing on petfood except for ground pecan shell, which was previously reviewed and found acceptable by FDA as a source of dietary fiber. While accepted for use in all animal feeds, the item was proposed by a petfood company, so it is safe to assume this ingredient will be used at least in dog and cat food formulations in the foreseeable future.
With IDC's acceptance of the new definition, it still has to jump through a few hoops within AAFCO before it is officially recognized. However, it is anticipated that the definition will appear in the 2010 edition of the AAFCO Official Publication .
IDC also accepted a new feed term for dietary starch. At the last meeting, the feed terms for sugars and fructans were accepted. These all came from work by a group under the Feed Labeling Committee (see below), whose charge is to develop a means to allow for carbohydrate-related label claims.
Presently, AAFCO Policy Statement #1 discourages guarantees for carbohydrates or nitrogen-free extract as neither necessary nor meaningful for the purchaser's information. However, that policy was last amended in 1963.
The working group recommended the policy stand on the basis that "carbs" is a vague term encompassing a lot of different compounds. But these new feed terms pave the way for label claims relating to specific carbohydrates of interest in both equine and pet nutrition.
There was also a proposal to delete two definitions-ground soybeans (AAFCO #84.1) and soybean hulls (AAFCO #84.3)-on the basis that the Model Bill already exempts these commodities from the definition of commercial feed.
However, the universal concern among attendees was that these deletions would complicate what to call these materials when mixed with other ingredients to make a commercial feed. The proposal was defeated.
Use on labels
With definitions for dietary starch, sugars and fructans established, the working group under the Feed Labeling Committee will continue its deliberation on how these terms can be used on labels. For example, it will attempt to define criteria as to what levels in a product constitute low dietary starch/sugars and how claims are to be supported by guarantees. While the working group will address these issues both for petfoods and animal feeds (particularly horse feeds), the recommendations regarding petfoods will likely be passed through PFC before going to MBRC.