Some of these smaller industry players worry their interests and concerns are not sufficiently known to regulators.

In early October, I attended the H.H. Backer Christmas 2008 Show in Chicago, Illinois, USA. Like other pet trade shows such as Global Pet Expo (GPE), the main function of the Backer show is for pet product companies to showcase their products to prospective buyers from retail firms. As I understand it, Backer is a bit smaller than GPE, but walking up and down the rows and rows of exhibit booths was still a daunting task.

While I enjoyed the exhibits tremendously, that was not my purpose there. Rather, I was participating in a meeting of the American Pet Products Association (APPA). For those who do not recognize the acronym, until recently this organization was known as the American Pet Products Manufacturers Association (APPMA). The name was changed recently to better reflect the association's diverse membership.

Fish tanks to petfood

I have been serving as the petfood consultant to APPA for the past couple of years. While its membership includes manufacturers and distributors of many different types of pet products-from fish tanks to bird toys to dog beds to cat jewelry-a significant proportion of the membership deals with petfoods, treats, chews and supplements. With all the recent developments in the regulatory arena concerning both the US Food and Drug Administration (FDA) and the Association of American Feed Control Officials (AAFCO), many of these members had questions about how these issues will affect their businesses. That was the purpose of the meeting during the Backer show.

The meeting also was to serve as a forum to discuss matters of mutual concern regarding the current regulatory environment. Many, but not all, APPA members can be classified as small to medium-sized companies. Some of these smaller industry players worry their interests and concerns are not sufficiently known to regulators; hence these companies' needs may not be considered as governmental bodies ponder the issues.

And AAFCO, too

The meeting was well attended, with representatives of about 30 APPA member companies participating. I gave what I predicted would be a short presentation on emerging regulatory issues, but with all the questions, my 16 PowerPoint slides took nearly an hour to get through! This included discussion of the FDA Amendments Act of 2007 (FDAAA) and how it could affect petfood manufacturing and labeling. Tangential to this issue was discussion of the FDA Animal Feed Safety System and other matters such as FDA's pending guidance regarding glucosamine and chondroitin sulfate.

AAFCO was not left out of the discussion. FDA and AAFCO have signed a memorandum of understanding (MOU) wherein FDA has assumed greater authority over the AAFCO feed ingredient definition process. AAFCO is also developing regulations to institute good manufacturing practices (GMPs) for all animal feeds, including petfoods and treats. (Currently, only medicated feeds and canned foods are subject to GMPs.)

The discussion also covered:

  • The pending revision of AAFCO's Dog and Cat Food Nutrient Profiles ;
  • Potential changes in feeding trial protocols; and
  • Possible mandatory calorie content statements for dog and cat foods.

During and after the presentation, the attendees were all engaged in the discussion. Other subjects included the Federal Trade Commission's guidance for "made in USA" claims and the US Department of Agriculture's National Organic Program. One hot topic was "no by-product" claims-specifically some APPA members recently experiencing more inclusive interpretation by many state feed control officials regarding what constitutes a by-product.

Next steps

There is thought of continuing this forum in the future, including possibly a similar meeting during GPE in February 2009. Depending on the timing of any new developments regarding the FDAAA or other matters, the group may use this meeting to evaluate and express its views on these issues.

APPA members can obtain a copy of the slide presentation by contacting APPA's regulatory group . Non-members can visit APPA's new website .

Background reading
FDA Amendments Act of 2007
FDA and AAFCO MOU