Pet Food Regulations

AAFCO update

There was considerable argument regarding development of a Feed Safety Program document.

Last month I discussed the American College of Veterinary Nutrition's petition to the Association of American Feed Control Officials (AAFCO) to amend the Model Pet Food Regulations regarding calorie content statements on petfood labels. This was not the sole issue of interest at the AAFCO Annual Meeting. On the contrary, a number of new regulations and other actions taken by AAFCO at the meeting will likely impact the petfood industry.

Pet Food Committee

The AAFCO Board and membership accepted the Committee's recommended amendment to the "Guidelines for Tartar Control Claims." Hopefully, the added language, which should appear in next year's Official Publication, will clarify that ingredients added to a petfood with the claimed intent of affecting tartar, plaque or breath odor by chemical (vs. mechanical) means require approval as drugs or letters of no objection from the US Food and Drug Administration. Thus, even if a substance is generally recognized as safe (GRAS) for another purpose in petfood, it is not necessarily GRAS when intending to affect dental health.

Proposed changes to the Model Regulations and the Model Pet Food Regulations were also accepted to clarify a discrepancy between the two in how guarantees should be declared. In some states, petfood labels that bear a claim relating to calcium content would be required to declare both minimum and maximum calcium guarantees, as is required for livestock feeds. The amendments would allow petfoods to declare minimum or maximum calcium, but not both. This item was moved to the Model Bill and Regulations Committee for further consideration.

The Pet Food Committee considered a report from the group working on a means to delineate when guarantees to support claims for nutrients or ingredients are required, and perhaps more importantly, when they are not required. The current thought of the working group is the development of a policy statement vs. amendment of the regulations. No action by the Committee was taken, but the working group continues its deliberations. The Committee also revisited a previous discussion regarding the need for calorie statements on petfoods indicated for "weight management" or similar terms, but do not make direct calorie-related claims such as "lite" or "less calories." Since this item shares some aspects with the ACVN petition that is also under consideration, no action was taken.

Model Bill and Regulations Committee

The AAFCO Board and membership accepted the Committee's proposal to amend the Model Pet Food Regulations to include the words "informal review sanctioned" as one means by which food additives or drugs can be allowed for use in petfoods. This amendment doesn't really do much as far as changing current procedures, but makes the language consistent with that which is already in the Model Regulations for livestock feeds.

The item from the Pet Food Committee (minimum/maximum guarantees) was discussed at the subsequent Model Bill and Regulations Committee session. After lengthy and somewhat contentious deliberation, the Committee voted not to accept the proposal, but rather to recommend it be sent back to the Pet Food Committee for further work. If memory serves me, this is at least the second, and perhaps the third time the Committee has rejected proposed amendments that would address discrepancies between the livestock feed and petfood regulations. Hopefully, the matter can be resolved in the near future.

Ingredient Definitions Committee

Quite a few feed definitions were considered at the General Session, but perhaps the one of most relevance in petfoods is that for "Fructooligosaccharide." The change from "tentative" to "official" status was accepted. In the process, the abbreviation "FOS" was deleted from the definition, which means manufacturers can no longer use it in lieu of the full name in the ingredient declaration.

The proposal to change the status of "Dried chicory root" from tentative to official was accepted. It now has to go to the Board and membership before that change in status is reflected in the Official Publicationthough on a practical basis it doesn't affect its currently-allowed use in petfoods.

Of even more relevance to petfood manufacturers is the Committee's acceptance of the proposal to amend the definition for "Taurine," specifying allowed use in dog foods. Prior to this change, some regulators had acted against dog foods containing this ingredient. Again, this matter must go through the Board and membership before it becomes official, but in the interim, the inclusion of taurine in dog foods should not cause much consternation among feed control officialsprovided claims relate only to nutritional function and not cardiac health or other "drug" benefits.

Other committees

The working group under the Feed Labeling Committee is still deliberating on a means to allow for carbohydrate-related claims on labels. Through interaction with the Laboratory Methods and Services Committee, the working group hopes to determine what guarantees should and can be made on the label to support a claim. While the focus at this time is on equine products, it is hoped that similar considerations for petfoods will eventually be addressed.

There was considerable argument in the Feed Manufacturing Committee session regarding its development of a Feed Safety Program document. This proposed program, which will definitely affect the way petfood companies manufacture their products in the future, was reportedly drafted without any industry inputa matter about which industry representatives expressed their significant disappointment. Hopefully, as it is such a critical issue, there will be more interaction between the parties as this document is developed further.

The Enforcement Issues Committee held a session just for AAFCO members prior to its "open" meeting. Unfortunately, without understanding what was said in the closed session, comments made to industry weren't very revealing (e.g., "Glucosamine was discussed"). There was some public interaction between the Committee and the National Animal Supplement Council on the latter's plans for member training and promises to clean up labeling, promotional materials and advertisements for products manufactured by its members.

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