Few people are inclined to describe the Association of American Feed Control Officials' (AAFCO) Model Regulations for Pet Food and Specialty Pet Food (more succinctly, Model Pet Food Regulations; or MPFR) as particularly "reader-friendly." Efforts to foster greater understanding and more uniform interpretation of the MPFR have been made over the years. An expansive "rewrite" of the regulations to regain a more logically flowing structure and more understandable wording to the document was promulgated in 2000. The AAFCO Pet Food Committee (PFC) also developed a "label review checklist" to provide people with a more convenient means to critique a label in step-wise fashion for potential regulatory discrepancies.
The latest effort of the PFC to clarify and provide further guidance to state feed control officials, the petfood and related industries and others on the labeling rules is a thorough guideline that explains the intent of each regulation and other labeling policies in detail. During development of the guideline, the document took on the euphemistic name of "Pet Food 101." However, as the document was finally published, it was entitled with the more officially sounding AAFCO Pet Food and Specialty Pet Food Labeling Guide (heretofore, the "Guide").
What's in the Guide?
The first major portion (Section II) of the Guide is an iteration of the MPFR as they appear in the AAFCO Official Publication. However, unlike in the Official Publication, each section of regulation is followed by some explanatory text. This may be as simple as a brief re-wording of the regulatory verbiage to clarify its basic intent, or it may go into considerable detail as to the practical application of the regulation.
Section III of the Guide focuses on the means for substantiation of nutritional adequacy, explaining the differences between an "unqualified" and "qualified" claim and the requirements for substantiation under each of the three methods (nutrient profiles, feeding protocols and product family membership). Copies of the model affidavits for use by a company to affirm compliance with the methods stipulated in the regulations appear at the end of the section.
Section IV is entitled "Pet Food Label Claims." This includes continued discussion of claims expressly subject to regulation under the MPFR, such as the use of ingredient names in product names, how to make calorie content statements and the requirements for comparative claims (e.g., "higher in protein") and descriptive terms such as "lite" and "less fat." However, it also discusses matters that may appear in sections of the AAFCO Official Publication other than the MPFR (e.g., "natural" claims, plaque/tartar control claims, criteria for when additional guarantees are required) or that do not appear in the Official Publication at all (e.g., drug claims, "organic" labeling, "human grade," hairball control claims).
"Nutrients" (Section V) and "Ingredients" (Section VI) describe the differences between "essential" and "nonessential" nutrients and "recognized" versus "unrecognized" ingredients, respectively.
Section VII provides discussion on Policy Statement 27, which allows for exemption of rawhide, bones and other chew and toy products from meeting state labeling and registration requirements, explaining when the exemption applies and perhaps more importantly, when it does not.
Section VIII provides information on AAFCO's website. Section IX includes a copy of the aforementioned label review checklist. The checklist also appears in the Official Publication.
The last section (Section X) is a compilation of fictional labels intended to illustrate practical application of the regulations. Each label is accompanied by pertinent excerpts from the label review checklist to show where the labeling in that case has gone awry from the rules.
What's not in the Guide?
The Guide makes clear that it is to be used in conjunction with the AAFCO Model Bill, AAFCO Model Regulations and MPFR. While the MPFR do appear in the Guide, the others do not. Also, ingredient definitions and other information pertinent to petfoods may not be in the Guide. So, the Guide cannot stand alone, and you may likely need the Official Publication on occasion to answer a particular question.
While the Guide discusses issues involving methods for nutritional adequacy substantiation, it does not provide any direct information about the methods themselves or how to determine if in fact a product has been properly substantiated. Don't expect the Guide to be able to answer all your questions about petfood labeling. Although far more explanatory than what is in the Official Publication, it can't be expected to cover all possible scenarios.
How is the Guide to use?
For some topics, guidance is smattered throughout the document. For example, if someone wished to find information on how to properly declare nutrient guarantees, it might be in Section II, but could also be in Section IV, Section V, Section IX or Section X. Much of the information in the various sections is redundant, but occasionally a new facet on the same subject may be introduced in one section that's not in the others. Thus, unless one seeks and finds all places in the Guide where a particular topic is discussed, some potentially vital information may be overlooked. On the other hand, information on some very important topics (e.g., cat food urine pH claims) may be hidden in places where it is not expected.
To me, then, the Guide might be more useful with better organization. At this juncture, trying to reorganize the Guide may not be practical; however, the addition of a subject index and/or greater cross-referencing would go far in resolving problems with use of the Guide.
What else do I need to know?
A member of industry expressed to me a concern about the Guide with which I share, namely, that the Guide might be perceived and enforced by some as de facto regulations. For sake of clarity, then, it must be noted that what is contained in the Guide is not legally binding and does not create or confer any rights to either the feed control official or the industry. In other words, interpretations and opinions in the Guide are not directly enforceable.
The Guide reflects the current thinking of the PFC as to its interpretation of the MPFR and associated matters. This is extremely helpful information necessary to help avoid many potential labeling pitfalls. However, it is not always the only viable interpretation. In fact, while I concur with the vast majority of opinions in the Guide, even a summary perusal revealed several statements with which I very respectfully disagree. Confounding the problem is the fact that few states adopt the MPFR verbatim. Even subtle changes to the wording of a particular regulation may dramatically affect its ultimate interpretation.
How do I get the Guide? Is it worth it?
The easiest means of obtaining a copy is through AAFCO's website (www.aafco.org). At US$125 per copy, the Guide appears to be the most expensive publication in AAFCO's library. Granted, you may not have to order a new copy every year, but eventually it will become out of date and will need revision or replacement.
In conclusion, the AAFCO Pet Food and Specialty Pet Food Labeling Guide can help answer a multitude of questions about the labeling rules that either aren't clear from reading the Official Publication or simply aren't even addressed in print elsewhere. I'd recommend the Guide to anyone who asked.
Considering AAFCO is an all-voluntary organization, the great efforts members of the PFC put into the work are obvious, admirable and highly appreciated. Although a bit pricey, even if it saves you one call to your friendly neighborhood regulatory consultant, that could make up for the cost right there.
By Lindsay Beaton
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By Lindsay Beaton