AAFCO’s Annual Meeting: New pet food rules are coming!

AAFCO's 2020 annual meeting resulted in several changes for pet food, from claims to labeling to feeding trials.

Although the meeting was virtual and shorter than in past years, plenty was accomplished at AAFCO’s 2020 Annual Meeting. | (Tashatuvango I Shutterstock.com)
Although the meeting was virtual and shorter than in past years, plenty was accomplished at AAFCO’s 2020 Annual Meeting. | (Tashatuvango I Shutterstock.com)

The Association of American Feed Control Officials (AAFCO) held its Annual Meeting virtually on August 5–7, 2020. Because of the online format, many of the committee sessions were shorter than typical. For example, the Pet Food Committee (PFC) session, which has often run 1.5 hours or more when conducted in person, was scheduled for only 45 minutes this time. Despite the restraints this put on discussion, some important advances were made.

Pet Food Committee decisions

The agenda items for the PFC session included a report on the progress made by the Human Grade Working Group. An amended feed term definition for "human grade" was accepted by the Committee and is moving forward. The exact verbiage should appear in the Committee minutes, but basically it opens the door to alternative, albeit equally rigorous, means of meeting AAFCO requirements for use of the term. The Working Group is still putting final touches on its proposed changes to the accompanying guidance document.

It is anticipated that these revisions will implement new procedures for certification of "human grade" pet foods by the Agricultural Marketing Service (AMS) within the U.S. Department of Agriculture (USDA).  Hopefully, more detailed information will be revealed at the next PFC teleconference in October 2020.

The Pet Food Labeling Modernization Working Group is moving forward as well. The report on proposed changes to ingredient declarations was accepted by the Committee. Also, reports related to labeling for nutritional adequacy and safe handling instructions were submitted for further consideration by the Committee. The report regarding the establishment of a "Pet Nutrition Facts Box" to replace the guaranteed analysis and calorie content statement on the label is expected by October 2020.

The PFC did accept a new guidance document pertaining to therapeutic dog and cat foods. The U.S. Food and Drug Administration (FDA) issued a Compliance Policy Guide on this matter in 2016 (CPG 690.150), but some confusion by both state regulators and the industry remains. The new guidance will closely mimic that by FDA, but with some changes to clarify AAFCO's perspective. In brief, it limits sales only under a valid veterinarian-client-patient relationship, and although it allows for information on indications for disease treatment, prevention and mitigation to be communicated to the veterinary professional, it restricts this information from appearing on the label or other consumer-oriented materials. This item now moves forward to the Board of Directors and membership at the next meeting.

Finally, there was brief discussion as to whether arachidonic acid was "essential" for purposes of making guarantees on dog food labels. The opinion expressed by FDA was that it was not essential, notwithstanding the fact that it appears by name in the AAFCO Dog Food Nutrient Profiles as it pertains to the maximum omega-6 to omega-3 fatty acid ratio requirement. No action was taken by the Committee. 

Model Bills and Regulations Committee actions

There was nothing on the Model Bills and Regulations Committee (MBRC) agenda pertaining to pet foods. However, a few of the items that were accepted and moved forward by the MBRC at the January meeting were presented for a vote by the full membership in the general session. Proposals for new pet food regulations clarifying how to incorporate ingredients into product variety names and percentage claims were approved and will appear in the next AAFCO Official Publication. The requirements for pet foods in meeting the 95%, 25%, "with" and "flavor" naming rules essentially remain the same. However, products labeled "100%___" or "All ___" are now limited to single ingredient products only (i.e., no exclusions for added water or trace additives).

With respect to claims where a specific percentage of an ingredient is declared, now all ingredients in the product must be considered in the percentage calculation. This includes any water added for processing, unless expressly excluded via a disclaimer accompanying the claim. For example, a product containing 50% beef, 40% water and 10% other ingredients could be claimed to contain "50% beef" or "83% beef, excluding water."

AAFCO membership votes  

The AAFCO membership also voted in new changes to the pet food regulations as they pertain to the nutritional adequacy feeding trial protocols (as well as to the language in the protocols themselves). Dog foods that are substantiated to be "complete and balanced" through feeding trials and are intended for puppies or all life stages must be based on trials using large breed dogs. Alternatively, if the trials are run using a small or medium breed (e.g., beagles), then the product is required to meet the calcium and phosphorus maximum levels as stipulated in the AAFCO Dog Food Nutrient Profiles for growth of large-size dogs. Normally, foods that are substantiated for nutritional adequacy by this method are not bound to meet the nutrient levels as dictated in the Profiles, but this is now the exception.

 

Briefly: Top 5 takeaways

  1. An amended definition for “human grade” has been accepted by the AAFCO Pet Food Committee, and these revisions will likely implement new procedures for certification of human-grade pet foods by the AMS.
  2. A report regarding the establishment of a "Pet Nutrition Facts Box" to replace the guaranteed analysis and calorie content statement on the label is expected by October 2020.
  3. The Pet Food Committee accepted a new guidance document pertaining to therapeutic dog and cat foods which mimics the FDA but clarifies AAFCO’s perspective.
  4. Proposals for new pet food regulations clarifying how to incorporate ingredients into product variety names and percentage claims have been approved.
  5. AAFCO membership has voted in new changes to pet food regulations as regards nutritional adequacy feeding trials: Dog foods substantiated to be “complete and balanced” and intended for puppies or all life stages must be based on trials using large breed dogs.
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