I think we can agree that the pet food marketplace has become further muddied and confusing for consumers because companies and brands have been channel jumping from pet specialty to grocery and vice versa. In the past, I think most consumers believed that if they wanted a premium product, they needed to go to a pet specialty retailer. Today, that is not the case in our ever-changing marketplace. As a result, I thought it would benefit both the industry and consumers to write a series of blogs posts that help people understand pet food product claims and how they are supported.
The first in my series covered scientific-based claims and the information needed to support them. Apart from a few universities and larger companies, most companies do not have the resources to develop new scientific claims through research and innovation. As a result, many companies utilize puffery claims for points of differentiation (e.g., farm to table).
The next two blogs in my series focused on ingredient-based claims for points of differentiation. The second discussed animal raising claims: how to obtain the claim and how some claims can be misleading to the consumer because they imply the animal was humanely raised (e.g., farm-raised). Lastly, we discussed the use of natural claims in the pet food industry and how they are defined by AAFCO and consumer perception. If you recall, the definition of natural does not mean the ingredient or food excludes chemical treatments, GMOs or that it is organic.
The last blog post was a good transition into this discussion, organic and non-GMOs in the pet food industry. First, we will focus on organic claims.
AAFCO (2017) defines organic as:
“A formula feed or a specific ingredient within a formula feed that has been produced and handled in compliance with the requirements of the USDA National Organic Program (7 CFR Part 205).”
Likely, you are asking what is the US Department of Agriculture (USDA) National Organic Program (7 CFR Part 205)? For a feed or a specific ingredient to be certified USDA organic, it must meet key criteria set forth by the government. Additionally, individual states may have their own certification program; however, they must meet the criteria per USDA guidelines. The key component is the development of an organic production and handling system program. The program must include and follow the USDA guidelines for land, soil, pest and weed management, origin of livestock, livestock feed and healthcare, etc. For more detailed information, refer to the link above.
Lastly, I would be remiss if I didn’t point out that USDA certified does not equal "made in the USA" (205.300).
For those of you who read my animal raising blog post, you will notice that I did not make any mention of organic being equal to animals being humanely raised. Livestock living conditions (i.e., humanely raised) falls under amendment 205.239, which has been delayed until May 14, 2018. It is also important to point out that this amendment will likely not pass in May 2018 since USDA has requested that the animal welfare program be withdrawn as a requirement. Therefore, you should make sure your humanely raised certifications fall under the the third-party, non-government certifications discussed in my past blog.
Many pet and human food companies (and bloggers) will tout that organic is healthier for people because no chemicals or drugs are utilized in the production of their crops or raising of the animals. This is simply untrue. Let me refer you to the National List of Allowed and Prohibited Substances section 205.601 (synthetic substances allowed for organic crop production), 205.603 (synthetic substances allowed for use in organic livestock production) and 205.605 (Nonagricultural (nonorganic) substances allowed as ingredients in or on processed products labeled as “organic”). I am not sure about you, but last time I checked, aspirin, vaccines, atropine and ivermectin (a parasiticide) were all chemicals or drugs and can be used per the USDA organic certification program.
In section 205.2, USDA clearly states that genetically modified organisms (GMOs) are not considered compatible with organic production. Now, it is important that they look at GMO as genetic engineering and not traditional or selective breeding. Why is it important to note this nuance? By definition, GMO is an organism (plant or animal) whose genetic makeup has been altered in some way. To the purist, selective breeding for desired traits would be considered GMO. Therefore, many purebred dogs would be considered GMOs because they may have been bred for desired traits (e.g., color and size). Those who truly understand the science refer to GMO as genetic engineering (think DNA splicing) that occurs in a non-natural setting like a laboratory.
Lastly, non-GMO does not mean the plants or animals were raised without pesticides, hormones or antibiotics utilized in traditional farming practices.
Similar to humanely raised, the government does not certify that ingredients are non-GMO. As a result, third-party, non-government organizations establish the criteria, perform the audits and provide the certification. It is important to recognize that the third parties simply certify that you do not use GMO ingredients; it does not mean that your product is GMO free. In fact, some organizations like the Non-GMO Project recognize the potential for cross contamination and have set animal feeds at a threshold < 5%. Seems like a high threshold to me, especially if I was paying for a high-priced food with the project’s logo.
As I discussed in my last blog, natural does not equal organic or non-GMO in the US. Having said that, not all of the world has our same point of view. For example, the EU’s definition does include non-GMO in their definition of natural (not organic). Figure 1 simplifies the differences between the EU and US. As you can see, the EU has stricter guidelines for natural (no chemical treatments and non-GMO ingredients) than the US (allows the use of chemical treatments and GMO ingredients).
In short, it depends. How much does your consumer want to pay and what is the popular belief today? I know this doesn’t really answer the question; however, as an industry, we follow human food consumer trends. I think most veterinarians and nutritionists would be the first to say that there is no compelling study that says organic, non-GMO, gluten free, grain free (or pick your latest fad) is healthier for the dog or cat.
That being said, it is important that when consumers purchase your products that claim non-GMO, organic, humanely raised or sustainable, you provide them with the correct messaging and transparency to go along with the certification. If you take anything away from my blog, I hope it is the ability to pose deeper questions to your suppliers, manufacturers and your procurement team.
Every certification has its loopholes and for valid reasons; however, when you make blanket statements like “organic doesn’t use chemicals or drugs,” you’d better be able to back it up. Ultimately, your message needs to truthful and not try to mislead consumers, because it will ultimately hurt your brand in the future.
Figure 1: The EU has stricter guidelines for natural pet food product claims than does the US.
Next time we will discuss, “Navigating through product claims, part 5: What does a product name tell you about the food?” If there are topics you would like to have discussed, feel free to comment below or reach out via LinkedIn: www.linkedin.com/in/ryanyamka.
Association of American Feed Control Officials. 2017 Official Publication. http://www.aafco.org/Publications
Buff et al., 2014. Natural pet food: A review of natural diets and their impact on canine and feline physiology. J. Anim. Sci. 92:3781–3791.
European Pet Food Industry Federation, 2011. Code of good labelling practice for pet food. http://www.fediaf.org/press-area/news/8:fediaf-new-nutritional-guidelines-cats-dogs.html