At the Association of American Feed Control Officials’ (AAFCO) mid-year meeting held in Anaheim, California, USA, on January 23, 2018, the Pet Food Committee was supposed to get an update on a working group’s progress of their review of the current AAFCO Feeding Protocols (to account for growth of large-size dogs). Unfortunately, due to the US federal government shutdown in January, the group members from the Food and Drug Administration (FDA) were not present, so the committee had to move on to the next topic.
For those of you who have been keeping track of the discussion, the AAFCO nutrient profiles for large-breed puppies were updated to include a maximum of 1.8 percent calcium on a dry matter basis (reduced from 2.5 percent). I am unsure what research went into the determination of the 1.8 percent maximum for calcium; however, AAFCO and FDA are trying to determine if pet food companies need to substantiate large-breed growth feeding claims with a specialized growth trial into adulthood.
The question I pose is, what would the study look like to make it valid and worthwhile? Additionally, would companies be required to perform large-breed adult maintenance studies (versus ones being conducted on Beagles today)? For most people this may not have any meaning, but for companies that are making complete and balanced claims based on feeding trials, this means they would need to redo studies using large-breed puppies.
For me, it begs a different question: Do AAFCO feeding trials matter? Before we answer that question, let’s dive into some packaging claims.
Variants of complete and balanced claims on packaging
Most pet foods in the marketplace make the claim that they are complete and balanced. Some exceptions are treats, toppers and therapeutic foods, which carry a claim that states they are for intermittent or supplemental feeding. For those foods that make complete and balanced claims, there can be three different definitions that appear on the packaging. These include:
- Product X is formulated to meet the nutritional levels established by the AAFCO Dog (or Cat) Nutrient Profiles for Life Stage Y.
- Animal feeding tests using AAFCO procedures substantiate that Product X provides complete and balanced nutrition for Life Stage Y.
- Product X provides complete and balanced nutrition for Life Stage Y and is comparable in nutritional adequacy to a product which has been substantiated using AAFCO feeding tests.
AAFCO requirements for complete and balanced claims
The claims above do have to meet certain guidelines set forth by AAFCO. Per AAFCO’s model regulations for pet food PF7, a food can qualify for being “complete and balanced,” “perfect,” “scientific” or “100% nutritious” (or similar variants) when the food meets at least one of following:
- Formulated — the nutrient requirements for the food set forth by the AAFCO-recognized nutrient profile for the appropriate life stage(s).
- Feeding studies — is substantiated by completion of the AAFCO recognized animal feeding protocol for the appropriate life stage(s).
- Comparable — is nutritionally similar to a “family” lead product that has been substantiated by completion of the AAFCO recognized animal feeding protocol for the appropriate life stage(s). Plus, there are additional requirements to qualify the product as a family member, which can vary by each state feed official.
Do consumers actually read these statements?
Sometimes it is difficult for consumers to find these statements on pet food packaging since they are not always located in the same place. They are usually found near the guaranteed analysis or the feeding guidelines, and often in smaller print, versus the romance copy, claims and pictures depicting the ingredients in the food. With that being said, the pet food industry and AAFCO, along with FDA, are working on solutions to modernize the pet food label to make this information more visible and more reader friendly.
Do consumers care how complete and balanced is substantiated?
Since I would be hard-pressed to find a pet food that carries the substantiation using a family lead, I will focus on formulated and testing only. If you ask whether consumers care if the pet food is formulated to meet the guidelines or if the food passed feeding tests, I believe you would get various answers depending on the consumer.
Some companies tout that their product is better because all their foods have passed AAFCO feeding trials. The same companies will justify the importance of these feeding studies by stating they can make a food made of leather to meet the AAFCO nutrient guidelines; however, the food wouldn’t be nutritious or help an animal thrive. If those companies can do these types of formulations, then yes, they should test all of their foods, and I may question their knowledge of ingredients, nutrition, digestibility and animal welfare policy.
Having said that, there is a wealth of knowledge in publications such as Small Animal Clinical Nutrition, 5th ed., Nutrient Requirements of Dogs and Cats and peer-reviewed studies, just to name a few. As a result, many companies can formulate appropriate foods for dogs and cats that they thrive on without the need for animal testing. Additionally, given consumers today, I believe they have greater awareness of animal welfare and do not believe in testing for testing sake.
Throughout my career, I was always taught to think about the 3R’s of research and animal welfare: reduction, refinement and replacement. Now, there may be some skeptics who still believe AAFCO testing makes a food more superior. Does it? For those who do not know what is required for the claim, let’s discuss the components of the actual AAFCO feeding trial. For purposes of our discussion, I will focus on canine adult maintenance.
What is an AAFCO feeding protocol?
Like most research feeding studies, the minimum feeding protocol for approving an adult maintenance claim for dog food has certain criteria which include:
- Minimum of eight healthy dogs at least 1 year of age and of optimal body weight.
- The test diet should be fed throughout the entire trial versus a concurrent control or colony average.
- Test duration is 26 weeks.
- Dogs can be fed ad libitum (free-fed) or based on energy needs.
- Clinical observations and measurements include:
a. Individual daily consumption
b. Individual body weight at beginning, weekly and end
c. Hemoglobin, packed cell volume, serum alkaline phosphatase and serum albumin measured at end of test
d. Complete physical examination at beginning and end of test
e. 25 percent of the dogs can be removed during the trial for non-nutritional reasons or poor intake
6. Success or failure determination:
a. Any nutritional signs of nutritional deficiency or toxicity — results in failure
b. All dogs not removed for non-nutritional reasons or poor intake must successfully finish the study (remember, this could be six dogs per 5e above) — results in success
c. No individual dog loses more than 15 percent body weight and the group average does not lose greater than 10 percent body weight — results in success
d. Hemoglobin greater than 14.0 g/dL, packed cell volume is greater than 42 percent, albumin is greater than 2.8 g/dL and serum alkaline phosphatase is less than 150 U/L — results in success
AAFCO protocol in layman terms
The above can seem a little overwhelming to someone not accustomed to seeing protocols. To simplify, the protocol only requires the six animals to pass based on physical observations, not losing weight (obesifying is OK) and four blood parameters during a period of six months. For this reason, the AAFCO guidelines do not find any of the three complete and balanced substantiations (formulating, feeding or family) to be more superior than the other.
Given the consumer’s and industry’s concerns for animal welfare, I again question: Do AAFCO feeding trials matter? The answer is simply no, unless you are the formulator who knows how to make leather meet the nutritional guidelines.
AAFCO feeding trials in summary
Since I have been in the pet food industry for roughly 20 years, I have been able to see how the industry and marketplace have drastically changed over time. I have had the opportunity to formulate dry kibble foods, wet foods, meat rolls, freeze dried foods, human grade foods and treats. During those times, there was a place for testing when there was a lack of knowledge of ingredients and effects of processing; however, many things have changed since then. Unfortunately, some pet food companies’ philosophies have not kept up with the times and still use this as a point of differentiation, which ultimately have allowed newcomers and challengers to appear.
Having said that, there is a place for feeding trials when we begin to investigate various nutrient levels that go beyond today’s knowledge or to test new non-essential nutrients and ingredients in our foods. Unfortunately, it is not the archaic AAFCO feeding protocols the industry currently utilizes today. While the Pet Food Committee is considering making a “special” AAFCO feeding protocol for large-breed dogs because they set a new maximum of 1.8 percent calcium (not sure why), they should consider making the test something more meaningful, with actual nutritionist and veterinarian input.
If all consumers and veterinarians knew exactly what the current feeding tests are, I bet they would at the very least be disappointed and likely follow up with additional questions. What is your animal welfare policy? Why do you stop there with your measurements? Why don’t you make your own study with the current protocol as the foundation?
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. 2018 Official Publication.
MS Hand et al., Small Animal Clinical Nutrition, 5th Edition. 2010, Mark Morris Institute.
National Research Council. Nutrient Requirements of Dogs and Cats. 2006, National Academies Press.