Petfood mislabeling is one of the top issues in the industry today. As consumers become more savvy about what their pets are eating, they look to—and depend on—product packaging to point them in the right direction. When something happens on the manufacturing end, such as the contamination of an ingredient, companies must maintain transparency to keep customer confidence. And when third-party studies are released calling the validity of product labeling into question, the industry must be able to respond.
Claims such as “grain-free” and “gluten-free” have no regulatory language as regards petfood, according to Dr. David Dzanis, DVM, DACVN, CEO of Regulatory Discretion Inc. and a writer and consultant on nutrition, labeling and regulation. In his September 2014 Petfood Industry magazine “Petfood Insights” column, Dzanis said that in spite of this, there are important factors to consider when making a claim in order to survive possible regulatory scrutiny.
For example, to truly pass the labeling test, petfood products claiming to be “grain-free” should avoid more than the obvious, US Food and Drug Administration (FDA)-defined cereal grains (barley, corn, rice, wheat, etc.). It’s also important to avoid any use of grain fractions (e.g., cornstarch, oat hulls, wheat middlings) and the use of any fats, oils or other ingredients derived from cereal grains in any manner could potentially compromise the truthfulness of the claim, said Dzanis.
“Gluten-free” is another label that has made the jump to petfood, but while it’s regulated for human food there is no accompanying petfood guidance. However, the human guidelines could be used by feed control officials as a basis for determination of whether a petfood claim is truthful, according to Dzanis, so it’s best to err on the side of caution and follow what is there, rather than ignore existing language and risk repercussions later.
A recent study published by California-based Chapman University highlighted where petfood product mislabeling might exist—and how easy it is to disseminate that information to consumers. Researchers in the university’s Food Science Program focused on commercial petfoods marketed for dogs and cats to identify meat species present (see Figure 1) as well as any instances of mislabeling. Of the 52 products tested, 31 were labeled correctly, 20 were potentially mislabeled and one contained a non-specific meat ingredient that could not be verified, said the researchers. Of the potentially mislabeled products, 13 were dog food and seven were cat food. Sixteen of the 20 contained meat species that were not included on the product label, with pork being the most common undeclared meat species. In three of the cases of potential mislabeling, one of two meat species were substituted for other meat species, said the report.
The study, published in the journal Food Control, could not determine the manner in which mislabeling might have occurred, or whether the mislabeling was accidental or intentional and at which points in the production chain it took place. While the petfood industry obviously knows what to look for, and can point to the important information missing, all consumers will see are the numbers and facts of such studies as presented. That’s why it’s so important to stay ahead of the game when it comes to labeling, and any accidental mislabeling.
In October 2014, Blue Buffalo faced a situation of accidental mislabeling due to an issue with one of its ingredient suppliers. A Texas plant owned by Wilbur-Ellis mislabeled some ingredients sent to the company’s customers, including Blue Buffalo. Wilbur-Ellis products labeled “100% chicken meal” may have instead contained poultry by-product meal, and Blue Buffalo took to the Internet in an open letter to its customers once it found out.
"Since this Wilbur-Ellis plant was the source of some of our chicken meal, we may have received some of these mislabeled shipments, and there likely are numerous other petfood companies who also received these mislabeled ingredients," said Bill Bishop, founder and chairman of Blue Buffalo. "The FDA has been informed of this situation, and you may rest assured that this mislabeling poses no health, safety or nutrition issue. And while this is comforting, since the health and well-being of our dogs and cats comes before anything else, the fact that any Blue Buffalo food could include a mislabeled ingredient is totally unacceptable. As a result, we have stopped doing business with this plant."
Even though the mislabeling on Wilbur-Ellis’s end had occurred and been corrected some months before Blue Buffalo was made aware of the situation, Bishop said he felt the company’s customers deserved to know. Transparency, Blue Buffalo believes, is key, especially when it comes to customer concerns about what their pets are eating.
But what are customers actually looking for on their petfood packaging? According to Lisa K. Karr-Lilienthal, extension companion animal specialist at the University of Nebraska-Lincoln Extension, Institute of Agriculture and Natural Resources, customers should be looking at the principal display panel (front of the label) and the information panel (immediately to the right of the principal display panel). She highlights the various the pieces of information consumers should hone in on when buying petfood, and what various nutritional information items and marketing claims really mean (see sidebar for link).
There are several considerations for manufacturers to focus on when creating petfood packaging:
- Reasonable representations of ingredients: While an image of rendered meal is unappetizing, it may be considered deceptive to show an image of a salmon fillet or boneless chicken breast if salmon or chicken meal is the actual ingredient. Instead, a middle ground must be found; for example, an image that conveys the nature of the source of the ingredient, rather than the ingredient itself (such as a whole, unprepared salmon, rather than the prepared fillet, to represent salmon meal).
- If it’s not in the product, it shouldn’t be on the label: Don’t put a fruit basket on the packaging if the product in question only contains some, and not all, of the fruits depicted in the image.
- Keep images in perspective: If cranberry is a minor ingredient in the product, or one of many ingredients that might exist in higher concentrations, don’t make a cranberry the primary packaging image.
Conservativism will go a long way toward staying on the right side of regulations. Whether labeling rules exist specifically for petfood already, or might simply be on the horizon, the best bet is to remain on top of consumer needs and ensure that the packaging conveys the most accurate representation of the product possible.