Is it time to ‘modernize’ pet food labels?

A newly formed group indicates the potential for changes down the line.

Andrea Gantz
Andrea Gantz

The current format of pet food labels in the United States has been around for many decades. The Association of American Feed Control Officials (AAFCO) Pet Food Committee was first convened in the 1960s, after which the basic labeling requirements took shape. Yes, there have been many updates and additions to these requirements over the years, but essentially, the fundamental layout that all pet foods must follow today has remained intact.

Some believe this format can be improved in order to make it easier for the purchaser to read and understand the information presented on the label. With that in mind, AAFCO formed the Pet Food Labeling Modernization Working Group in August 2016 to consider proposals for change and make recommendations back to the Pet Food Committee. The working group is still in its initial stages of discussion, so there is nothing much on which to report at this juncture. However, it is an interesting exercise to ponder the possibilities. 

Potential impact of the Pet Food Labeling Modernization Working Group

One aspect that may be impacted is the guaranteed analysis. Some have looked at the Nutrition Facts box (as required on human food labels under the Nutrition Labeling and Education Act of 1990 and more recently updated) as a source of inspiration. The regulation promulgated under the Act prescribes a very precise format for declaring nutrient content in a clearly delineated, easily identified section on the label. Many of the specific requirements are not directly transferable to pet foods, as the nutritional requirements, and hence the information that is most important to convey to the consumer, is different. 

For example, cholesterol content of the food, while important to human health, would be of far less benefit when dealing with dogs and cats. Still, because the person purchasing the pet's food is likely to be the same one buying food for his/her human family members, a discernible section of the label that emulated the Nutrition Facts Box would be easy to locate and identify. The Nutrition Facts box on human foods also provides information regarding calorie content, so perhaps the calorie content statement can be joined with the guaranteed analysis in this newly envisioned section.

Another aspect with the potential for change is the ingredient declaration. The US Food and Drug Administration (FDA) regulations impose the names, order and format of declared ingredients. Because these labeling requirements are under federal law, it would be difficult for AAFCO to deviate too far from what's in the Code of Federal Regulations already. However, the FDA regulations for human food labeling do allow some laxity in how ingredients are declared compared to those for animal feed labeling, so perhaps there is room to incorporate some of those aspects to make the declaration a little better to parse and comprehend. To date, FDA has not held up to its charge from Congress to promulgate pet food-specific labeling regulations as required under the FDA Amendments Act of 2007, anyway, so perhaps some revisions can be made to the FDA regulations so there is no conflict with AAFCO.

Statements regarding intended use and nutritional adequacy also have potential for refinement. Right now, a purchaser may have to hunt the fine print on the label to find a rather long and perhaps confusing statement regarding the life stages for which the product is nutritionally suitable. When searching through product at a retail outlet, it may be tedious flipping around packages to try and locate a product appropriate for the individual pet. Perhaps a bold, obvious and succinct indication of intended use on a panel of the label that is normally viewed by the consumer at time of sale would be very helpful in that regard.

Some aspects likely won't change much, if at all, such as the net content declaration and the manufacturer's or distributor's name and address. There hasn't been any pressing concern regarding need for improvement, and their requirements and format are fully engrained in FDA regulations, anyway. However, other sections may be changed or even added, such as the feeding directions, handling directions (specific to the type of product), etc.

Any changes still a long way off

In any case, there is no need for the pet food manufacturer to ramp up for extensive label changes in the near future. With luck, the working group may be able to provide some of its recommendations at the "mid-year" AAFCO meeting in January 2017. Even if there is consensus on the concepts, it will take a long time to draft, refine and enact new model regulations, then allow a reasonable grace period for manufacturers to implement the drastic revisions needed. Remember, AAFCO is notoriously "deliberate" in its process. Implementing the new calorie content statements took eight years, while revising the AAFCO Dog and Cat Food Nutrient Profiles took even longer. Now, I would anticipate some time before anything discussed at this juncture came to fruition.


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