AAFCO holds annual meeting, part 1: Pet Food Committee

The Pet Food Committee covered a lot of ground, including regulatory considerations and the formation of a new working group, at the latest AAFCO annual meeting.

(FurryFritz | AdobePhoto.com)
(FurryFritz | AdobePhoto.com)

The 2019 Annual Meeting of the Association of American Feed Control Officials (AAFCO) was held August 5–7, 2019, in Louisville, Kentucky, USA. As always, there was a flurry of activity and spirited discussion during the Pet Food Committee session. Notwithstanding the large number of items on the agenda, though, few definitive decisions were reached.

Proposed changes and eliminations

Several proposed changes to the Model Pet Food and Specialty Pet Food Regulations were discussed but no actions were taken at the meeting.

One proposal would revise the feeding trial protocols and associated regulations to account for the unique nutritional requirements for growth of large size dogs. This proposal would address the same issue as the revisions to the AAFCO Dog Food Nutrient Profiles did a few years ago. For feeding trials, though, a practical consideration is that there is a paucity of large breed dog colonies available to test products for nutritional adequacy. The proposed alternative to a feeding trial using a suitably large breed, then, would be to conduct the feeding trial using a more available albeit smaller breed, but with the provision that the food must also meet the calcium and phosphorus restrictions as stipulated in the Profiles for growth of large size dogs.

The other proposals would affect the product naming rules and ingredient percentage claims. These proposals will be further discussed and likely voted on during the Committee teleconference in the coming month or so. 

A proposal coming from the Model Bills and Regulations Committee (MBRC) would eliminate Statement for Uniform Interpretation and Policy (SUIP) #27, which provides exemption from labeling and registration requirements for certain dog chew products under specified conditions. The goal of MBRC is to move many of the current SUIPs into more enforceable formats. It would be relatively straightforward to work the labeling exemptions from SUIP #27 into the Model Pet Food Regulations, but the registration exemption would present a much greater challenge. The proposal was sent back to MBRC for further work.

Group work updates

A number of updates on the activities of various groups were provided to the full Committee. The Human Grade Working Group is continuing its pursuit of an arrangement with the U.S. Department of Agriculture's Agricultural Marketing Service (USDA AMS) to provide for third-party certification of claims. The Pet Food Labeling Modernization Working Group has received feedback from a second round of consumer focus groups. This information will go back to the subgroups for further consideration. The AAFCO Website Review Working Group did not provide an update except to promise a report by the "mid-year" meeting in January. 

Trade shows and conferences

There was news that the AAFCO-sponsored exhibit booth at Petfood Forum 2019, as well as the AAFCO Pet Food Labeling Workshop held in conjunction with Forum, were successes. The hope is to be able to repeat these functions in the future. 

An update was also provided with regard to the National Conference on Weights and Measures (NCWM). As reported previously (see Petfood Industry magazine, July 2019), NCWM had proposed a change in its rules to stipulate that all dog chews be declared in terms of weight; i.e., that count alone for items such as rawhides was not sufficient.

Existing U.S. Food and Drug Administration (FDA) regulations already require net weight statements when count alone is inadequate in advising the purchaser of the contents of the package. NCWM was pondering an amendment to the rule to provide for exceptions (effectively similar to FDA's regulation), but as reported at this meeting, that change was defeated and the rule was enacted as originally proposed. Although enforcement actions by weights and measures regulatory bodies are not anticipated before 2021, manufacturers not in compliance may start receiving notices of violation in the near future.

New working group for pet food labeling

One potentially major development from the Pet Food Committee was the formation of a new working group. Its charge is to deliberate on possible new regulations, guidance and/or policy to address the labeling of dog and cat foods intended for management of certain disease conditions under the direction of a veterinarian (i.e., "therapeutic diets"). Presently, FDA provides some guidance on the labeling and distribution of such products (see link in sidebar), but with minor exception in the Model Pet Food Regulations as they relate to nutritional adequacy and feeding directions, AAFCO is largely silent. This lack of direction has reportedly caused confusion among both state regulators and the industry. What recommendations come out of this working group will be interesting.

Of course, actions of AAFCO outside of the Pet Food Committee also impact the industry. The November column will report on some of the other activities at the AAFCO Annual Meeting.


Briefly: Top 5 takeaways

  1. Changes to the Model Pet Food and Specialty Pet Food Regulations were discussed, but no actions were taken.
  2. The Human Grade Working Group is pursuing an arrangement with the USDA AMS to provide for third-party certification of claims.
  3. Enforcement actions by weights and measures regulatory bodies are not anticipated before 2021, but manufacturers not in compliance may start receiving notices of violation soon.
  4. A new working group has been formed in the Pet Food Committee to deliberate on possible new regulations addressing the labeling of pet foods intended for management of certain therapeutic diets.
  5. FDA Compliance Policy Guide Sec. 690.150 Labeling and Marketing of Dog and Cat Food Diets Intended to Diagnose, Cure, Mitigate, Treat or Prevent Diseases
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