AAFCO: Their labeling requirements and the “Rules”
Written by Beth Laubenthal, January 2014.
This article is the second in a series of four focused on the pet food industry manufacturing process. This one discusses AAFCO (Association of Animal Feed Control Officials) and its pet food manufacturing guidelines. The others are: The Origins of the Pet Food Industry, The Rendering Process: From the Raw Materials to Your Store Shelves, and finally, Decoding Kibble: The Ingredients. None of this is intended to frighten anyone. The objective is to educate people, arming them with the information they need to make better food choices for their pets. If these articles are of any value to you, I hope you will share them and “pay it forward” for other pet owners!
There are two government agencies in the United States that are involved in pet foods labeling and regulation enforcements: the US Food and Drug Administration (FDA) and the Association of American Feed Control Officials (AAFCO). The AAFCO sets rules on everything on the label and the FDA enforces these regulations. It should be noted that pet food companies do not have to follow AAFCO protocols. They, do, however, have to follow their state laws, and most states institute the AAFCO guidelines.
According to AAFCO, “While most states follow AAFCO model regulations, exact language and interpretation may differ between states. While these documents offer guidance that are helpful in the vast majority of states, it is the responsibility of the manufacturer to ensure compliance with individual state requirements.”
AAFCO requires eight things to be labeled on every package of pet food, and each has its own definition and usage rules:
- Brand and Product Name and purpose
What species the product is intended for
Nutritional Adequacy Statement
Name and address of the manufacturer
List of Ingredients
When it comes to the name of the pet food, the AAFCO has regulations on the wording. It has to do with the amount of the particular ingredient listed in the name of the food. There’s the “95 percent rule,” “25 percent rule,” “3 percent rule” and “Flavor rule.”
Under the 95 percent rule “applies to products consisting primarily of meat, poultry or fish, and most often are canned products.” Examples for pet foods that fall under this rule include “Chicken Cat Food,” “Tuna Cat Food,” “Duck Cat Food.” If multiple meats are present, they must equal 95 percent of the total ingredients and be listed in order of the quantity present in the food. An example would be “Trout and Tuna Cat Food.” Trout would have to be in greater quantity than tuna. This rule only applies to animal products. “Chicken and sweet potato cat food” would not apply to this rule unless chicken comprised 95 percent of the ingredients. If water is added to the pet food, in order for this rule to apply, whatever animal product is listed on the pet food, it must account for 70 percent of the total ingredients and be listed in order of the quantity present in the food. An example would be “Trout and Tuna Cat Food.” Trout would have to be in greater quantity than tuna.
Dinners, entrees, platters, nuggets and formulas fall under the 25 percent rule. Under this rule, the ingredients (including non animal ingredients) must be at least 25 percent, but less than 95 percent, of the total ingredients (10 percent if water is added). “Chicken Dinner for Cats” is one such example. “Chicken and Rice Formula” is another example. When more than one ingredient is listed, the total of the ingredients must comprise at least 25 percent of the pet food. In addition, each ingredient listed must be at least 3 percent of the pet food. For instance, with “Chicken and trout entrée,” chicken could comprise of 23 percent of the total ingredients while trout comprises just 3 percent. The order that the ingredients are listed in the name of the food must follow the order that they are listed in the ingredient list (those more prominent are listed first). Furthermore, the primary ingredient does not have to be listed in the name of the food. For instance, “Chicken and tuna dinner for cats” could consist mainly of beef, corn or other ingredients.
According to the FDA, “The ‘3%’ or ‘with’ rule was originally intended to apply only to ingredients highlighted on the principal display panel, but outside the product name, in order to allow manufacturers to point out the presence of minor ingredients that were not added in sufficient quantity to merit a ‘dinner’ claim.”
The 3 percent rule covers foods such as “Cat food with chicken” where chicken makes up less than 3 percent of the total ingredients. It also covers foods such as “Chicken and Rice with Cheese.” In this case, the “chicken and rice” would fall under the 25 percent rule and the “with cheese” would fall under the “3 percent/with” rule.
The “Flavor rule” states that enough ingredient must be added to the pet food to make it taste like what the product claims to be a flavor of. For instance, “Chicken flavored cat food” must taste like chicken – though it may not have any real chicken in it. In fact, “Chicken flavored cat food” may not contain any animal product in it at all as long as it tastes like chicken.
In terms of listing the purpose of the product on the package, the manufacturer must indicate if the product is meant to be used as a treat or be fed as a “food item.” The product must also indicate what species (cat, dog, horse, gerbil, etc) it is intended for. Usually, at the bottom of the package, there is a weight or quantity statement as required by the AAFCO standards.
Guaranteed Analysis looks at the nutrients in pet food. Only four nutrients are required by the AAFCO: crude protein (minimum amount), crude fat (minimum amount), crude fiber (maximum amount), and maximum water content. “‘Crude’ refers to the analysis method, rather than the quality of the nutrient,” according to the AAFCO.
Claims of vitamins (“good source of vitamins A and D”) must be backed up in the Guaranteed Analysis table. If no claims are made, the manufacturer may voluntarily list any other nutrients. The nutrients are determined by independent laboratories.
The Nutritional Adequacy Statement must state if the pet food is a “complete and balanced” food for different age groups. An example of a statement is “Formulated to meet the nutritional levels established by the AAFCO cat food nutrient profiles for all life stages.” Another statement could read, “A good source of complete nutrition according to AAFCO standards for adult cats.”
All pet foods must have feeding directions. It must state to feed your pet x amount of food for every x amount of weight. For instance, “Feed a half cup for every 5 pounds of body weight.” Canned foods might say “Feed 3/4 can for every 4 pounds twice daily.”
The name of the manufacturer and address must be listed on the package. The street address does not necessarily have to be listed as long as the city and state are listed. Often times, manufacturers will list a phone number for any questions or comments a pet owner might have.
Lastly, the most mystifying part of the labeling requirements: the ingredient list. At first glance, it is easy to read. It’s simply a list of ingredients found in the pet food. When looked at closely, it can be very confusing to understand what the ingredients actually are and what their purpose is in the food.
The order in which ingredients appear on a pet food label are by weight: the heaviest ingredients are listed first. The rest of the posts in this series will examine that label.
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Created 02/17/14; Updated 08/11/14