interpreting pet food labels pgs 309 - 316. pet food labels are regulated at two levels. the federal...

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Interpreting Pet Food Labels

pgs 309 - 316

Pet food labels are regulated at two levels. The federal

regulations are enforced by the FDA and the state regulations are enforced by the AAFCO

PRODUCT NAME:What is in a name?

Product names are dictated by the percentages of named

ingredients. The AAFCO has four primary percentage rules.

These rules pertain to the animal based protein only.

THE 95% RULE:This applies to products

consisting primarily of meat, poultry or fish.

These foods have simple names such as Beef for Dogs or Tuna Cat Food. At least 95% of the

product must be the named ingredient (by weight), not

counting the water added for processing. Counting the added water, the named ingredient must

still comprise 70% of the product.

If the food name includes a combination of protein ingredients

then the two together must comprise 95% of the total weight. The first ingredient named must

be the one of higher predominance.

Eg. Chicken and beef dog food must contain a higher % of

chicken

The 95% rule only applies to ingredients of animal origin. Grains can not be used as a

component of the 95% total. For example, a Lamb and Rice dog food would be misnamed unless

the product contained at least 95% lamb.

THE 25% RULEIf the named ingredients comprise

at least 25% of the product but less than 95% then the pet food name must include a qualifying

descriptive term such as “dinner, platter, entrée, nuggets or

formula” Therefore “Beef Dinner for Dogs”

only has to contain ¼ beef

The primary ingredient is not always the named ingredient so Chicken Formula Cat Food may contain more fish than chicken.

THE 3% RULEor the “with” rule

This rule was intended to apply to ingredients that appeared outside the product name.

Therefore label may include a sideburst is at least 3% of that

ingredient is added.

AAFCO also allows the term “with” indicating that 3% of that ingredient has been added. This

can become confusing for the consumer because Cat Food with Tuna (3% tuna) is very different from Tuna Cat Food (95% tuna).

THE FLAVOR RULE

With this rule a specific percentage is not required BUT

the product must contain an amount sufficient to be detected.

With respect to flavors, pet foods often contain “digests” which are

material treated with heat, enzymes and/or acids to for

concentrated flavors. Therefore Chicken Flavored Cat Food may not actually contain any chicken

at all

Any statements such as “improved” or “new” are only permitted for 6 months and then must be removed.

Any comparisons or preference statements are permitted for one year and must be substantiated by evidence. To remain on the label after one year, the claim must be resubstantiated.

Eg. 3 out of 4 pet owners prefer Huff n’ Puff Dog Food over the leading brand. I must be able to document this.

WHAT ELSE HAS TO PRINTED ON THE BAG?

ALL cat and dog food labels must contain eight pieces of

information

#1 Product Name

#2 Designation or Statement of intent.

This identifies the food as dog or cat food.

#3 The Net Quantity Statement.

This tells you how much product is in the bag.

#4 The Manufacturers Name and Address

Not all labels include a street address, but by law it should be listed in either a city directory or

telephone directory

#5 Ingredients ListAll ingredients are required to be

listed in order by weight including their water content.

This is an important point because meat is very high in

moisture.

So in comparing foods:Pet food A may list “meat” as its first

ingredient and pet food B may list corn first and “meat meal” second.

Meat is approx 75% water but in meat meal, water and fat have been removed, so it is only 10% moisture. When comparing

the foods on a dry matter basis (mathematically removing the water) Pet food B has more animal source protein.

#6 Guaranteed AnalysisThe label must state the

minimum percentages of crude protein and crude fat and the

maximum percentages of crude fiber and moisture.

The “crude” term itself refers to the specific method of testing

the product, NOT to the quality of the nutrient itself.

Crude protein measures the total nitrogen content of a product and, from that, estimates the amount of protein within that product. Crude protein measurements include nitrogen from proteins as well as from non-protein nitrogen sources 

Guarantees are declared on an “as fed” or “as is” basis this

represents the amounts present as it is found in the can or bag. This doesn’t have much bearing

when the guarantees of two products of similar moisture

content are compared.

To convert a nutrient guarantee to a dry matter basis divide the nutrient guarantee by the dry

matter percentage.Eg. Let’s compare the crude

protein content of dry vs canned food

Crude protein = 8.0%

Moisture = 74% (dry matter = 26 %)

8 / 26 x 100 = 30.7

Crude protein = 37%

Moisture = 9.0 % (dry matter = 91%)

37 / 91 x 100 = 40.6

It is very important to check the moisture percentage. The

maximum percentage for pet food is 78% EXCEPT for

products labeled as stew, in sauce, in gravy etc These

products may contain as much as 87.5% moisture

#7 Nutritional Adequacy Statement

The AAFCO mandates that “complete and balanced” pet

food must be substantiated for nutritional adequacy by one of

two means

The first method is for the pet food to contain ingredients formulated to provide levels of nutrients that meet an established profile. Presently, the AAFCO Dog or Cat Food Nutrient Profiles are used. Products substantiated by this method should include the words, "(Name of product) is formulated to meet the nutritional levels established by the AAFCO (Dog/Cat) Food Nutrient Profiles." This means the product contains the proper amount of protein, calcium, and other recognized essential nutrients needed to meet the needs of the healthy animal.

The alternative means of substantiating nutritional adequacy is for the product to be tested following the AAFCO Feeding Trial Protocols. This means that the product, or "lead" member of a "family" of products, has been fed to dogs or cats under strict guidelines and found to provide proper nutrition. These products should bear the nutritional adequacy statement "Animal feeding tests using AAFCO procedures substantiate that (name of product) provides complete and balanced nutrition."

Regardless of the method used, the nutritional adequacy statement will also state for which life stage(s) the product is suitable, such as "for maintenance," or "for growth." A product intended "for all life stages" meets the more stringent nutritional needs for growth and reproduction. A maintenance ration will meet the needs of an adult, non-reproducing dog or cat of normal activity, but may not be sufficient for a growing, reproducing, or hard-working animal. On the other hand, an all life stages ration can be fed for maintenance. Although the higher levels of nutrients would not be harmful to the healthy adult animal, they are not really necessary. Occasionally a product may be labeled for a more specific use or life stage, such as "senior" or for a specific size or breed. However, there is little information as to the true dietary needs of these more specific uses, and no rules governing these types of statements have been established. Thus, a "senior" diet must meet the requirements for adult maintenance, but no more.

* Ensure consumer protection* Safeguarding the health of animals and humans* Providing a level playing field of orderly commerce for the animal feed industry.

The Association of American Feed Control Officials (AAFCO) is a voluntary membership association of local, state and federal agencies charged by law to regulate the sale and distribution of animal feeds and animal drug remedies.

#8 Feeding InstructionsFeeding directions instruct the consumer on how much product should be offered to the animal. At minimum, they should include verbiage such as "feed ___ cups

per ___ pounds of body weight daily." On some small cans, this may be all the information that can fit. The

feeding directions should be taken as rough guidelines,

a place to start.

If a calorie statement is made on the label, it must be expressed on a "kilocalories per kilogram" basis. Kilocalories are the same as the "Calories" consumers are used to seeing on food labels. A "kilogram" is a unit of metric measurement equal to 2.2 pounds.

1 kilogram = 2.2 lbs

Many pet foods are labeled as "premium," and some now are "super premium" and even "ultra premium." Other products are touted as "gourmet" items. Products labeled as premium or gourmet are not required to contain any different or higher quality ingredients, nor are they held up to any higher nutritional standards than are any other complete and balanced products.

Other Label Claims

The term "natural" is often used on pet food labels, although that term does not have an official definition either. For the most part, "natural" can be construed as equivalent to a lack of artificial flavors, artificial colors, or artificial preservatives in the product. As mentioned above, artificial flavors are rarely employed anyway. Artificial colors are not really necessary, except to please the pet owner's eye. If used, they must be from approved sources

Natural" is not the same as "organic." The latter term refers to the conditions under which the plants were grown or animals were raised. Farmers who grow organic produce and meat don't use conventional methods to fertilize, control weeds or prevent livestock disease. For example, rather than using chemical weedkillers, organic farmers may conduct more sophisticated crop rotations and spread mulch or manure to keep weeds at bay. Any product labeled as organic must be USDA certified.

Meat is defined as “the clean flesh of slaughtered animals and

is limited to ..striated muscle with or without the

accompanying and overlying fat and the portions of skin, sinew,

nerve and blood vessels that normally accompany the flesh.

Meat meal is rendered product from mammal tissues exclusive of any added blood, hair, hide

trimmings, horn, manure, stomach and stomach contents. Therefore during the rendering process it could contain parts of animals we may not think of as

meat.

The non-rendered, clean parts, other than meat, derived from slaughtered mammals. It includes, but is not limited to, lungs, spleen, kidneys, brain, livers, blood, bone, partially defatted low temperature fatty tissue, and stomachs and intestines freed of their contents. It does not include hair, horns, teeth and hoofs. It shall be suitable for use in animal food. If it bears name descriptive of its kind, it must correspond thereto.

Meat By Product:

Chicken By-Product Meal - consists of the ground, rendered, clean parts of the carcass of slaughtered chicken, such as necks, feet, undeveloped eggs and intestines, exclusive of feathers, except in such amounts as might occur unavoidable in good processing practice.

Byproduct is not necessarily a negative thing.

Once an animal has been carved into specific cuts (ribeye, t-bone, fillet etc)

The remaining animal cuts are process together and called by products. It is generally better to look for by products that come from a single species.

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