AAFCO August 2012 Report

Thanks to an amazing and heartwarming outpouring of support from so many wonderful people, last weekend I was able to attend the 103rd Annual Convention of AAFCO (Association of American Feed Control Officials), the organization that makes the rules about how pet food is made. These rules are embodied in a book called the “OP” (Official Publication) that is updated every year.

AAFCO itself has no regulatory authority, but its members, the feed control officials (FCOs), do enforce the rules on animal feeds and pet foods in their own jurisdictions. AAFCO comprises the FCOs from each state, as well as Canada, Puerto Rico, and Costa Rica, as well as representatives from the FDA and USDA.

AAFCO meets twice a year to update its model regulations and review changes to federal law that affect its members, as well as to take suggestions from industry on new ingredients, or changes to existing ingredient definitions due to market forces or new technology.

Now, anyone who pays the registration fee can attend AAFCO meetings and sit in the audience. Lots of people who are interested in the policy outcomes do exactly that. An audience member can ask questions, give feedback, make suggestions, or raise objections on anything AAFCO is working on.

However, there is another level of participation, that of “industry advisor.” These advisors ostensibly represent non-profit/lobbying organizations such as the National Renderers Association, National Grain and Feed Association, and the Pet Food Institute; although for many of them their “day job” is working directly for manufacturers and suppliers.

It is important to note that while advisors sit at the table with the FCOs , and can say whatever they want about the issues, they have no voting power. Only FCOs and government representatives can vote.

What advisors do have, though, is influence.

I started attending AAFCO meetings in 1999, as a representative of the Animal Protection Institute, a non-profit animal rights organization. Even after I left API, I continued to attend meetings whenever I could. I have always been welcomed and treated graciously. Once, I even wrote an article about AAFCO, explaining the organization and dispelling the many myths that were flying around the internet, that remained posted on their website for many years.

In my experience, AAFCO members are genuinely interested in hearing from consumers, veterinarians, and others who have a stake in their decisions; but the problem is that they don’t hear very much from those sectors. On the other hand, at every meeting, a huge contingent of representatives from the feed, pet food, and supply industries shows up to lobby for their particular interests. AAFCO hears plenty from them!

When AAFCO only hears one side of the story, their decisions cannot help but be equally one-sided. Therefore, it’s critical that people who will stand up for pets and consumers, like Susan Thixton (www.truthaboutpetfood.com) and myself, attend these meetings and make sure your voices are heard.

AAFCO’s mission statement says:

Although AAFCO has no regulatory authority, the Association provides a forum for the membership and industry representation to achieve three main goals:

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

Sometimes it may seem like AAFCO has forgotten the “consumer protection” part; but even when they do try to implement a consumer-friendly policy, they get massive pushback from the pet food industry and its Washington DC-based lobbying group, Pet Food Institute (PFI).

PFI claims to represent the manufacturers of “95% of all the pet food in the U.S.” Notice how it doesn’t say “95% of pet food manufacturers.” It merely means that the 28 pet food manufacturers who are PFI members produce 95% of the sheer tonnage of U.S. pet food. Of course, those members include the huge multinational pet food makers, like Purina and Mars, generic and private label manufacturers like Diamond, who make food for other brands and/or themselves, and a handful of smaller companies like Natural Balance, Merrick, Fresh Pet, and Castor & Pollux.

So it was good to be back at AAFCO to see many of my old friends, as well as my “adversaries” from PFI and the pet food companies. It’s a very good thing to let them know they are being watched. (Actually, the people who attend these meetings are very nice, and they are extremely good at their jobs. It’s just that I disagree with their objectives and their methods!)

At the January 2012 meeting, I was appointed to the two committees that deal with pet food issues: the Ingredient Definitions Committee and the Pet Food Committee, as well as to a “work group” that was supposed to create new ingredient definitions for venison and other meats that do not fall into an existing definition. (However, the only “work” done appeared to be to ask industry to write the definitions; and even that small task hadn’t been completed, according to the report from the chair of the group.)

It was a big deal that Susan and I were appointed to these committees, and apparently there was a huge kerfuffle about it at the January meeting. The Board of Directors discussed it, and we were subsequently told that we needed to be “official representatives” of an association, like the American Feed Industry Association; otherwise we could not “officially” be on those committees. So I am now the “official” representative of the Pet Welfare Alliance (formerly Pet Parents Action Group).

Much of what goes on at an AAFCO meeting is about regulations, enforcement, and other technical topics, but a few issues were discussed that are of interest to pet guardians.

1. Updated Nutrient Profiles

The current nutritional standards that pet food is made by were put together in 1989 and 1990 by canine and feline “expert committees,” based on the 1985 guidelines from the National Research Council (NRC).

Yes, you read that right. The current standards being used right now in 2012 are almost 30 years old. Moreover, when those standards were set, there had been very little nutritional research done on dogs and almost none on cats, so many of those standards were actually based on research in rats and chickens. Since then, many new requirements have been discovered, and pet food companies have mostly kept up, at least with the most crucial items.

The NRC updated its guidelines and published them in 2006 (Nutrient Requirements of Dogs and Cats). Now, this is interesting because the guidelines were finished in 2003. However, my sources say that PFI raised a huge stink, because the new guidelines included maximums, and adhering to maximums would be a hassle for the pet food companies. (Manufacturers typically put 300-400% of the required nutrients in the food, to avoid potential deficiencies as these nutrients break down over time. Imposing maximums would mean that they would have to actually be accurate!) PFI managed to delay publication of the guidelines for three years.

When the not-so-new NRC guidelines finally came out, AAFCO convened new canine and feline expert committees to update its profiles. Those committees just finished their work. (And they are completely washing their hands of it, but that’s another story!) The FDA has some issues with the results; for example, they think the calcium levels are too low for large breed dogs.

The Pet Food Committee voted to accept the reports from the expert committees, but took no further action. They will review the issue again in January.

Of course, AAFCO takes quite a bit of time to accomplish anything–between committee meetings, board meetings, voting by the membership, and annual publication of the OP–so the new profiles will not see the light of day before 2014, at the earliest.

2. Carbohydrate Claims

Pet food labels are required to list the levels of certain nutrients in the Guaranteed Analysis: protein, fat, fiber, and moisture. What’s missing from this picture? The other major nutrient, carbohydrate.

Lots of people—pet guardians, veterinarians, retailers—want to have carbohydrate information available, and rightly so. Obesity is a serious problem for pets in this country. But…cats and dogs are carnivores. The carb requirement for an adult dog or cat is zero. Nevertheless, there are lots of carbs in pet food. Dry food in particular is loaded with carbs, which contribute to weight gain and many other health problems. (See: 10 Reasons Why Dry Food is Bad for Cats and Dogs)

Some pet foods do list carb information (Hill’s puts it on its website) using a method called “nitrogen free extract” or NFE. However, this is not a very reliable test and doesn’t provide pet guardians with enough information to be useful.

AAFCO appointed a “Carbohydrate work group,” but its report was not good: they are stalled because nobody can come up with a method of testing for carbohydrates that is valid across the board for not only pet food, but also feed for horses and livestock. Without an analytical procedure for labs to follow, there can be no standard. And there they remain stuck.

3. Calorie Statements

Five years ago, the American College of Veterinary Nutrition called for pet foods to list calorie information on their labels. And for five years, PFI opposed it. Why? For one thing, it would cost their members money to change their labels. For another, it would give consumers a way to compare foods that might not be favorable to PFI’s clients. And, of course, PFI opposes every change that would benefit consumers, if it might cause the slightest inconvenience to pet food manufacturers.

But finally…good news! The requirement for calorie information passed and has gone to the Board for approval. Of course, there’s bad news, too. The requirement won’t be finalized until next year; it won’t go into effect until at least 2014; and manufacturers will be given a three year grace period to relabel its existing foods.

But hey, it’s better than nothing.

4. “Tartar Control” Products

A lot of people give their pets foods or treats that claim a benefit for dental health. AAFCO’s and FDA’s general policy has been that these products are misbranded (illegal), but it’s okay as long as they make these claims based on some inherent property of the ingredients or the finished product. For example, a treat containing parsley could say it “freshens breath” because parsley itself does that naturally. A crunchy treat could claim it reduces tartar because of its hard texture. (Of course, this isn’t exactly true: see Does Dry Food Clean the Teeth) While these claims aren’t technically permissible, the FDA (and hence AAFCO) views it as a “low enforcement priority.”

The Veterinary Oral Health Council (VOHC) contacted AAFCO and claimed a conflict between policy and guidelines among FDA, AAFCO, and itself. VOHC reviews pet oral health products and issues the equivalent of a “Good Housekeeping seal” on approved products. The real issue, of course, is that most products out there that claim to improve tartar or breath do nothing of the kind: they’re worthless, or worse, because people tend to rely on such products to maintain their pets’ teeth, instead of brushing or veterinary care. VOHC has a very good point, but AAFCO and FDA decided there was no conflict, and took no action.

In other AAFCO action:

I was appointed to a work group that will review and update regulations on direct-fed microbials (probiotics), yeast, and similar ingredients whose nature or process has changed over time.

A new ingredient definition, stabilized rice bran, was discussed; I asked for an exclusion for cats to be added to the definition, since rice bran has been shown to deplete taurine in cats. Taurine is an essential amino acid for cats; it’s necessary for vision and heart function;  taurine deficiency can be fatal. While the new definition was adopted, I am working with the Rice Product Investigator to make the necessary changes in this and other rice bran products to make sure they are not used in any food or treats for cats. I also provided this information to the FDA at their request.


Perhaps the most interesting thing I learned at this meeting is how much the presence of “newcomers” is affecting the status quo. Basically, the same group of people have been attending these meetings for years. They all know each other very well. But now… evidently, quite a few people (FCOs as well as industry people) are keeping a close watch and reporting everything we post online. They had clearly checked out all our connections in great detail. That’s good–they should! Full and complete information is the best way to keep everyone honest!

So, to AAFCO, I say a big thank you, it’s great to be back, and I am very happy to participate!

All in all, this AAFCO meeting was productive and beneficial for consumers. AAFCO was reminded of a part of its mission that sometimes takes a back seat under the pressure of its more profit-minded participants, and the industry knows…I’m baaack!

Thanks again to everyone who donated to make this “Mission Possible”!

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