Pet Food Labeling Guidelines in USA & Canada

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Enforcement Authority in USA

Pet food labeling is regulated at two levels. 

National Level : The federal regulations, enforced by the United States Food and Drug Administration (FDA), establish standards applicable for all animal feeds:

  • proper identification of product
  • net quantity statement
  • manufacturer’s name and address
  • and proper listing of ingredients.

State Level : Some states also enforce their own labeling regulations. Many states have adopted the model pet food regulations established by the Association of American Feed Control Officials (AAFCO). These regulations are more specific in nature, covering

  • aspects of labeling such as the product name
  • the guaranteed analysis
  • the nutritional adequacy statement
  • feeding directions
  • and calorie statements.

AAFCO does not regulate, test, approve or certify pet foods in any way. AAFCO establishes the nutritional standards for complete and balanced pet foods, and it is the pet food company’s responsibility to formulate their products according to the appropriate AAFCO standard.

It is the state feed control official’s responsibility in regulating pet food to ensure that the laws and rules established for the protection of companion animals and their custodians are complied with so that only unadulterated, correctly and uniformly labeled pet food products are distributed in the marketplace and a structure for orderly commerce.

Pet Food Inspection :

4 primary ways unsafe or improperly labeled meat and poultry products come to the attention of FSIS:

  1. Company that manufactured or distributed product informs FSIS of potential hazard
  2. Test results received by FSIS as part of its sampling program indicate that the products are adulterated or misbranded
  3. FSIS field inspection program show a product as unsafe or improperly labeled
  4. Epidemiological data submitted by State or local public health departments or other Federal Agencies such as FDA or Center for Disease Control (CDC) indicates a problem with the food

An inspected Commercial Kitchen is not required for making pet foods. Local County Health Departments regulate commercial (for human food) kitchens. 

But commercial kitchens fall under zoning laws, Health Department laws, and state ordinances which require that the following be met:

  • Must comply with regulations for state and local health districts
  • Must be inspected
  • Daily requirements for cleaning surfaces
  • Clean and sanitary storage of foods at safe temperatures
  • Avoiding direct hand contact with ready-to-eat foods
  • Adhere to fire safety regulations
  • Clean kitchen exhaust systems regularly
  • Comply with plumbing codes
  • Other requirements include adequate floor space, cooking hoods, fire suppression systems, sinks and electrical systems

Regulation Details :

What is a Pet Food ?

Pet food is defined as any commercial (i.e., you offer for sale, sell exchange or barter) feed prepared and distributed for consumption by dogs or cats.

  • Pet food is a subset of animal feed.
  • Complete and balanced foods are pet foods.
  • Treats/snacks are pet food.
  • Nutrient supplements (vitamins, minerals, fatty acids) are pet food.
  • Nutrient-added waters are pet food.
  • Edible chews (rawhide, hooves, pizzles) are also pet food under the law, but may be exempt from state registration and labeling requirements under specified conditions.
  • Non-nutritional supplements (herbs and botanicals, metabolites) are not pet food, but rather may be subject to regulation as drugs. The law that allows these types of ingredients in “dietary supplements” for human consumption does not apply to animal products.
    – AND –
  • Pet food sold – in a local farmers market is considered commercial feed.
  • Pet food sold – over the Internet is considered commercial feed.
  • Pet food sold – at a veterinarian’s office is considered commercial feed.
  • Pet food sold – in a local store is considered commercial feed.

Ingredient Listing Format:

  • Ingredients must be listed in order of predominance by weight, on an “as formulated” basis. The ingredient that makes up the highest percentage of the total weight as it goes into the product is listed first.

 

  • Each ingredient must be listed by its appropriate name. There is no allowance to group ingredients smaller than some percentage (like 1% or 2%).

 

  • There is no allowance in pet foods to use a collective term for replacing individual ingredient names with a group term, like combining wheat, corn and oats into one ingredient name “grain products”.

 

  • The ingredients used must be AAFCO officially defined animal feed ingredients, or be common or usual names of feed ingredients, be approved food additives in 21 CFR 573, or be considered GRAS (Generally Recognized as Safe) animal feed additives.

 

  • Just because an ingredient is used in human food does not mean that it is acceptable to use in animal feed or pet foods.  It is important that if an AAFCO defined name exists, then that is the name that must be used in the ingredient statement.

Some AAFCO defined ingredients and some ingredients listed in the Code of Federal Regulations have restrictions for which animals can consume the ingredient or restrictions on how much of the ingredient can be used. You need to check to be sure that the ingredients that you use are approved for use in animal feeds. Many regulators will immediately reject product registration requests if they find unapproved ingredients in the ingredient list.

Additionally, there is no allowance for dietary supplements for animals. DSHEA does not apply to animals.

For animals there are only two categories: food or drug. Be advised that some ingredients used in dietary supplements for humans cannot be used as pet food ingredients.

Federal and state officials can help you to determine if an ingredient is an approved ingredient.

Usage of types of ingredients ?

You can not use any type of ingredients.

  • The ingredients used in pet food must be appropriate for the pet. Some ingredients have been defined via the AAFCO Ingredient Definition Process. Any ingredient with an AAFCO defined name must be listed in the ingredient statement by that name.

 

  • Some ingredients are common or usual in the pet’s diet. Some ingredients are feed additives that are “Generally Recognized As Safe” (GRAS) by the FDA.

 

  • All ingredients used in any pet food must be acceptable either via the AAFCO ingredients definition process, via formal FDA-CVM review or via Self-Affirmed GRAS.

 

  • All of these methods require extensive  amount of information including a substantial portion that must be in the public domain.

 

  • Not just any ingredient can be used, especially ‘new’ ingredients that might be used a dietary supplements for humans. Such ingredients are not always safe for animals.

 

  • The legalese says the labels of foods must have the ingredients listed in descending order of predominance by weight. This means that the weight and not the volume of each ingredient must be determined.

 

  • Then the ingredient list is assembled by listing each  ingredient by its proper name starting from the most and proceeding down to the least. All ingredients must be listed.

“Organic” refers to the handling and processing of ingredients and products, not the quality of product. Pet foods and pet treats must comply with the USDA’s National Organic Program (NOP) regulations (7 CFR 205). 

These regulations cover:

  • ingredient sourcing
  • ingredient handling
  • manufacturing
  • labeling & certification of products wanting to use the word “organic” in their labeling

Guaranteed analysis : 

  • All pet food labels require a guaranteed analysis on the label to advise the purchaser of the product’s nutrient content. At minimum, guarantees are required for minimum percentages of crude protein and crude fat, and maximum percentages of crude fiber and moisture. The only exception is for products that do not and are not intended to provide protein, fat or fiber (for example, vitamin and mineral supplements), in which case the product is exempt from guarantees for those components.

 

  • In all cases, though, a moisture guarantee is required. Guarantees for other nutrients are normally voluntary, although additional guarantees may be required to support claims made on the label.

For example, claims such as “with calcium” or “high in vitamin E” would require minimum calcium or vitamin E guarantees, respectively.

  • Unless the product is formulated through the use of sophisticated computer software with a complete and accurate database on nutrient content of all ingredients used in the product, the best means of determining appropriate guarantees is by laboratory analysis. A “proximate analysis” of the finished product includes testing for the four nutrient components mentioned above in addition to ash. Results are typically reported in percentages “as fed” (AF). If unsure as to the units reported, it is prudent to ask the laboratory for clarification.

 

  • Important to note is that a single analysis of a product may not provide sufficient data to determine reliable guarantees. Guarantees are declared as either “minimums” or “maximums,” meaning that if a feed control official obtained a sample of the product and tested it in his or her official state lab, the crude protein and crude fat must be NO LESS THAN the stated percentage on the label, while the crude fiber and moisture must be NO MORE THAN the label declaration. Each batch of finished product is going to vary in composition due to variation in ingredient composition, mixing rates, and amount of water driven off during the cooking process. Unfortunately, a single analytical value does not give any indication as to the expected batch-to-batch variation. As a result, the composition of the batch that was tested may be very different from the one the feed control official analyzes!

 

  • Failure to meet the guarantees may result in possible enforcement action against the product. It is prudent, then, to test multiple batches of each product. How many? In general, the more analyses conducted, the better one can estimate batch-to-batch variation and hence more reliably set guarantees. Understanding economic limitations of start-up companies, it is prudent to conduct at least two analyses of each variety to start. As more batches are produced and analyzed, more data may indicate the need to adjust the guarantees on the next label printing.

Net Quantity Statement:

The net quantity statement tells you how much product is in the container. There are many FDA regulations dictating the format, size and placement of the net quantity statement. None of these do any good if the consumer does not check the quantity statements, especially when comparing the cost of products. For example, a 14-ounce can of food may look identical to the one-pound can of food right next to it.

Also, dry products may differ greatly in density, especially some of the “lite” products. Thus, a bag that may typically hold 40 pounds of food may only hold 35 pounds of a food that is “puffed up.” A cost-per-ounce or per-pound comparison between products is always prudent.

Manufacturer’s Name and Address:

The “manufactured by…” statement identifies the party responsible for the quality and safety of the product and its location. If the label says “manufactured for…” or “distributed by…,” the food was manufactured by an outside manufacturer, but the name on the label still designates the responsible party. Not all labels include a street address along with the city, state, and zip code, but by law, it should be listed in either a city directory or a telephone directory. Many manufacturers also voluntarily include a toll-free number on the label for consumer inquiries. If a consumer has a question or complaint about the product, he or she should not hesitate to use this information to contact the responsible party.

Ingredient List:

All ingredients are required to be listed in order of predominance by weight. The weights of ingredients are determined as they are added in the formulation, including their inherent water content. This latter fact is important when evaluating relative quantity claims, especially when ingredients of different moisture contents are compared.

For example : – one pet food may list “meat” as its first ingredient, and “corn” as the second ingredient. The manufacturer doesn’t hesitate to point out that its competitor lists “corn” first (“meat meal” is second), suggesting the competitor’s product has less animal-source protein than its own. However, meat is very high in moisture (approximately 75% water). On the other hand, water and fat are removed from meat meal, so it is only 10% moisture (what’s left is mostly protein and minerals). If we could compare both products on a dry matter basis (mathematically “remove” the water from both ingredients), one could see that the second product had more animal-source protein from meat meal than the first product had from meat, even though the ingredient list suggests otherwise.

Nutritional Adequacy Statement:

Any claim that a product is “complete,” “balanced,” “100% nutritious,” or claims of a similarly nature that suggests a product is suitable for sole nourishment when it is not, in fact, nutritionally adequate for such purpose is a potentially unsafe product. For this reason, an AAFCO nutritional adequacy statement is one of the most important aspects of a dog or cat food label. A “complete and balanced” pet food must be substantiated for nutritional adequacy by one of two means.

  1. 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 all recognized essential nutrients needed to meet the needs of the healthy animal.
  2. The alternative means of substantiating nutritional adequacy is for the product to be tested using the appropriate AAFCO Feeding Trial Protocol(s). 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.

A product that does not meet either of the methods for substantiation of nutritional adequacy must state that “this product is intended for intermittent or supplemental feeding only,” unless the product is conspicuously identified as a “snack,” “treat.” or “supplement.”

Feeding Directions:

Feeding 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.

Breed, temperament, environment, and many other factors can influence food intake. Manufacturers attempt to cover almost all contingencies by setting the directions for the most demanding.

The best suggestion is to offer the prescribed amount at first, and then to increase or cut back as needed to maintain body weight in adults or to achieve proper rate of gain in puppies and kittens. A nursing mother should be offered all the food she wants to eat.

Calorie Statement:

  • Pet foods can vary greatly in calorie content, even among foods of the same type (dry, canned) and formulated for the same life stage. Feeding directions vary among manufacturers, too, so the number of calories delivered in a daily meal of one food may be quite different from another.

 

  • The number of calories in a product roughly relates to the amount of fat, although varying levels of non-calorie-containing components, such as water and fiber, can throw this correlation off. The best way for consumers to compare products and determine how much to be fed is to know the calorie content. AAFCO regulations have been developed to allow manufacturers to substantiate calorie content and include a voluntary statement.

 

  • 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. Manufacturers are also allowed to express the calories in familiar household units (for example, “per cup” or “per can”) along with the required kilocalories per kilogram statement. Even without this additional information, however, consumers can make meaningful comparisons between products and pick the product best suited for their animals’ needs. As with the guaranteed analysis, the calorie statement is made on an “as fed” basis, so corrections for moisture content must be made as described above. To roughly compare the caloric content values between a canned and a dry food, multiply the value for the canned food by four.

Other Label Claims:

  • 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.

  • The term “natural” is often used on pet food labels, although that term does not have an official definition either. AAFCO has developed a feed term definition for what types of ingredients can be considered “natural” and “Guidelines for Natural Claims” for pet foods.  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, the same as for human foods. Especially for high-fat dry products, some form of preservative must be used to prevent rancidity. Natural-source preservatives, such as mixed tocopherols (a source of vitamin E), can be used in place of artificial preservatives. However, they may not be as effective.

 

  • “Natural” is not the same as “organic.” The latter term refers to the conditions under which the plants were grown or animals were raised. There are no official rules governing the labeling of organic foods for pets at this time, but the United States Department of Agriculture is developing regulations dictating what types of synthetic additives, such as vitamins and purified amino acids, may be used in pet foods labeled as organic

Pet Food Labeling Regulation in Canada:

Canadian pet food manufacturers are currently subject to several Canadian and international regulations including the Canadian Food Inspection Agency’s enhanced animal health safeguards which make it illegal for specified risk materials (SRMs) to be fed to any animal, including dogs and cats.

Pet food manufacturers must comply with the Consumer Packaging and Labelling Act and the Competition Act, administered by Industry Canada. These regulations specify how pet foods may be marketed to consumers, including how food is named and what information must be included on pet food labels.

Members of the Pet Food Association of Canada (PFAC) also manufacture to the nutritional standards set out by the Association of American Feed Control Officials (AAFCO).

  • The Government of Canada’s enhanced animal health safeguards, implemented in July 2007, make it illegal for specified risk materials (SRMs) to be fed to any animal, including dogs and cats. Members of PFAC support this new legislation and have fully complied with it by removing specified risk materials from their pet food.

 

  • The labelling and advertising of pet food is regulated by the Consumer Packaging and Labelling Act and the Competition Act, administered by Industry Canada. PFAC members fully comply with these Acts and with the Guidelines for the Advertising and Labelling of Pet Food, which is a voluntary guide developed to ensure consistency and accuracy on pet food labels.
    • The Guidelines also help to ensure that Canadian consumers clearly understand the contents of each package of pet food. They were developed by a working group including Canadian pet food manufacturers and importers, representatives from the Competition Bureau and the Government of Canada, as well as consumers.

 

  • The Consumer Packaging and Labelling Act mandates that the following items be included on pet food labels.
    • Common or generic name: e.g. “Dog Food” or “Cat Food”
    • Net weight: amount of product within the package, measured in metric units
    • The manufacturer’s or importer’s contact information

 

  • The Guidelines, an accepted standard in the pet food industry, recommend pet food labels should contain at least the following information in addition to the Consumer Packaging and Labelling Act .
    • List of ingredients: listed in descending order by percentage of weight
    • Feeding instructions
    • Guaranteed analysis: information on the minimum and maximum nutritional quantities. For example, the analysis will include the maximum or minimum percentage of protein, fat, fiber and moisture.
    • Nutritional adequacy or intended life stage for which the food is suitable

 

  • Ingredients must be listed and identified by their common name. When an ingredient or combination of ingredients makes up 90% or more of the total weight of all ingredients, these ingredients may also form a part of the product name. For example, if the product contains 90% or more beef, it may be called “My Brand Beef Dog Food”.