Understanding Pet Food Packaging, Labelling and Regulations

If you have ever looked at the labelling on your pet food, it can be a little confusing. While there is a lot of good information on the package, it might not be clear on how to interpret that information when choosing a food for your dog. Not only do the nutrition labels look different from what we are used to seeing on our own food items; marketing can fill the packaging with buzz words, that may distract from the real information about what the food contains.

Dog food labels and packaging do have minimum requirements to be included on every package to provide accurate information to consumers. However, that still doesn’t explain what a guaranteed analysis is and how to read it or what a nutritional adequacy or AAFCO statement is and how that pertains to their dogs needs.

In this blog I would like to take a closer look at dog food packaging and delve into what goes into to making a dog food label. What legal requirements and regulations do companies need to follow, and what checks and balances are there to ensure the information contained on the package is correct so consumers can make knowledgeable choices.

I would also like to explore clever marketing techniques and words used by companies, scrutinizing as to the real meaning behind them and how that translates to your dog’s needs.

What is AAFCO?

AAFCO stands for the Association of American Feed Control Officials its purpose is to monitor and oversee the sale and distribution of animal feeds and drug remedies. It is not responsible for testing and quality control, and it does not certify or approve dog foods.

It is a non-profit organization that sets a guideline and standard for dog food companies to follow which is why on pet food packaging you will see an AAFCO Statement. This statement is a statement of “nutritional adequacy or purpose” also known as a nutrition claim. Under AAFCO regulations this must be validated by the manufacturer of the product.

To be a member of AAFCO you must be an employee of a state or government agency which enforces animal feed regulations which also includes dog food. Members of AAFCO include the Canadian Food Inspection agency (CFIA), the U.S. Food and Drug Administration (FDA) as well as individual state departments of agriculture; Costa Rica and Puerto Rico are also members of AAFCO.

How to read an AAFCO statement

The AAFCO statement, or nutritional adequacy statement is a proclamation for how the food is intended to be used and for what life stage. It is to indicate that the food is complete and balanced and can be fed as a regular diet for stages such as growth, regular adult maintenance, reproduction, or some combination of these; it may also state if a food is intended to be fed as supplemental or occasional feeding. It is important to note that products which are advertised as a treat, snack or supplement are exempt from this nutritional adequacy statement.

There are two types of commonly used methods which validate the nutritional adequacy, the formulation method, and the feeding trial method. The formulation method means that the food has been using AFCO guideline which have been generated on a computer, to ensure the recipe meets the standard. With the feeding trial method, the manufacturer of the food must perform a feeding trial with the food being the sole source of the dog’s nutrition and see how the food performs when these dogs are fed that specific diet. Feeding trials, however, can be costly and take time so not all companies will use this method when validating their AAFCO statement, most rely on their food being formulated with the ingredients and nutrition to meet the standard.

Some examples you may see on your pet food packaging are statements like:

“[Pet Food Name] Dog food is formulated to meet the nutritional levels established by the AAFCO Dog Food Nutrient Profiles for maintenance of adult dogs.”

Or

“Animal feeding tests using AAFCO procedure substantiate that [Pet Food Name] provides complete and balanced nutrition for growing puppies and gestating or lactating adult female dogs.”

There is a special statement for puppies who are expected to reach 70 pounds. In 2016 AAFCO expanded their guidelines to include specifications for foods categorized as growth that they have also met the requirements for these dogs who will become 70 pounds or more at their adult weight. This is due to dangerously high calcium found in some diets which is not suitable for larger breed dogs as they are more sensitive to calcium amounts either being too low or too high. This new guideline is to help ensure the appropriate and safe levels of calcium are found in foods with this statement. So, if you have a large breed puppy look for the AAFCO statement that reads:

“[Pet Food Name] is formulated to meet the nutritional levels established by AAFCO Dog Nutrient Profiles for growth/all life stages including growth of large-size dogs (70 lbs or more as an adult).”

A special note for senior dogs, there are some AAFCO statements which proclaim the food is formulated for “All life stages”. To have this statement it would mean that the food also contains a growth component suitable for lactating females and puppies. This food may not be a great choice for older adults and seniors who do not require a growth component to their food, for them I would suggest finding a diet more appropriately suited for their life stage.

What is the role of the FDA?

While there is no requirement for dog food manufacturers to retain pre-market approval by the FDA, however, the FDA does ensure that all the ingredients use in pet foods are safe and appropriate.

The FDA currently requires each manufacturer to include proper identification, net quantity, name, address of the manufacturer/distributor and the proper listing off all ingredients, in order based on weight. Labelling regulations may also be enforced on the state level based on the recommendations by AAFCO.

Regarding more specific claims such as, “hairball control” or “maintains urinary tract health”, the FDA reviews such claims and provides guidance for collecting data to substantiate them. They will not recommend one product over the other or offer any advice on what food you should choose.

Dog food complaints can also be made to the FDA by way of the Safety Reporting Portal or if in the US, the local state FDA Consumer Complaint Coordinators.

What is a guaranteed analysis?

A guaranteed analysis shows the minimum or maximum levels of nutrients in the product like crude protein, crude fat, and crude fibre, with the word crude meaning; in its natural, unprocessed state. It gives a percentage rather than exact amounts of the nutrients in the food. It is not a guarantee of the quality of the ingredients, but is a guarantee, of these maximum and minimum values. Sometimes a guaranteed analysis is included for other nutrients if the pet food company has made a specific claim of that nutrient, if this is the case, then it must be included in the guaranteed analysis. Companies may also include the minimum percentage levels of calcium, phosphorus, sodium, and linoleic acid on a voluntary basis.

How are ingredients listed?

First off, we should look at the difference between an ingredient and nutrient as the two words are not interchangeable. An ingredient is the mode that provides the nutrients as the nutrients are the individual components that are metabolically useful and sustain life.

You may not know that ingredients on your dog food label are listed in order by weight before processing which will include the moisture content as well. Therefore, heavier ingredients such as chicken or beef are listed first as they can have a high-water content, and other “lighter” ingredients such as grains will be listed after.

Ingredients must also be identified by their common term and not a brand or trade name. Smaller ingredient categories like vitamin and minerals can be joined together as a group and listed as such.

You may see “sufficient water has been added for processing”, this is added to the label when water is added in the preparation of food.

This ordering of ingredients can sometimes be used as a misleading marketing tool as companies proclaim that meat being listed first means the diet has more meat in it or is mostly meat. However, as I previously mentioned this is weight before processing with water content, so the meat may not be the main ingredient in the food, it just weights more before they process the food.

Buzz Words and Marketing

There are savvy marketing tactics everywhere, the pet food industry is no exception. Let’s look at a few of the marketing buzz words sometimes used to translate what they mean.

 Human-Grade

This is a term that has been showing up on pet food packaging for years, and it can be misleading, but what does it mean. According to AAFCO;

“Edible is a standard; human-grade is not. For a product to be deemed edible for humans, all ingredients must be human edible and the product must be manufactured, packed, and held in accordance with federal regulations in 21 CFR 110, Current Good Manufacturing Practice in manufacturing, packing, or holding human food. If these conditions are met for a dog food, human-grade claims may be made. If these conditions are not met, then it is an unqualified claim and misbrands the product” –AAFCO

This is also based on US regulations so it should be noted that these definitions don’t mean anything for other countries’ products. It is important to remember just because it is labelled as human-grade it doesn’t mean that the ingredients are of better quality or that it is nutritionally adequate. It also doesn’t mean the food is any safer than products that aren’t labelled as human-grade.

All Natural Ingredients

AAFCO has listed their definition of “natural” to be defined as:

               “A feed ingredient derived solely from plant, animal, or mined sources, either in its unprocessed state or having been subject to physical processing, heat processing, rendering, purification, extraction hydrolysis, enzymolysis or fermentation, but not having been produced by or subject to a chemically synthetic process and not containing any additives or processing aids that are chemically synthetic except in amount as might occur in good manufacturing practices.

According to the FDA the term “natural” is to mean:

               “Nothing artificial or synthetic (including all colour additives regardless of source) has been included in, or has been added to, a food that would not normally be expected to be in that food”

This doesn’t mean that foods labelled as such have a higher nutritional content or that it is a complete ad balanced diet. The supplements, vitamins and minerals found in dog food are already, by definition, naturally derived so a diet that claims to be “all natural” can also contain vitamin supplements. These also include dry food under their definition which is subject to processing and cooking or rendering.

No Fillers

Fillers are in a diet to add bulk and not much else, with little to no nutritional value and AAFCO doesn’t have a definition for the term. Often grains are lumped into the category of being a filler, but this simply isn’t true as grains provide many nutritional benefits. They may get a bad reputation these days with lots of talk of grain-free diets, however, dogs need carbohydrates to produce energy, so a grain free diet isn’t exactly a better choice for your dog. In fact the FDA in 2019 stated it was investigating higher incidences of canine dilated cardiomyopathy which had been suspected to be caused by dogs being fed a “grain-free” diet. This is not to say grain-free diets are bad for your dog, however, you may want to use caution and check with your vet if you want to feed a grain-free diet but aren’t sure if it is right for your dog.

Supplements and Additives

I wanted to include a little bit about supplements as you may see dog food labelled “with Glucosamine” or some other nutritional supplement, however, these claims may be misleading. It is not to say that it doesn’t contain the supplement but, it may not be included in therapeutic levels so that your dog may benefit. Your dog needs approximately 20 mg of glucosamine per pound of body weight. This would mean a 50-pound dog would need 1000mg of glucosamine a day to be therapeutic. When purchasing a food that has a claim about the glucosamine in its food, I would look for an indication on the package of the amount contained per cup. If you do not see anything on the label to indicate the amount the food contains then it would be best to add the glucosamine to your dog diet by way of a veterinary supplement to ensure they are receiving the benefits. The same can be said for other nutrients that may be claimed on the package, if they aren’t able to specify the amounts as to what each cup contains then you really can’t be sure they are getting what you intended.

What are meat by-products?

The word by-product is generally thought of as a bad term, that these ingredients are somehow inferior or offer no nutrition when that simply isn’t the case. The term meat by-product refers to the leftover parts of the animal, other than meat that are derived from the clean slaughtered animal after the meat parts have been used for its intended use, usually a product for human consumption. These by-products consist of the lungs, liver, kidney, spleen, blood, bone, and stomach intestine which has been emptied of its contents. These are an excellent source of nutrients as wild dogs will eat the same “by-product” sources after successfully hunting and killing their prey. These meat by-products do not contain hair, horn teeth, or hooves as it is sometimes thought to.

By-products are also common ingredients in human food like liver, gelatin, flaxseed oil and beef bouillon.

You may see by-products listed as” poultry by-products”, or “meat by-products” or just “by-products”. Poultry by-products are just the by-products after processing poultry but do not include muscle, skin, or feathers.

There is also another by-product definition, Animal by-product meal, this is made from meat by-products but will sometimes contain and entire carcass with exception to hair, hooves, horn, manure, stomach, or rumen contents.

What are the Labelling Requirements?

As I mentioned, there are minimum labelling requirements for dog food. There are eight required items to be listed on the package, which are: the brand and product name, the name of the species which the food is intended for, the quantity statement, the guaranteed analysis, ingredient statement, nutritional adequacy statement, feeding directions and the address of manufacturer or distributor.

When it comes to the brand and product name, how the name is presented can have its own rules when using unique descriptions. “Beef Recipe Dog Food” and “Dog Food with Beef” are not the same. It depends on the amount of the particular ingredient in the food as to how certain descriptions can be used in the brand and product name.

The quantity statement is self explanatory as it is to state the net weight or net volume of the food and the appropriate units must be used and shown in both imperial and metric.

The guaranteed analysis we covered before, which is to state the nutrients in the food and their percentages.

The ingredient statement is the ingredients list, as we discussed before which is ordered by weight before processing.

The nutritional adequacy statement or the AAFCO statement which proclaims how the food is to be used and who it is suitable for.

The feeding directions and the address of the manufacturer are also self explanatory.

Manufacturers may choose to add extra information on their packaging of their own accord above the minimum labelling requirements.

Conclusion

It is great to have so many choices out there when it comes to pet food as there is a diet for almost everything. From specific diets for animals with special needs such as Urinary or GI health to calming diets for anxiety, as well as regular life stage diets for puppies, adults, and seniors.

As I mentioned before, there is so much information out there it can sometimes to be hard to see through the distractions to find the info you are looking for. I hope this “crash course” in pet food packaging helps you better understand what information is composed on your pet’s food package, so next time you’re looking at pet food labelling, you will be able to decipher the code!

As always, if you have any concerns about your dog’s specific needs, please contact your local veterinarian as they and their staff can assist you to find a food that will work best for them.

Emily Charlton is a lifelong animal lover drawing on more than 12 years experience in a veterinary clinic.

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