All pet foods sold within the United States are required by law to have certain key pieces of information on the label. Adherence to these requirements are regulated both at the Federal level (enforced by the Food and Drug Administration [FDA]) and at the State level (enforced by State Feed Officials). The FDA requirements are fairly minimalistic. All animal “feeds” (dog and cat food falls under this category) must have: 1) a way of identifying the product (name or product number); 2) a net quantity (gram amount); 3) a name and address (city or street) of manufacturer or distributor; and 4) a list of ingredients written in common industry terms (note: this doesn’t mean that anyone else needs to understand them). Most of the individual 50 states have also adopted guidelines proposed by the Association of American Feed Control Officials (AAFCO). AAFCO has no regulatory enforcement and they cannot make states adopt all or even part of what they call the “Model Bill and Regulations”, but if any Pet Food Company wants to sell across multiple states, they will usually meet the most stringent of the state labeling laws. In addition to the 4 FDA pet food label requirements, you should also find: 5) a species designation (it has to say whether it is intended for a dog, a cat, or both); 6) a guaranteed analysis; 7) feeding guidelines; 8) nutritional adequacy statement; and 9) a calorie statement. It seems like a lot of information to take in, but once you know what is required by law vs. what is added for fluffy marketing you will be able to evaluate the merits of each food better.
So here is your list of label requirements and explanations of each…
- Product Name
All pet foods must have a formal name that distinguishes it from other foods within the same brand. The way the Product Name is written will also tell you about the formulation of the food.
The hidden “code” in Product Names:
The 95% Rule: If the Product Name is written as “Chicken for Cats” or “Beef for Dogs” then at least 95% of the weight of the food (not counting water added for processing) must be that named ingredient, AND must be at least 70% of the finished product (so with the water added).
The 25% Rule: Also called the “Dinner” rule. If a food is listed as a “Chicken Dinner” or “Turkey & Sweet Potato Dinner”, then at least 25% (not including water added for processing) must be the named ingredients, AND must be at least 10% of the finished product, AND the ingredients need to be listed in descending order of weight (so for the turkey and sweet potato example, there needs to be more turkey than sweet potato), AND none of the named ingredients can be less than 3% of the total.
The 3% Rule: Also called the “with” rule. Examples of this would include Product Names like “Beef Dog Food with Cheese” or “Cat Food with Chicken”. Any ingredient that follows the word “with” in the Product Name must be at least 3% of the total finish product.
Flavors: When it says, for example, “chicken flavor” the actual named ingredient isn’t required as long as the dog or cat thinks it tastes like it anyway. Maybe this is why everything tastes like chicken…
Also it is important to know that ingredients other than those listed in the Product Name can still be included in the formulation and you should always check the label if you are trying to avoid certain proteins (plant or animal) that may trigger a reaction in your dog or cat. More on ingredient definitions in my next entry.
- Net Quantity
Pretty self-explanatory. This tells you how much is in the bag or can of food. If there is no net weight on the packaging, stop. Put it back on the shelf and move on.
- Name and Address
This is where Pet Food Companies that use third-party manufacturers can get a bit tricky. The requirement by the FDA and supported by AAFCO is for a name and address of the party taking responsibility for the food, not who actually made it. When you look for the Pet Food Company contact look to see whether the food was “Manufactured by…”, “Distributed by…”, or “Manufactured for…” the Pet Food Company printing their name on the label.
Pet Food Manufacturing Companies are up front with who makes their foods. These pet foods will either list their own company name or the name of the parent company of the brand label (this is usually the case for pet foods manufactured and distributed by the larger multinationals, for example Alpo is made by Nestle Purina and Nature’s Variety is made by Big Heart Brand, which was Del Monte Foods until they changed the name of the pet care business in February 2014). Pet Food Manufacturing Companies will own all parts of manufacturing and distribution (and often some of the ingredient supply chain) so that they can control product quality more tightly (I’m sure it helps reduce production costs, too).
“Distributed by…” or “Manufactured for…”
Pet Food Marketing Companies on the other hand either lack the financial capital to build a pet food manufacturing facility, or they have decided to skip the sciencey-stuff and instead spend money on print ads, tv/web commercials, and making the cutest darn label graphics you ever did see. Either way, Pet Food Marketing Companies contract production of their food, add their own label to the finished product, and then sell it. Often at a “premium” price. This is a pretty common occurrence in the pet food industry and it can be nearly impossible to know who makes what for which company because of confidentiality agreements between all parties. There are a few marketing companies that I consider to be of a better caliber than others. These are the companies that out-source manufacturing, but still enforce quality control standards for raw materials and finished products by having independent testing done. They may be small companies but are genuinely trying to make a pet food that improves animal health and performance whether it is for a couch kitty, or a sled dog. Unfortunately there are many more Pet Food Marketing Companies that skip along intentionally ignorant of what is actually in their finish products. They are too busy counting their money and thinking up ways to dupe owners into spending more for pet food to worry about silly details like bacterial contamination or whether their food actually has the right nutrient balance.
As for the address, a street (i.e. snail-mail) address is not required as long as the company is “listed in either a city directory or a telephone directory”. Do those still exist in the US? Now days, almost all Pet Food Companies websites and a quick Internet search will lead you to a link for contact resources. If contact information is missing on your food or treat package, put it back. Do not feed it. If the company doesn’t know enough to comply with federal and state laws I wouldn’t trust them to make a safe food.
- List of Ingredients
The only requirements for the List of Ingredients are that it is ordered by weight and is written in industry accepted terms. Ah, how simple that sounds, but contentious it can be. In my next post I am planning to cover ingredient definitions, but for now I will tell you that that every Pet Food Company is guilty of padding their labels to make certain ingredients move up or down on the ingredient list. To make an animal protein jump up higher on the list, they simply use one animal protein and many different types of carbohydrates (like a diet that includes chicken, barley, oat, amaranth, potato, sweet potato, quinoa, carrots,…) or they use “meals” (i.e., dehydrated, defatted protein powders) of other animal proteins so that you can honestly say “Chicken is the #1 Ingredient!” (as a wet weight) on their packaging even when the next two ingredients are poultry meal and poultry by-product meal and make up a larger proportion of the total dietary protein than the fresh chicken meat.
- Species Designation
Another pretty easy one to understand. Dog food has to be listed as “dog food” and cat food has to be listed as “cat food”. If there is no indicator on which one you should feed it to, stop. Put it back on the shelf and move on.
- Guaranteed Analysis
Only four things are required to be included on the Guaranteed Analysis (or “As-Fed Basis”): Crude Protein (listed as a minimum), Crude Fat (listed as a minimum), Crude Fiber (listed as a maximum) and Moisture (listed as a maximum). Pet Food Companies will often list other things to highlight nutrients that they think will encourage pet owners to buy their food. This is the Pet Food Companies way of saying, “look at me! look at me! I care about your dog because I include (fill in the blank)!”. They all do it. My concern with the Guaranteed Analysis is that many dog and cat caregivers will use this as a reference for comparison between brands of foods, but these values are only estimates and tell you nothing about the quality of the food or the nutritional values.
The terms “crude” refer to the method of testing use to estimate protein, fat and fiber levels in the product. Crude Protein for example is estimated by measuring the absolute nitrogen content of the food, which is then used to back calculate to a specific amount of actual protein. This is where pet food manufacturers got into trouble in 2007. At that time raw material providers took rice and wheat flours (low nitrogen containing benign powdered ingredients) and added melamine and cyanuric acid (two high nitrogen toxic industrial chemicals). This was done to make these flours look like the higher nitrogen containing ingredients rice gluten and wheat gluten (“gluten” is simply the name for a plant protein). The recipients of these contaminated flours only tested for nitrogen levels at that time, and since they matched what was expected for rice gluten and wheat gluten, they were added to foods. It wasn’t until children in Asia and pets in the United States (any elsewhere) started going into kidney failure and dying that the intentional contamination was found. No one had thought to test for melamine and cyanuric acid in food ingredients before April of 2007, but everyone does now.
If I could change one thing about pet food labels it would be to do away with the Guaranteed Analysis completely and replace it with something more representative of what is actually in the food. Minimum values tell you the lower limit for protein and fat, but for animals with specific needs or intolerances to higher levels of these nutrients, the potential maximum values are more problematic. Animal proteins are expensive so the Proximate Analysis (actual amounts in each batch that are monitored internally by Pet Food Manufacturers) and the Guaranteed Analysis values (listed on the label) for Crude Protein are often the same, but fat is cheap and especially in foods with higher amount of fresh animal proteins (like canned cat and dog foods), fat content can be highly variable. Proximate Analysis for Crude Fat can be up to 25-30% higher than the Crude Fat number listed on the label, and is allowed as normal variation in raw materials. This may surprise pet owners since Pet Food Companies like to use images of lean meats on their label graphics (like chicken breast or beef loin), but what you need to know is that animal proteins used by Pet Food Companies are the fatty cuts that people in the US don’t want to eat. For the most part, the meats used in all pet foods are the “by-products” of the human food supply. It will still be fresh, high-quality, USDA- inspected chicken that is used, it is just the back and wing meat, not the breast. Unless the manufacturer has tight control on nutrient specifics for ingredient, there can be quite a bit of variation in fat levels in canned foods. See my last entry on Poop if you want to learn more about what happened when you inadvertently increase your dog’s fat intake. Dry foods have a more constant fat level batch-to-batch. Because dry foods are exposed to air after opened, any increase in fat level in a dry pet food will require an increase in the amount of preservatives used to prevent the food from going rancid.
And the last problem with the Guaranteed Analysis is that you also can only compare food that have similar moisture (i.e., water), fiber, and mineral (“Ash”) contents. Some people will advocate factoring out the water and convert everything to a “Dry Matter Basis” for comparison, which doesn’t really work for today’s foods. Forty years ago when all dry foods were basically the same ingredients in different packages, it may have worked. But today’s pet foods can have dramatically different fiber levels and different mineral levels, each of which will have a dilutional effect on the other numbers. For example, Company X can use a poor quality protein (which has a high Ash content) in their food, but add very little fiber. Company Y on the other hand may use a good quality protein (which has a lower Ash content), but also have added fiber for gastrointestinal health. The result would be that the Crude Protein number on the label for Company X’s food may be higher than or Company Y, even though Company Y’s diet may a better quality food. The other problem with converting everything to a “Dry Matter Basis” is that it requires the use of a calculator and knowledge of conversions. I consider myself a math nerd and there are a lot of simple calculations I can do in my head, but dividing the crude protein value by the dry matter content and then multiplying by 100 while standing in a pet food aisle is not one of them.
- Feeding Guidelines
Every one complains about Feeding Guidelines, even people who work in the pet food industry, and they are almost always wrong for the “average” pet. But, Feeding Guidelines are required to be on pet food labels by most State Feed laws so we’re stuck with them. Knowing a few key pieces of information will help make them more user-friendly though. First thing to understand is that they are calculated from one of 2 different math formulas that can be used to estimate energy requirements for dogs and cats. These formulas were developed over 50 years ago on dogs and cats living in research setting (so minimal activity and minimal breed variation). The second thing to know is that even within those populations from 50+ years ago, individual variation was +/- 50%. In my experience calculated energy requirements very rarely match actual needs of dogs and cats living in home environment. I collected food intake information on every dog and cat I saw for the last 12+ years and compared it with the calculated energy “requirement” (yep, math and nutrition nerd) and they rarely matched. For example, the “average” 40 lb mixed breed dog has calculated requirement of either 986 Calories per day or 1182 Calories per day (depending on the formula used) and then when you factor in normal variation for physical activity and medical health you have a potential daily Calorie range of 493 to 1773(!). Pet Food Companies can’t possibly give guidelines that will work for every animal, but they can give us a place to start. Even better yet would be for every dog and cat owner to keep track of how much your dog or cat needs to eat to maintain an ideal body condition. Then you can make your own feeding guideline based on Calories per cup or can that are provided on the package. The most important aspect of feeding (other than making sure the diet is balanced) is to keep your canine or feline companion at an optimal weight for their size, irrespective of actual amount fed.
- Nutrition Adequacy Statement
This is another part of the label that I use to evaluate the quality of a Pet Food Company itself. Every pet food requires a statement that the food is either “complete or balanced…” for a given life-stage (growth, adult maintenance, or both) or is intended for “for supplemental or intermittent feeding”. Food intended to support normal healthy animals is labels as “complete and balanced” and things like treats are “intermittent feeding only”. So if you are feeding your dog only dog cookies each day, you may want to check the label. Certain therapeutic diets, like ones developed for animals with kidney disease, may also be labeled as “intermittent feeding only” and are ok to use longer-term when needed but should only be fed under veterinarian supervision.
Pet Food Companies have two ways of gaining a “complete and balanced” Adequacy Statement. One way is to generate a formula for a diet on a computer, make sure it meets the established mins and maxs for essential nutrients according to AAFCO recommendations, make the food, and then sell it. This is a diet that has been “formulated to meet the needs”. The other way a “complete and balanced” Adequacy Statement can be written is that it has gone through “feeding trials”. A diet that has undergone feeding trials also starts with a computer generated formula, making sure that it meets the established mins and maxs for essential nutrients according to AAFCO recommendation. The food is then made and feed it to a group of test subjects in a controlled environment to ensure nutritional adequacy before being sold for feeding to other dogs and cats.
AAFCO Feeding Trials have strict minimum standards. The diet used in the trial must come from the same batch of food (to minimize batch-to-batch variation that can occur and may influence blood work values); it must be fed exclusively (so no treats or substitutions allowed); it must have a minimum number of animals (only 8, which is not a huge number, but will still tell you if the food has any major concerns); must be fed for a designated period of time (6 months for a maintenance trial); and all animals must meets basic physical exam and blood work parameters for heath during the time of the trial. Feeding Trials are not mandatory in order to sell a pet food and the minimum requirements for an AAFCO Feeding Trial are not considered the “gold standard” for optimal nutrition by any legitimate Pet Food Company, but a Feeding Trial will give the company an idea of whether there are any larger issues with their assumed “complete and balanced” formulations. Every dog and cat food sold in the US started as a diet that was “formulated to meet the needs”, but certain problems (like nutrient interactions) won’t show up on a computer screen, but would be hard to miss in a Feeding Trial.
- Calorie Statement
The American College of Veterinary Nutrition (ACVN) has helped advise AAFCO for years and in 2005 ACVN began petitioning to have a Calorie Statement added to the label requirements; finally in 2011 it gained approval and in 2012 having a Calorie Statement was officially added to the AAFCO Model Bill and Guidelines. Your ACVN in action!
What can you take home from this?
Today’s pet food labels aren’t perfect, but there is a good bit of information on what I consider “company quality” that you can find when you start reading labels with an educated eye. Does the company make their own food? If they don’t will they tell you who does? Are they monitoring quality of their products? Or simply making money at the expense of dog and cat health? Everyone thinks that their food is the best, but I tend to have a preference for companies that are willing to spend a little bit of money to prove it. If you want to read more about pet foods and label regulations check out websites for AAFCO and the FDA.
Lisa P. Weeth, DVM, MRCVS, DACVN