A Sum of Its Parts: Understanding Pet Food Labels, Part 2 of 2.

So what exactly is in that pet food you are feeding?

Words and phrases found in the List of Ingredients (like “corn gluten meal” or “poultry by-product”) have very specific definitions within the pet food industry, but can seem vague and confusing for anyone on the outside. And many alternative pet food companies and self-appointed pet food “advice” websites will use misinformation and fear-mongering to promote their foods or philosophies. My hope is that by providing the actual legal definitions of pet food ingredients, it will help dog and cat caregivers (owners and veterinarians alike) make the best decisions they can when it comes to selecting a food for their beloved companion.

mybowl image

What’s in your bowl? Hint: it doesn’t actually look like that.

The word used for ingredient names in dog and cat foods are determined by laws adopted by individual states as recommended by the Association of American Feed Control Officials (AAFCO) Model Bill and Guidelines. AAFCO was founded in 1909 to help guide what was at the time a fledgling feed industry. Unfortunately (at least in my opinion), as pet ownership evolved over the last 105 years, the rules and regulations on pet food labels and ingredients haven’t quite kept up. The ingredient definitions that the pet food industry has to work with today are a relic of a time when most pet owners didn’t read any food labels, let alone quibbled about what exactly was in “meat by-product”.

Without further ado I will give you what I consider the not-so-secret ingredient definitions from the 2014 AAFCO Official Publication …

  1. Meat and Meat By-Product = From Regulation PF5; Ingredients (b): “The ingredients “meat” and “meat by-product” shall be qualified to designate the animal from which the meat and meat by-product is derived unless the meat and meat by-product are made from cattle, swine, sheep, goats, or any combination thereof.”
  • Translation:  “Meat” cannot be dog, cat, horse, road kill, etc, unless specifically named as such. If it isn’t beef, pork, sheep (lamb/mutton), or goat it cannot legally be included as “meat” or as a “meat by-product”.
  1. Meat = From Official Names and Definitions of Feed Ingredients; Item 9.2: “Meat is the clean flesh derived from slaughtered animals and is limited to that part of the striated muscle which is skeletal or that which is found in the tongue, in the diaphragm, in the heart, or in the esophagus; with or without accompanying and overlying fat and the portions of skin, sinew, nerve, and blood vessels which normally accompany flesh. It shall be suitable for use in animal foods. If it bears a name descriptive of its kind, it must correspond thereto. (Adopted 1938, Amended 1939, 1963).”
  • Translation = It is the muscle and similar type animal proteins from any combination of cattle, swine, sheep and goats (if labeled as “meat”) or the muscle protein from a specifically named food animal  that hasn’t made its way into the human food supply chain. Not because these meats are unfit for human consumption, but because people in the US are squeamish about eating them (mmm, tongue…) or they are not economically feasible to sell as a human food.
  1. Meat By-Product = From Official Names and Definitions of Feed Ingredients; Item 9.3: “Meat by product is 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, bones, partially defatted low temperature fatty tissue, and stomach 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. (Proposed 1973, Adopted 1974, Amended 1978)”
  • Translation:  “Meat By-Product” is the edible, non-muscle meat protein portions of cattle, swine, sheep, goats, or “any combination thereof” that is not eaten widely by people in the US. It specifically excluded intestinal “contents” (i.e., poop) as well as the non-digestible parts on the animal. The internal organs like liver and kidney are typically what ends up in pet food and are the primary component of “by-product”, but these vitamin and mineral rich foods would otherwise go to waste in the US (we don’t eat much liver and onions now days…). It can technically include brain, but because of BSE concerns, brain is not a common component of “by-product”.
  1. Poultry = From Official Names and Definitions of Feed Ingredients. Item 9.57: “Poultry is the clean combination of flesh and skin with or without accompanying bones, derived from parts of whole carcasses of poultry or a combination thereof, exclusive of feathers, heads, feet or entrails. It shall be suitable for use in animal food. If it bears a name descriptive of its kind, it must correspond thereto. If the bone has been removed, the process may also be so designated by use of appropriate feed term. (Proposed 1978, Adopted 1979, Amended 1995, Amended 1997).”
  • Translation:  Poultry can technically be any bird species used in food animal production such as chicken, duck, turkey, quail, ostrich, or emu, although the reality is that it is almost always chicken, duck and turkey (with or without bone) that haven’t made their way into the human food supply chain. This is not because these poultry proteins are unfit for human consumption, but because people in the US only want to eat breast, leg/thigh, and wing meats and the rest of the frame needs to go somewhere. It is also important to note that bone is allowed unless the Pet Food Company specifically tells you so on the List of Ingredients.
  1. Poultry By-Product = From Official Names and Definitions of Feed Ingredients; Item 9.12: “Poultry By-Product must consist of non-rendered clean parts of carcasses of slaughtered poultry such as heads, feet, viscera, free from fecal contents and foreign matter except in such trace amounts as might occur unavoidably in good manufacturing practice. If the product bears a name descriptive of its kind, the name must correspond thereto. (Proposed 1963, Adopted 1964, Amended 2000).”
  • Translation:  It is everything except the frame meat from a chicken, duck, and/or turkey, but specifically not poop (“fecal contents”).  Yes, it can include heads and feet, but the reality is that poultry producers will usually get a higher price for heads and feet on the “ethnic” food market for human consumption (mmm, chicken feet…) than they will from the Pet Food Companies.  The internal organs are typically what end up in pet food and are the primary component of “by-product”, but again these vitamin and mineral rich foods would otherwise go to waste in the US.
  1. Poultry By-Product Meal = From Official Names and Definitions of Feed Ingredients. Item 9.10: “Poultry By-Product Meal consist of ground, rendered, clean parts of carcasses of slaughtered poultry such as necks, feet, undeveloped eggs, and intestines, exclusive of feathers, except in such amounts as might occur in good manufacturing practices. …[guaranteed amounts of specific nutrient are listed next, but I’ve left them out here]… If the product bears a name descriptive of its kind, the name must correspond thereto. (Proposed 1985, Adopted 1990, Amended 2000).”
  • Translation:  I don’t know why there are two different lists of what can be included in fresh vs. processed “poultry by-products”, but there are and there are some key differences between the two. The biggest being that chicken poop (“fecal contents”) is specifically excluded from fresh “poultry by-products”, but feathers are what is excluded “poultry by-product meal”. So if you follow the letter of the law, “poultry by-product meal” can include poultry feces, while “poultry by-product” can include feathers, but not vice-versa. Weird distinction, but now you know.
  1. Rendering = From Official Feed Terms: “cooking and separating process in which conditions such as time and temperature, with or without pressure, are sufficient to remove water, kill pathogenic microorganisms, and separate fats and oils from other components.”
  • Translation:  Meals are the dehydrated, defatted product of cooking an ingredient prior to incorporation into pet foods. Depending on the source protein, “meals” can be good ingredients or bad. Using animal protein “meals” allows for a very specific and consistent amount of protein in the diet without the worries of water or fat fluctuations that can affect formulation using fresh meats (of any kind), but the rendering process can alter the structure of essential amino acids making them less digestible and create a nutrient deficiency if not corrected by the manufacturer.
  1. Adulteration , Model Bill and Regulation
    1. Section 7 (a) (7): “If it consists whole or in part of any filthy, putrid, or decomposed substance, or if it is otherwise unfit for feed”
    2. Section 7 (a)(9): “If it is, in whole or in part, the product of a diseased animals or of an animal that has died otherwise than by slaughter”
  • Translation:  Only healthy food animals and non-disease parts can be included in pet foods, anything else is considered an “adulterant” and subject to legal action against the manufacturer or raw material provider. The truth about the types of animal proteins that can legally be added to pet foods is not nearly as exciting and head-line grabbing as telling pet owners that “4D” meats go into main stream pet food (4D=dead, dying, diseased and disabled if you haven’t heard this term before).
  1. Gluten = From Official Feed Terms: “The tough, viscid nitrogenous substance remaining when the flour of wheat or other grain is washed to remove the starch.”
  • Translation:  Gluten is just the generic term for protein from grains. People who have “gluten” sensitivities or Celiac Disease  are actually reacting to the proteins gliadin and glutenin that are specific to wheat, rye, and barley (grains in the wheat family); these are not found in corn or rice at all, so “corn gluten” or “rice gluten” can be eat by people  with documented “gluten” problems.
  1. Brewers Rice = From Official Names and Definitions of Feed Ingredients. Item 75.4: “Chipped Rice, Broken Rice, or Brewers Rice is the small fragments of rice kernels that habe been separated from the larger kernels of milled rice.”
  • Translation:  The less aesthetically pleasing pieces of rice that don’t end up in people foods. I love that the other synonymous terms are “broken” or “chipped” rice. I can understand why Pet Food Companies prefer the term “Brewers Rice” instead.
dog-food-label-9 - Copy

But real lamb is the first ingredient!

As a Veterinary Nutrition Specialist the only times I run into problems with some of these ingredients is when I encounter a dog or cat with food allergies or with liver dysfunction.  For animals with suspected food allergies previous diets that included “meat” and/or “poultry” on the List of Ingredients could potentially contain any combination of beef, pork, lamb, goat, chicken, duck and turkey, so I need to avoid all of them in the new diet; “Poultry By-Product Meal” can also include eggs, so now I have to add that to the list of foods to avoid, too. Animals with liver disease should not be fed diets with any “By-Products” since feeding organ meats (especially liver!) may worsen their clinical signs and increase the risk of developing hepatic encephalopathy or urate bladder crystals/stones. And the only times I worry about “Gluten” is if has been contaminated with melamine and cyanuric acid, which shouldn’t happen now that Pet Food Companies are testing for these potential contaminants, or if I have an animal with a suspected food allergy to that particular plant protein.

So why do some Pet Food Companies continue to use these vague, often misinterpreted ingredient names? My theory is that these terms were originally adopted into the AAFCO guidelines (1938 for the oldest, 1985 for the newest) at a time when pet owners wanted to buy the lowest cost food for their dogs and cats and the specific ingredients had little to no importance as long as the food was safe and healthful. BY using these general ingredient terms Pet Food Companies could provide a least-cost food that easily complies with label regulations. If a Pet Food Companies makes a food with “Meat”, “Poultry” or “By-Product” then they have what would I would considered an “open formulation” and are legally allowed to substitute nutritionally comparable ingredients depending on cost and ingredient availability, without having to submit new product approval to the FDA first.  If a Pet Food Company lists specific animal ingredients (like “Beef” or “Chicken”) then they have what I consider a “closed formulation” and any substitution to a specifically name ingredient list would be considered an “adulteration” and would be illegal unless they obtain prior approval, a process that can take months to years. These two methods of developing a pet food formulation are equally nutritious. “Open formulation” are easier and less expensive from a production standpoint, but are a pain when trying to find a novel diet to manage a suspected food allergy.

The take-home message…

Every ingredient used in a pet food is a “by-product” of the human food supply chain. If it wasn’t, only the very wealthy would be able to feed their pets (or themselves!) and we would have an even larger problem with food waste than we already do. Personally, I don’t have a problem with pet food manufacturers using the clean, edible parts of plants and animals that people would otherwise discarded, this is the ultimate in eco-friendly, sustainable feeding practices. I just wish you could walk down the pet food aisle without needing to consult the AAFCO Office Publication to understand the ingredient list!

Happy Feeding!

Lisa P. Weeth, DVM, MRCVS, DACVN

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8 thoughts on “A Sum of Its Parts: Understanding Pet Food Labels, Part 2 of 2.

  1. Hi Dr.Weeth,

    I’m hoping you can shed some light on what has been a source of confusion for me in regards to the use of 4 D product in pet foods. On the one hand ” the product of a diseased animals or of an animal that has died otherwise than by slaughter” is an adulterant and forbidden but on the other hand the Compliance Policy Guidelines seem to be saying if the product is processed ( rendered or canned) its use is allowed.

    From Compliance Policy Guideline Canned Pet Food : “Pet food consisting of material from diseased animals or animals which have died otherwise than by slaughter, which is in violation of 402(a)(5) will not ordinarily be actionable, if it is not otherwise in violation of the law. It will be considered fit for animal consumption.”
    http://www.fda.gov/ICECI/ComplianceManuals/CompliancePolicyGuidanceManual/ucm074710.htm

    The Compliance Policy Guideline for Rendered Animal Feed ingredients has similar wording: “No regulatory action will be considered for animal feed ingredients resulting from the ordinary rendering process of industry, including those using animals which have died otherwise than by slaughter, provided they are not otherwise in violation of the law.”
    http://www.fda.gov/ICECI/ComplianceManuals/CompliancePolicyGuidanceManual/ucm074717.htm

    Are these not saying that product from diseased animals and those that died (4 D) is allowed in processed pet foods? I always thought it was up to the individual manufacturer if these materials were used. Any light you can shed on this issue would be appreciated.

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    • Hi Aimee,

      Thanks for taking the time to read my post and for asking a very good question and point of clarification. You are asking about FDA Compliance CPG Sec. 690.300 Canned Pet Food and CPG Sec. 675.400 Rendered Animal Feed Ingredients.

      For those who are not familiar with these FDA Compliance CPG Sec. 690.300 Canned Pet Food Policy states:

      “Pet food consisting of material from diseased animals or animals which have died otherwise than by slaughter, which is in violation of 402(a)(5) will not ordinarily be actionable, if it is not otherwise in violation of the law. It will be considered fit for animal consumption.
      The Center will consider regulatory action based on low acid canned food violations alone where the report indicates a probable hazard to pets. CVM will also consider regulatory action against canned pet food on the basis of use of decomposed animal tissues or use of tissues containing violative drug residues.”

      And CPG Sec. 675.400 Rendered Animal Feed Ingredients Policy states:

      “No regulatory action will be considered for animal feed ingredients resulting from the ordinary rendering process of industry, including those using animals which have died otherwise than by slaughter, provided they are not otherwise in violation of the law.
      Rendered animal feed ingredients which contain harmful microorganisms, toxins or chemical substances may be considered adulterated under Section 402(a)(1) or (2) of the Act. Where a rendering procedure itself raises a question of disease transmission [i.e., Mad Cow disease], the ingredient made may be deemed adulterated under Section 402(a)(4).”

      Yes, you are correct that animals and parts of animals that have died by “means other than slaughter” can be used to make both wet- and dry-rendered ingredients that can then be used in canned pet foods as long as they were not decomposed prior to rendering and do not contain microorganisms, toxins or chemical substances that are known to be harmful to animals. This means that the diseased parts of animals (such as tumors) and animals that died either on the farm or on their way to slaughter facility can be cooked down and used in animal feeds as long as these animal proteins are not harmful to dogs and cats. Personally I don’t have a problem with tumors or dead food animals being rendered and used for pet foods since the rendering process cooks everything down to its basic protein structures, but I would have a problem if these ingredients were being used in place of fresh proteins (they have potentially different nutrient contents) or if an ingredient provider was substituting these lower cost ingredients in order to inflate profits (no one likes a cheater).

      Many major pet food manufacturers (including Big Pet Food) have made statements that they do not to use 4D animals in their foods because of pet owner concerns about the quality of these protein sources. I’m not completely versed in all of the intricacies of pet food manufacturing or food science technology, but I don’t know of a way to distinguish rendered proteins from “intentional slaughter” vs. “other than slaughter”. To my knowledge the rendering process makes it all generic protein slurry and masks this distinction. In order to control quality of starting materials, some pet food manufactures may require inspection of rendering facilities in the supply contracts or they may own the rendering facilities outright in order to control quality of starting materials, but not all companies will do this.

      ~Lisa Weeth

      Liked by 1 person

      • Thanks for clarifying that issue. I have found that when asked, BPF will state that they do not incorporate 4 D into their products. I do wish that they would make that well known on their websites to temper the “head line grabbing”.

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  2. Hi Lisa:

    I really enjoyed reading your posts. They are extremely well written and easy to understand.

    I just wanted to add to your section addressing “Nutritional Adequacy Statement” (NAS).

    When the NAS begins with “Animal feeding….”, most of the veterinarians and consumers assume that the product has gone AAFCO feeding trials, e.g. maintenance trial lasting a min of 6 months. This assumption could be totally false because most of the companies use diluted “Product Family” (PF) criteria. As you know well, that under the PF criteria you have to test a product (called as a Parent product) as per AAFCO feeding trial protocol. Other products (I call them children) can be put under its umbrella and can be related to the parent product by plus/minus 7.5% of the parent’s ME and by certain nutrients. Then the company conduct a 2-week feeding trial (rather than 6-month trial) on the children products and uses the NAS “Animal feeding…..” on children products.

    When you see a product on the shelf with NAS “Animal feeding…” you can not tell if the product has undergone a 6-month maintenance feeding trial or 2-week digestibility trial as per PF criteria. My industry experience tells me that, ALMOST ALL products sold OTC making “Animal feeding….” NAS have undergone diluted PF criteria. Doesn’t mean they are inadequate or bad. Therefore, I do not put too much emphasis of NAS “Animal feeding…..” anymore.

    In the Flavor rule, I believe, the flavored source must be present in the ingredient statement. It could be as little as 0.1%.

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    • Thanks, Avi, glad you have enjoyed my posts so far.

      I agree. At a time when people want truth in labels and advertising, the product “Family” is a loophole to the AAFCO feeding trials that I wish would close so that all pet foods were labeled honestly.

      The “Family” destination allows manufacturers to put one diet through the official 6-month feeding trial and then formulate a number of nutritionally equivalent diets and label them all as having gone through feeding trial, but without the trouble and expense of multiple trials. I understand why companies do this. If all diets in the “Family” are truly similar in ingredient quality and nutrient amounts to the “Lead” diet (the one that went through a 6-month trial) then all diets in the “Family” would be expected to pass without any problems. So why spend the extra money and put more animals through feeding trials than necessary? The AAFCO recommendations are that the “Family” products are made with similar ingredients, meet the dry matter percentages of key essential nutrients (like crude protein and calcium), and meet or exceed the nutrient profile of the “lead” product or AAFCO minimum nutrient requirements, without exceeding AAFCO maximums.

      What I should have added in my original post is that I use the presence of a feeding trial (any feeding trial) as an indicator that that particular Pet Food Company was willing to spend money on something other than their marketing budget and employee salaries. I admit that I do tend to favor pet food companies that support the field of dog and cat nutrition, whether it is challenging their own diets through feeding trials or supporting studies that further the understanding of dog and cat nutrition, or both.

      ~Lisa Weeth

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