REGULATIONS & INGREDIENT DEFINITIONS FOR CONSUMERS

PET FOODREGULATIONS &INGREDIENTDEFINITIONS

FOR CONSUMERS

Provided for pet food consumers by Susan Thixton, pet food consumer advocate.TruthaboutPetFood.comAssociationforTruthinPetFood.com

This document is based on the Model Bills and legal definitions published in the AAFCOOfficial Publication. All content is accurate and written in consumer language (not legallanguage).

This document is solely for pet food consumers

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Regulations

This document is solely for pet food consumers.Provided by Susan Thixton, pet food consumer advocate. TruthaboutPetFood.com and AssociationforTruthinPetFood.com

All laws across the US are public information, except pet food laws. Some minimal information is posted onthe FDA website, some minimal information is posted on various State Department of Agriculture websites.The majority of the regulations/laws that govern pet food is published in the AAFCO Official Publicationwhich consumers have no free access to. Below you’ll find some of the more significant pet food regulationsrewritten in consumer language.

Illegal and Legal

On the FDA website consumers will find“Compliance Policies” that FDA uses asguidance to regulate pet food. Quoting one(of many) FDA policies:

Material from diseased animals oranimals which have died otherwise than byslaughter” is a direct violation of federallaw. Though it is difficult to understandhow and why FDA and each StateDepartment of Agriculture ignore federaland state laws, consumers must be awarethat authorities DO allow this in pet food.There is no warning on pet food labelsalerting consumers to the potential ofillegal/risk ingredients.

Consumer advocates continue to questionauthorities on these issues. Authoritiescontinue to stall, failing to fully explainhow illegal/adulterated pet foods andtreats can be sold to unknowingconsumers.

Not all pet foods violate law. Some use onlyfood quality ingredients and manufactureaccording to food safety standards.However consumers struggle to determinewhich product is safe/legal and which isnot.

Existing regulations classify all pet foodsinto two separate categories: Feed Grade orHuman Grade (these terms are fullyexplained on following pages). Briefly,‘human grade’ pet foods are required toabide by all food safety laws, ‘feed grade’pet foods are not required to abide by foodsafety law (they might, but they are notrequired to). Unfortunately, both categoriesare termed ‘pet food’ (cat food or dog food)on product labels.

Pet Food Labels and Websites

AAFCO/FDA regulations require pet food labels and websites(websites are considered an extension to the label) to includeparticular information with intent to provide the consumer withsufficient information to make purchase decisions. The required‘sufficient’ label information is:

● Product and Brand name● Species statement (cat food or dog food)● Quantity statement (weight)● Guaranteed Analysis (disclosing protein and fat %

minimum, fiber and moisture % maximum)● Ingredient list (per AAFCO/FDA definitions)● Nutritional adequacy (if the pet food is ‘Complete’

providing all nutrients per AAFCO/FDA nutritionalrequirements or if the pet food is ‘Supplemental’ whichdoes not meet the AAFCO/FDA nutritionalrequirements)

● Feeding directions (not held to any regulatoryguidelines, feeding directions are at manufacturerdiscretion)

● Name and address of brand (not the actualmanufacturer and not contact information)

Images on pet food labels are required by AAFCO/FDAregulations to be a truthful representation of the ingredientswithin the pet food. However,

.

Statements on pet food labels and pet food websites arerequired by regulation to be truthful. However,

.

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All laws across the US are public information including legal definitions, except pet food definitions. On thefollowing pages you’ll find pet food ingredient definitions based on the legal definitions rewritten in consumerlanguage.

The ingredients used in pet foods and treats each have their own specific definition written by and owned byAAFCO (in cooperation with FDA). Pet food ingredients are NOT the same as human food ingredients. Each petfood ingredient has it’s own definition specific to pet food/animal feed. These definitions are published yearly inthe AAFCO Official Publication, cost to consumers $110.00 (per year).

Pet food manufacturers are not required to disclose to consumers if ingredients included in a pet food arehuman grade or an inferior and in some cases illegal AAFCO/FDA allowed alternative ingredient. Consumerscan trust that ‘Human Grade’ pet foods (stated on the label) contain 100% human grade ingredients andsupplements. For all other pet foods, ask the manufacturer questions regarding ingredient quality.


Pet Food IngredientDefinitions

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This symbol indicates the meat ingredient is required by the AAFCO/FDA definition to be sourcedfrom a slaughtered animal, but

. To confuse thingsfurther, there is no AAFCO definition of slaughter, thus the requirement to be sourced from a‘slaughtered animal’ is unclear in meaning.

Federal law defines a food as adulterated Diseased meat from non-

USDA approved animal sources would be a direct violation of this federal law.

Pet foods using these ingredients are not guaranteed to use non-USDA approved animal meat. Itonly means they are allowed to use non-USDA approved animal meat by AAFCO/FDA.

This symbol indicates the meat ingredient as federal food safety law requires. Pet food meat

sourced from a non-slaughtered animal is of significant risk.

Federal law defines a food as adulterated Meats sourced from non-

slaughtered animals would be a direct violation of this federal law.

Pet foods using these ingredients are not guaranteed to use non-slaughtered animal meat. It onlymeans they are allowed to use non-slaughtered animal meat by AAFCO/FDA.

Consumers are not provided with clarification to what quality of ingredients are included in the petfood they are purchasing. This section provides an example question to send to your pet foodmanufacturer regarding quality.

Also this section provides an example statement to send your State Department of Agricultureregarding the enforcement of law with pet food. Consumer action can help make pet food safer.


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Human Grade

Human grade pet foods are ‘food’ formulated for petconsumption. The AAFCO/FDA definition of HumanGrade pet products requires all food safety standardsof food to be met;

● manufacturing per human food regulation● warehousing per human food regulation● and ingredient quality (including

supplements) to be human edible.

Per regulation, this term is ONLY allowed to be usedwhen referencing the complete/final product (treatsor pet food). As example regulation does not allowmanufacturers to state human grade ingredients IFthe whole product does not meet the human grademanufacturing and warehousing requirements.

Human grade is considered a voluntary claim. Inother words, it is accepted by regulatory that all petfoods are feed grade unless a manufacturervolunteers to meet the quality standards of humangrade.

Consumers can trust a Human Grade claim on a petfood label – regulatory authorities scrutinize wordingon pet food labels.

–regulatory authorities do not scrutinize pet foodwebsites.


Pet FoodDefinitions

is ONLY thefollowing:

Ingredientssuitable for human

consumption

Manufactured perhuman food safety

standards

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Feed Grade

Ingredients or final product (treats or pet food) that isspecifically intended for animals. Ingredients or finalproduct are not required to be suitable for humanconsumption. The AAFCO/FDA definition of feedgrade

per FDA Compliance Polices orindividual State authority.

Consumers are never informed if ingredients in a petfood violate law. Pet food manufacturers are notrequired to disclose feed grade quality on pet foodlabels or websites.

All pet food/treat products are termed ‘food’; this ismisleading. Unless a pet food meets requirements ofHuman Grade claim - it is not food, it is feed/feedgrade.

Consumer advocates have requested FDA requirefeed grade pet foods to be labeled as feed (exampleCat Feed or Dog Feed), we are waiting on theirdecision.


Pet FoodDefinitions

could consist ofany of the following:

Ask your pet food manufacturer for a guarantee -in writing - if ingredients are feed grade or foodgrade.

Ask your State Department of Agriculture toenforce federal law with pet food.

Condemned animalmaterial, recycledwaste, inferior andillegal ingredients

Ingredientssuitable for human

consumption

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Animal By-Product Meal

A rendered (cooked prior to manufacturing of petfood) ingredient. The AAFCO/FDA definition allowsslaughtered or non-slaughtered whole animalcarcasses or any part of the animal including horn,hoof, hide and intestines (definition allows feces to beincluded). Any animal species is allowed in thisingredient.

Species source is required to be declared on the label(example Beef by-product meal) or if multiple animalspecies included ingredient is declared on the labelas Animal by-product meal.



inpet food could consist of any of

the following:

USDA inspected andcondemned animal

tissues

Tissues from animalsthat were never USDA

inspected orslaughtered such as

animals that have diedin the field and eveneuthanized animals

USDA inspectedand approvedanimal tissues(human edible)

Ask your pet food manufacturer for a guarantee -in writing - that animal by-product meal issourced from USDA inspected and approvedanimal tissues. For safety and quality nutrition,this ingredient should ONLY be sourced fromUSDA inspected and approved animal tissues.

Ask your State Department of Agriculture toenforce federal law with pet food; ask that Animalby-product meal be required to be sourced fromUSDA inspected and approved animalingredients.

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Animal Digest

Animal digest is material sourced from any species ofslaughtered or non-slaughtered animal carcass oranimal part that has been partially processed throughchemicals and water – hydrolysis. Animal digest doesnot include hair, horn, hoofs. Any animal species isallowed in this ingredient.

Animal digest can be stated on the label as speciesspecific such as ‘ ’ but is most commonlystated on the label as ‘Animal digest’ includingmultiple species of animal sources.



in pet foodcould be sourced from any of

the following:


tissues





Ask your pet food manufacturer for a guarantee -in writing - that animal digest is sourced fromUSDA inspected and approved animal tissues.For safety and quality nutrition, this ingredientshould ONLY be sourced from USDA inspectedand approved animal tissues.

Ask your State Department of Agriculture toenforce federal law with pet food; ask that Animaldigest be required to be sourced from USDAinspected and approved animal ingredients.

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Animal Fat

Animal fat is obtained from the rendering (cooking) ofslaughtered or non-slaughtered animal proteins, thefat is separated from the meat/protein material. Anyanimal species is allowed in this ingredient.

Animal Fat could be stated on the label speciesspecified such as ‘ ’ or if it is acombination of animal species would be stated on thelabel as ‘Animal Fat’.



in pet food couldbe sourced from any of the

following:


tissues





Ask your pet food manufacturer for a guarantee -in writing - that animal fat is sourced from USDAinspected and approved animal tissues. For safetyand quality nutrition, this ingredient should ONLYbe sourced from USDA inspected and approvedanimal tissues.

Ask your State Department of Agriculture toenforce federal law with pet food; ask that Animalfat be required to be sourced from USDAinspected and approved animal ingredients.

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Fish Meal

The AAFCO/FDA definition of fish meal is not definedto any specific type of fish, any fish is allowed. Meal inthis instance implies the fish/fish parts were driedprior to the manufacture of the pet food; there is norestrictions/requirements to how product is dried. Theingredient can contain whole fish or fish cuttings or acombination of both.

If one species of fish is used, it is required to bedescribed as such on the label; example: MenhadenFish Meal. If more than one species the ingredient willbe listed as Fish Meal.



ingredients can bepreserved with no disclosure

to consumers:

Risk chemical -ethoxyquin

Naturox - saferalternative

Ask your pet food manufacturer for a guarantee -in writing - that the fish meal is preserved withoutthe use of ethoxyquin. Ethoxyquin is a riskpreservative linked to multiple health concerns.

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Liver

Animal organ meat sourced from slaughtered or non-slaughtered animals.

Liver could be stated on the label species specifiedsuch as ‘ ’ or ‘ ’ or if it is acombination of animal species would be stated on thelabel as ‘Liver’.



in pet food could besourced from any of the

following:


liver

Liver from animalsthat were never USDA



USDA inspectedand approvedanimal liver

(human edible)

Ask your pet food manufacturer for a guarantee -in writing - that liver is sourced from USDAinspected and approved animals. For safety andquality nutrition, this ingredient should ONLY besourced from USDA inspected and approvedanimal.

Ask your State Department of Agriculture toenforce federal law with pet food; ask that liver berequired to be sourced from USDA inspected andapproved animals.

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Meat

Meat in pet food is flesh from slaughtered mammals,does not include bone, and can include parts of theanimal not typically understood as meat in humanfood, such as the tongue or heart.

Meat would be stated on the label species specifiedsuch as ‘ ’ or ‘ ’.




following:

USDA inspected andcondemned meat

Meat sourced fromanimals that were

never USDA inspected

USDA inspectedand approvedmeat (human

edible)

The AAFCO/FDA definition of Meat in pet food isrequired to be sourced from a slaughtered animal,but is not required to be sourced from a USDAinspected and approved slaughtered animals asfederal food safety law requires.

Ask your pet food manufacturer for a guarantee -in writing - that meat is sourced from USDAinspected and approved animals. For safety andquality nutrition, this ingredient should ONLY besourced from USDA inspected and approvedanimal.

Ask your State Department of Agriculture toenforce federal law with pet food; ask that meatbe required to be sourced from USDA inspectedand approved animals.

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Meat By-Products

Meat by-products are defined as non-meat; caninclude lungs, stomach, and intestines (required to befreed of feces) from slaughtered mammals.

Meat by-products could be stated on the label speciesspecified such as ‘ or ‘

’ or if it is a combination of animal specieswould be stated on the label as ‘Meat by-products’.



in petfood could be sourced from

any of the following:

USDA inspected andcondemned meat by-

products

Meat by-productssourced from animalsthat were never USDA

inspected

USDA inspectedand approved

meat by-products(human edible)

The AAFCO/FDA definition of Meat by-products inpet food is required to be sourced from aslaughtered animal, but is not required to besourced from a USDA inspected and approvedslaughtered animals as federal food safety lawrequires.

Ask your pet food manufacturer for a guarantee -in writing - that meat by-products are sourcedfrom USDA inspected and approved animals. Forsafety and quality nutrition, this ingredient shouldONLY be sourced from USDA inspected andapproved animal.

Ask your State Department of Agriculture toenforce federal law with pet food; ask that meatby-products be required to be sourced fromUSDA inspected and approved animals.

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Meat Meal

A rendered (cooked prior to manufacturing of petfood) ingredient. The AAFCO/FDA definition of meatmeal specifies the ingredient is slaughtered or non-slaughtered mammal tissues, but allows non-tissuematerial such as horn, hoof, hide and intestines withfeces (definition allows feces to be included).

Meat meal would be stated on the label speciesspecified such as ‘ ’ or ‘ ’ or if itis a combination of animal species would be stated onthe label as ‘Meat meal’.



in pet food couldbe sourced from any of the

following:

USDA inspected andcondemned mammal

tissues


mammal tissues(human edible)




Ask your pet food manufacturer for a guarantee -in writing - that meat meal is sourced from USDAinspected and approved animals. For safety andquality nutrition, this ingredient should ONLY besourced from USDA inspected and approvedanimals.

Ask your State Department of Agriculture toenforce federal law with pet food; ask that meatmeal be required to be sourced from USDAinspected and approved animals.

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Meat and Bone Meal

A rendered (cooked prior to manufacturing of petfood) ingredient. Meat and bone meal can include theentire slaughtered or non-slaughtered animal carcassor any part of the animal including horn, hoof, hideand intestines with feces (definition allows feces to beincluded). Any mammal species is allowed in thisingredient.

Meat and bone meal would be stated on the labelspecies specified such as ‘ ’ or‘ ’ or if it is a combination ofanimal species would be stated on the label as ‘Meatand bone meal’.





USDA inspected andcondemned mammal

tissues


mammal tissues(human edible)




Ask your pet food manufacturer for a guarantee -in writing - that meat and bone meal is sourcedfrom USDA inspected and approved animals. Forsafety and quality nutrition, this ingredient shouldONLY be sourced from USDA inspected andapproved animals.

Ask your State Department of Agriculture toenforce federal law with pet food; ask that meatand bone meal be required to be sourced fromUSDA inspected and approved animals.

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Poultry

Poultry in pet food can include a combination of flesh,skin and bone from slaughtered poultry. TheAAFCO/FDA holds no requirement to whatpercentage of flesh, skin and/or bone the ingredientcontains – it would still be considered poultry if it wasmajority skin and bones. Poultry is required to be freeof feathers, heads, feet, and intestines.

Poultry would be stated on the label species specifiedsuch as ‘ ’ or ‘ ’.




following:

USDA inspected andcondemned poultry

Poultry that werenever USDA inspected


poultry (humanedible)

The AAFCO/FDA definition of Poultry in pet food isrequired to be sourced from a slaughtered animal,but is not required to be sourced from a USDAinspected and approved slaughtered animal asfederal food safety law requires.

Ask your pet food manufacturer for a guarantee -in writing - that poultry are sourced from USDAinspected and approved animals. For safety andquality nutrition, this ingredient should ONLY besourced from USDA inspected and approvedanimals.

Ask your State Department of Agriculture toenforce federal law with pet food; ask that poultrybe required to be sourced from USDA inspectedand approved animals.

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Poultry By-Products

Poultry by-products in pet food can includeslaughtered or non-slaughtered poultry heads, feet,intestines, feathers, or whole carcasses.

Poultry by-products could be stated on the labelspecies specified such as ‘ ’ or‘ ’ or if it is a combination ofanimal species would be stated on the label as‘Poultry by-products’.








Poultry sourced fromanimals that were never

USDA inspected and poultrysuch as spent hens (hens nolonger laying eggs) that areground whole (as they arenot slaughtered, they are

often groundalive/maceration or gassed)

Ask your pet food manufacturer for a guarantee -in writing - that poultry by-products are sourcedfrom USDA inspected and approved animals. Forsafety and quality nutrition, this ingredient shouldONLY be sourced from USDA inspected andapproved animals.

Ask your State Department of Agriculture toenforce federal law with pet food; ask that poultryby-products be required to be sourced fromUSDA inspected and approved animals.

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Poultry By-Product Meal

A rendered (cooked prior to manufacturing of petfood) ingredient. Poultry by-product meal in pet foodcan include feathers, heads, feet, undeveloped eggs,intestines or whole carcasses of slaughtered or non-slaughtered poultry.

Poultry by-product meal could be stated on the labelspecies specified such as ‘

’ or ‘ ’ or if it is acombination of animal species would be stated on thelabel as ‘Poultry by-product meal’.



inpet food could be sourcedfrom any of the following:




Poultry sourced from animalsthat were never USDA

inspected and poultry such asspent hens (hens no longer

laying eggs) that are groundwhole (as they are not

slaughtered, they are oftenground alive/maceration or

gassed)

Ask your pet food manufacturer for a guarantee -in writing - that poultry by-product meal issourced from USDA inspected and approvedanimals. For safety and quality nutrition, thisingredient should ONLY be sourced from USDAinspected and approved animals.

Ask your State Department of Agriculture toenforce federal law with pet food; ask that poultryby-product meal be required to be sourced fromUSDA inspected and approved animals.

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Poultry Meal

A rendered (cooked prior to manufacturing of petfood) ingredient. Poultry meal in pet food can includea combination of flesh, skin and bone of slaughteredpoultry. The AAFCO/FDA definition holds norequirement to what percentage of flesh, skin and/orbone the ingredient contains – it would still beconsidered poultry meal if it was majority renderedskin and bones. Poultry meal is required to be free offeathers, heads, feet, intestines.

Poultry meal would be stated on the label speciesspecified such as ‘ ’ or ‘ ’or if it is a combination of animal species would bestated on the label as ‘Poultry meal’.



in pet foodcould be sourced from any of

the following:


Poultry that werenever USDA inspected



The AAFCO/FDA definition of Poultry meal in petfood is required to be sourced from a slaughteredanimal, but is not required to be sourced from aUSDA inspected and approved slaughtered animalas federal food safety law requires.

Ask your pet food manufacturer for a guarantee -in writing - that poultry meal is sourced fromUSDA inspected and approved animals. For safetyand quality nutrition, this ingredient should ONLYbe sourced from USDA inspected and approvedanimals.

Ask your State Department of Agriculture toenforce federal law with pet food; ask that poultrymeal be required to be sourced from USDAinspected and approved animals.

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Supplements

Pet food supplements are included as feed grade orhuman grade similar to other ingredients. Feed gradesupplements would ONLY be suitable for animalconsumption and are not required to bemanufactured to the same safety standards as humanedible/grade supplements.



in pet foodcould be either of the

following:

Feed grade

Humangrade/human

edible

Ask your pet food manufacturer for a guarantee -in writing - that supplements are human grade.

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Vegetables, Fruits and Grains

The AAFCO/FDA definitions of most vegetable, fruitand grain ingredients are similar to the commonunderstanding of these ingredients with the exceptionthat none are required to be the same quality ashuman food and none are required to be transportedor warehoused the same as human food.



in pet food could beeither of the following:

Waste non-ediblevegetables, fruits and

grains

Humangrade/human

ediblevegetables, fruits

and grains

Ask your pet food manufacturer for a guarantee -in writing - that vegetable, fruit and grains aresourced from human edible products. For safetyand quality nutrition, these ingredients shouldONLY be sourced from human edible products.

Ask your State Department of Agriculture toenforce federal law with pet food; ask thatvegetable, fruit and grains be required to besourced from human edible products.

REGULATIONS & INGREDIENT DEFINITIONS FOR CONSUMERS

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