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Pet Food: The Lowdown on Labels
This article was originally printed by the U.S. Food and Drug Administration in FDA Consumer magazine, May-June 2001; updated by Michigan Dept. of Agriculture, August 2006.
Pet Food: The Lowdown on Labels
Walk into any pet food superstore or the pet food aisle of your local grocery store and you are met head-on by hundreds of products, all claiming to be just what your pet either wants or needs. Choosing from among the bags, cans, boxes, or pouches stacked on store shelves, or the bulk pet food in inviting open bins, can be a bit overwhelming. Which formulation of food is best? When does my dog need "adult formula"? Is "premium" cat food really better? Is "natural" food really healthier and will Fluffy think "gourmet" will taste better?
According to market researchers, U.S. consumers are expected to spend more than $13 billion a year on cat and dog food by the year 2006. To try to optimize their share of these dollars, pet food manufacturers work hard to make their products stand out among the many types of dry, moist, and semi-moist foods available. Today’s pet food packaging carries such descriptive words as "senior," "premium," "super-premium," "gourmet," and "natural." While these terms have no standard definition or regulatory meaning, other terms do have specific meanings, and pet foods, which are regulated by the Food and Drug Administration’s Center for Veterinary Medicine (CVM) and state agencies such as the Michigan Department of Agriculture, must carry certain information on their labels. Consumers can be confident that their pets are eating a nutritionally sound food if they understand the full significance of these labels.
The Right Stuff: Choosing a Good Pet Food
So how can pet owners choose the right food for their pets? Pet owners can start by examining three parts of the pet food label: the nutritional adequacy statement, the contact information for the manufacturer, and the list of ingredients.
For complete pet foods, the life stage claim, which is found in the nutritional adequacy statement on the label, will tell the pet owner which life stages of an animal the food is suitable for. The nutritional adequacy statement will also indicate how the product’s nutritional adequacy was substantiated, either by the product meeting one of the Association of American Feed Control Officials’ (AAFCO) Dog or Cat Food Nutrient Profiles or by passing an AAFCO Feeding Protocol Study.
Another item to check on the label is the contact information. Pet owners should look for the manufacturer's telephone number. Only the manufacturer's name and address are required, but a consumer affairs telephone number allows people to call manufacturers and request additional information about their products.
The list of ingredients on the label informs purchasers about the composition of the product. Pet owners who do or do not want to feed a pet a certain ingredient can look at the ingredient list to make sure that particular substance is included or excluded.
Some people prefer to pass up animal by-products, which are proteins that have not been rendered and may contain heads, feet, viscera and other animal parts not particularly appetizing.
"Meal" is another ingredient that some people like to avoid. In processing meat meal or poultry by-product meal, by-products are rendered (heat processed), which removes the fat and water from the product. Meat or poultry by-product meal contains parts of animals not normally eaten by people. Sometimes protein quality of by-products is nutritionally equivalent to or better than that from muscle meat.
Some consumers try to avoid pet foods with synthetic preservatives, such as butylated hydroxyanisole (BHA), butylated hydroxytoluene (BHT), and ethoxyquin. BHA and BHT are antioxidants. Oxygen reacts preferentially with BHA or BHT rather than oxidizing fats or oils, thereby protecting them from spoilage. Ethoxyquin, in particular, has been hotly debated. Current scientific data suggest that ethoxyquin is safe, but some pet owners avoid this additive because of a suspected link to liver damage and other health problems in dogs. CVM has asked pet food producers to voluntarily lower their maximum level of ethoxyquin in dog food while more studies are being conducted on this preservative, and the industry is cooperating.
Many products preserved with naturally occurring compounds, such as tocopherols (vitamin E) or vitamin C, are available. These products have a much shorter shelf life than those with synthetic preservatives, especially once a bag of food is opened.
Some animal nutritionists recommend switching among two or three different pet food products every few months. Nutritional advice for people to eat a wide variety of foods also applies to pets. Doing so helps ensure that a deficiency doesn't develop for some as yet unknown nutrient required for good health. When changing pet foods, add the new food to the old gradually for a few days to avoid upsetting the pet's digestive system.
Pet Food Safety and Nutrition
No matter what choice they make, consumers can take comfort in knowing that pet food is manufactured under a series of standards and regulations. These regulations require some nutrients and additives, disallow others, and stipulate certain information that must be on the label. The labels of packages and cans of commercial cat and dog food must list five pieces of information: guaranteed analysis, nutritional adequacy statement, ingredients, feeding guidelines, and the manufacturer's name and address.
With the exception of a nutritional adequacy statement, these items must also appear on commercial food labels for other pets, such as gerbils, snakes, and parakeets.
The guaranteed analysis specifies the product's minimum percentages of crude protein and crude fat. It also gives the maximum percentages of crude fiber and moisture. ("Crude" refers to a specific method of measuring the nutrient, and is not an indication of quality.) Although not required, some manufacturers also specify the percentages of other nutrients, such as ash and taurine in cat food, and calcium and phosphorus in dog food.
The amounts of crude protein and most other nutrients appear less for canned products than for dry ones because of differences in moisture content. Canned foods typically contain about 75 percent moisture, while dry foods contain only about 10 percent.
The nutritional adequacy statement assures consumers that a product meets all of a pet's nutritional needs. The Association of American Feed Control Officials (AAFCO), an advisory body of state and federal feed regulators, develops recommended standards for nutrient contents of dog and cat foods. AAFCO also publishes ingredient definitions and regulations. Having officially recognized definitions for ingredients assures that when different companies list the name of an ingredient on a pet food label, that ingredient meets the definition and standards that have been established for it, and is the same in every product.
The FDA's CVM works in partnership with AAFCO to determine safe pet food ingredients and testing protocols. In addition to federal regulation of pet food, most state governments regulate pet foods and labeling through their agricultural departments, such as the Michigan Department of Agriculture. AAFCO has created a model feed bill that states often adopt in their own laws.
CVM gives scientific and regulatory advice to AAFCO and the states on pet food issues, and CVM representatives serve on AAFCO committees and meet regularly with AAFCO's board of directors. CVM investigators also team with AAFCO to check out questionable pet food ingredients or claims.
Manufacturers can show their food meets AAFCO's standards for nutritional adequacy by calculations or by feeding trials. Calculations estimate the amount of nutrients in a pet food either on the basis of average nutrient content of its ingredients, or on results of laboratory tests--but not animal feed tests. If the calculations show that the food provides sufficient nutrients to meet the specific AAFCO nutritional profile referenced, the pet food label must carry the statement: "(Name of product) is formulated to meet the nutritional levels established by the AAFCO (Dog or Cat) Food Nutrient Profiles for (specific life stage)."
Feeding trials signify that the manufacturer has tested the product in dogs or cats under strict guidelines. Products found to provide proper nutrition based on feeding trials must carry the statement: "Animal feeding tests using AAFCO procedures substantiate that (name of product) provides complete and balanced nutrition for (specific life stage)."
Some pet foods which have not themselves been tested in feeding trials, but are nutritionally similar to another (lead) product in the company’s line that has been tested, may be considered nutritionally adequate based on acceptable test results of the lead product. Products that claim to provide proper nutrition based on comparison with a tested product must carry the statement: "(Name of product) provides complete and balanced nutrition for (specific life stage), and is comparable in nutritional adequacy to a product which has been substantiated using AAFCO feeding tests.” To qualify for comparison to a lead product, the untested products must be of the same product type (dog food vs. cat food), product moisture (dry, semi-moist, canned), and metabolizable energy content and nutrient levels as the tested lead product.
Regardless of the method used, the nutritional adequacy statement on a cat or dog food label must also tell which life stage the product is suitable for. AAFCO has established two nutrient profiles each for dogs and cats--growth/lactation and maintenance--to fit their life stages.
Every complete product must meet at least one of these two profiles or have passed one or more feeding studies. A product intended for growing kittens and puppies, or for pregnant or lactating females, must meet AAFCO's nutrient profile for growth/lactation. Products that meet AAFCO's profile for maintenance are suitable for an adult, non-reproducing dog or cat of normal activity level, but may not be adequate for an immature, reproducing, or hard-working animal. A product may claim that it is for "all life stages" if it is suitable for adult maintenance and also meets the more stringent nutritional needs for growth and reproduction.
Growth/lactation and maintenance are the only nutrient profiles authorized by AAFCO and CVM, so terms like "senior" or "formulated for large breed adults" essentially mean the food meets the requirements for adult maintenance.
Snacks and treats that are clearly identified as such are not required to include a nutritional adequacy statement. But these foods, in all other respects, must meet FDA and state regulations for pet food labeling. Dog chews made from rawhide, bone, or other animal parts (such as pig ears) are also considered "food" since pets eat them. These products must bear a list of ingredients and provide the manufacturer's name and address, but they are not required to give a guaranteed analysis, nutritional adequacy statement, or feeding directions.
Like human foods, pet foods are regulated under the Federal Food, Drug, and Cosmetic Act, and must be pure and wholesome and contain no harmful substances. They also must be truthfully labeled. Foods for human or pet consumption do not require FDA approval before they are marketed, but they must be made with ingredients that are "generally recognized as safe" (GRAS) or ingredients that are approved food and color additives. If scientific data show that an ingredient or additive presents a health risk to animals, CVM can prohibit or modify its use in pet food.
Pet food ingredients must be listed on the label in descending order by weight, but consumers should realize that the weight includes the moisture in the ingredient, making it tricky sometimes to tell which ingredients provide the preponderance of one or more nutrients. A moist ingredient, such as beef, which may be 70 percent water, may be listed ahead of a dry ingredient, such as soybean meal, which is only 10 percent water--yet the soy actually contributes more protein to the diet.
Similar materials listed as separate ingredients may outweigh other ingredients that precede them on the list of ingredients. For example, chicken may be listed as the first ingredient, then wheat flour, ground wheat, and wheat middlings. The consumer may believe that chicken is the predominant ingredient, but the three wheat products--when added together--may weigh more than the chicken.
Just as dietary supplements for people are growing in popularity, so are animal food supplements for pets.
The FDA considers animal food supplements that are not approved nutrients or GRAS to be unapproved food additives or unapproved new animal drugs. As such, they are not permitted in pet food. Nevertheless, consumers will see on some cat and dog food labels ingredients such as glucosamine and chondroitin, which are claimed to alleviate joint stiffness and pain, and St. John's wort, purported to treat depression and relieve stress.
Neither the FDA nor state feed control officials have the number of employees required to monitor every supplement and food manufacturer and prevent those using unapproved ingredients from selling their products. The same forces apply for why police cannot write speeding tickets to everyone driving over the speed limit. That doesn't make speeding legal.
Pet owners should check with their veterinarians before giving their pets supplements, whether alone or in a food product. Dogs and cats are not small furry people and pet owners should not assume that a supplement they take themselves is good for their pet.
Table Scraps May Be Dangerous
Some people think a food that they eat is good for their pets. This is not necessarily true. Some human foods, in fact, may be dangerous to pets. Depending on their size and breed, small amounts of chocolate, onions, macadamia nuts and bread dough can be fatal if ingested by a dog.
Also because of their different body chemistry and nutritional requirements, cats should not be fed dog food.
Feeding directions on pet food provide only a broad guideline. Nutritional requirements vary according to a pet's age, breed, body weight, genetics, amount of activity, and even the climate in which the pet lives.
Many owners are guilty of overfeeding their pets, and even a "light" food can cause weight gain if fed in excess of caloric needs. Studies estimate that between 25 and 40 percent of dogs and cats that enter a pet clinic are overweight. Obesity can shorten a pet's life by contributing to heart and liver problems, diabetes, arthritis, bladder cancer, and skin disorders and it can put a pet at higher risk while undergoing anesthesia and surgery. Pet owners should consult their veterinarians for the appropriate amount and type of food to give their pets, especially those that are overweight.
A pet food can claim to be "light" or "lean" only if it meets AAFCO's standard definitions for these terms. These definitions differ for dog and cat food and also depend on the moisture content of the food. The words "light," "lite" and "low calorie" all have the same meaning.
The words "lean" and "low fat" also mean the same thing. But "less calories" and "reduced calories" mean only that the product has fewer calories than another product, and "less fat" and "reduced fat" mean the product is less fatty than another one. In both cases, the manufacturer must state on the label the percentage of reduction and the name of the product of comparison.
Many pet food labels do not provide calorie content, but consumers can get this information by contacting the manufacturer, whose location must be on the label. Many manufacturers provide a toll-free number for consumers as well as their Web site address.
When a 'Food' is a 'Drug'
Statements that a product can treat, prevent or reduce the risk of a disease are considered drug claims and are not allowed on pet food. CVM also disallows claims such as "improves skin and coat," "prevents dry skin," and "hypoallergenic." Consumers may see phrases such as "promotes healthy skin" and "promotes glossy coat." CVM permits these claims, but any healthy animal that gets adequate nutrition should have these qualities anyway without eating a special food.
Recognizing the close link between diet and disease, CVM does allow certain health-related information on labels to help consumers evaluate pet foods. For example, while a product cannot claim to treat feline lower urinary tract disease, a concern for some cat owners, it may make the claim that the food "reduces urine pH to help maintain urinary tract health," provided data generated by the manufacturer and reviewed by CVM support the statement.
CVM permits some dental claims on pet foods. The grinding and scraping action created by the jaw movement of animals as they chew on certain foods or treats, or some chemicals in foods, can help reduce plaque and tartar, so CVM allows claims such as "helps control plaque" and "helps control tartar." CVM does not allow claims to treat or prevent gingivitis or periodontal disease because these are claims to treat disease.
Pet owners may see claims such as "improves doggie breath" on pet food or treats. These claims have no regulatory meaning; manufacturers use them simply to promote their products.
The phrase "recommended by veterinarians" also has no regulatory meaning. There is no minimum number or percentage of veterinarians required for a company to be able to state its product is recommended by veterinarians.
While a label may be truthful in stating “veterinarian recommended,” it could be misleading at the same time. Consider for example that some companies in the business of selling pet food are owned by or employ veterinarians with a vested interest in making a profit.
CVM provides manufacturers some latitude in making health claims regarding a category of food known as veterinary medical foods, which consumers can obtain only through a veterinarian. Manufacturers design these foods to treat a particular disease or condition. Although not regulated as drugs, these foods may carry health information in promotional materials for the veterinarian to help them treat their patients correctly.
For additional regulatory information on pet food and labeling, call CVM at 240-276-9300 or visit http://www.fda.gov/cvm/.
Keeping Pet Food Fresh
Always keep canned pet food refrigerated after opening. If you store dry pet food in a container other than its original bag, be sure to wash the empty container with soap and water before adding food from a new bag. The residual fat that settles on the bottom of the container can become rancid beyond its normal shelf life. This spoiled fat may contaminate fresh food added to the container, causing vomiting or diarrhea when fed to your pet.
Irradiation of Pet Food
In April 2001, the FDA approved an irradiation process that can be used on all animal feed and feed ingredients, including pet food and treats. This process can reduce the risk of contamination from all strains of Salmonella bacteria. Salmonella organisms can cause gastrointestinal upset and diarrhea in people and pets.
Irradiation is a process in which products are exposed to sources of ionizing radiation which cause chemical, not nuclear, changes similar to other conventional cooking or preservation methods. It has already been approved for use on a variety of human foods. Extending this process to animal feed and feed ingredients will not only increase the safety of the feed for the animals consuming it, but to people who handle animal feed and feed ingredients. Irradiation is a useful tool for reducing disease risk.
Irradiation treatment compliments, but does not replace, the need for proper food handling practices in the production, processing, and handling of animal feed and pet foods including treats. Pet owners need to practice safe food handling practices after handling pet treats, including washing hands thoroughly in warm water and with soap after any contact.
Pet Food and the Risk of 'Mad Cow Disease'
Bovine spongiform encephalopathy (BSE), commonly known as "Mad Cow Disease," has not been detected in horses, dogs, and other pets, such as birds, reptiles, and gerbils. However, a feline version of BSE, first identified in 1989, has been documented in domestic cats in Europe, mostly in the United Kingdom, according to the U.K.'s Ministry of Agriculture, Fisheries and Food.
While a very small number of cases of BSE have now been confirmed in the United States in cattle, no cases of BSE or similar forms of the disease have ever have been found in cats in this country. The same precautions that the U.S. government is taking to keep BSE from spreading throughout this country's cattle herds are also protecting our pets.
Scientists believe BSE is transmitted through animal feed containing certain animal proteins that may harbor the BSE agent. In 1997, the FDA adopted a BSE feed regulation that prohibits the feeding of certain animal proteins to ruminants in the United States. And in October 2005, the FDA proposed an amendment to the regulation that requires the removal of certain high-risk materials from all animal feed, including pet food.
Since December 2000, the U.S. has banned imports of animal proteins--from any species--from countries that either are known to have BSE in their cattle herds or are considered at high risk for having it. This means that no meat-containing pet food can legally be imported from a country at risk for BSE.
Making Sense of 'Light' and 'Lean' in Pet Food
The calorie and fat contents listed below are the maximum limits allowed in dog and cat food labeled "light" or "lean." These definitions are established by the Association of American Feed Control Officials and authorized by the FDA. Comparisons between products in different categories of moisture content are considered misleading.
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