Pet Food Labeling
Surfing the web and entering “pet food labeling” into a search engine yields
five million three hundred and forty thousand hits, although, we know that
not all these hits are valid or completely answers the question, it is still
a daunting task for the average person to wade through so many links .
Many people do not know that pet food labeling is regulated at both the
federal and state level. Federal regulations are enforced by the Food and
Drug Administration’s Center for Veterinary Medicine (CVM). Many states have
adopted regulations for pet food labeling but most adopted those from the
model pet food regulations established by the Association of American Feed
Control Officials (AAFCO).
The following is based on the information found at this link:
Federal regulations cover product name, net quantity statement, guaranteed
analysis, nutritional adequacy statement, feeding directions, and other
The percentages of named ingredients in the total product are dictated by
four AAFCO rules.
The "95%" rule applies to products consisting primarily of meat, poultry or
fish, such as some of the canned products. They have simple names, such as
"Beef for Dogs" or "Tuna Cat Food." In these examples, at least 95% of the
product must be the named ingredient (beef or tuna, respectively), not
counting the water added for processing and "condiments." Counting the added
water, the named ingredient still must comprise 70% of the product. Since
ingredient lists must be declared in the proper order of predominance by
weight, "beef" or "tuna" should be the first ingredient listed, followed
often by water, and then other components such as vitamins and minerals. If
the name includes a combination of ingredients, such as "Chicken 'n Liver
Dog Food," the two together must comprise 95% of the total weight. The first
ingredient named in the product name must be the one of higher predominance
in the product. For example, the product could not be named "Lobster and
Salmon for Cats" if there is more salmon than lobster in the product.
Because this rule only applies to ingredients of animal origin, ingredients
that are not from a meat, poultry or fish source, such as grains and
vegetables, cannot be used as a component of the 95% total. For example, a
"Lamb and Rice Dog Food" would be misnamed unless the product was comprised
of at least 95% lamb.
The "25%" or "dinner" rule applies to many canned and dry products. If the
named ingredients comprise at least 25% of the product (not counting the
water for processing), but less than 95%, the name must include a qualifying
descriptive term, such as "Beef Dinner for Dogs." Many descriptors other
than "dinner" are used, however. "Platter," "entree," "nuggets" and
"formula" are just a few examples. Because, in this example, only
one-quarter of the product must be beef, it would most likely be found third
or fourth on the ingredient list. Since the primary ingredient is not always
the named ingredient, and may in fact be an ingredient that is not desired,
the ingredient list should always be checked before purchase.
If more than one ingredient is included in a "dinner" name, they must total
25% and be listed in the same order as found on the ingredient list. Each
named ingredient must be at least 3% of the total, too. Therefore, "Chicken
n' Fish Dinner Cat Food" must have 25% chicken and fish combined, and at
least 3% fish. Also, unlike the "95%" rule, this rule applies to all
ingredients, whether of animal origin or not. For example, a "Lamb and Rice
Formula for Cats" would be an acceptable name as long as the amounts of lamb
and rice combined totaled 25%.
Even a minor change in the wording of the name has a dramatic impact on the
minimum amount of the named ingredient required, e.g., a can of "Cat Food
With Tuna" could be confused with a can of "Tuna Cat Food," but, whereas the
latter example must contain at least 95% tuna, the first needs only 3%.
Therefore, the consumer must read labels carefully before purchase to ensure
that the desired product is obtained.
Net Quantity Statement
The net quantity statement tells you how much product is in the container. A
cost-per-ounce or per-pound comparison between products is always prudent.
All ingredients are required to be listed in order of predominance by
weight. The weights of ingredients are determined as they are added in the
formulation, including their inherent water content. This latter fact is
important when evaluating relative quantity claims, especially when
ingredients of different moisture contents are compared.
For example, one pet food may list "meat" as its first ingredient, and
"corn" as its second. The manufacturer doesn't hesitate to point out that
its competitor lists "corn" first ("meat meal" is second), suggesting the
competitor's product has less animal-source protein than its own. However,
meat is very high in moisture (approximately 75% water). On the other hand,
water and fat are removed from meat meal, so it is only 10% moisture (what's
left is mostly protein and minerals). If we could compare both products on a
dry matter basis (mathematically "remove" the water from both ingredients),
one could see that the second product had more animal-source protein from
meat meal than the first product had from meat, even though the ingredient
list suggests otherwise.
That is not to say that the second product has more "meat" than the first,
or in fact, any meat at all. Meat meal is not meat per se, since most of the
fat and water have been removed by rendering. Ingredients must be listed by
their "common or usual" name. Most ingredients on pet food labels have a
corresponding definition in the AAFCO Official Publication. For example,
"meat" is defined as the "clean flesh of slaughtered mammals and is limited
to...the striate muscle...with or without the accompanying and overlying fat
and the portions of the skin, sinew, nerve and blood vessels which normally
accompany the flesh." On the other hand, "meat meal" is "the rendered
product from mammal tissues, exclusive of any added blood, hair, horn, hide
trimmings, manure, stomach and rumen contents." Thus, in addition to the
processing, it could also contain parts of animals one would not think of as
"meat." Meat meal may not be very pleasing to think about eating yourself,
even though it's probably more nutritious. Regardless, the distinction must
be made in the ingredient list (and in the product name). For this reason, a
product containing "lamb meal" cannot be named a "Lamb Dinner."
Further down the ingredient list, the "common or usual" names become less
common or usual to most consumers. The majority of ingredients with
chemical-sounding names are, in fact, vitamins, minerals, or other
nutrients. Other possible ingredients may include artificial colors,
stabilizers, and preservatives. All should be either "Generally Recognized
As Safe (GRAS)" or approved food additives for their intended uses.
At minimum, a pet food label must state guarantees for the minimum
percentages of crude protein and crude fat, and the maximum percentages of
crude fiber and moisture. The "crude" term refers to the specific method of
testing the product, not to the quality of the nutrient itself.
Some manufacturers include guarantees for other nutrients as well. For dog
foods, minimum percentage levels of calcium, phosphorus, sodium, and
linoleic acid are found on some products.
Guarantees are declared on an "as fed" or "as is" basis, that is, the
amounts present in the product as it is found in the can or bag. This
doesn't have much bearing when the guarantees of two products of similar
moisture content are compared (for example, a dry dog food versus another
dry dog food). However, when comparing the guaranteed analyses between dry
and canned products, one will note that the levels of crude protein and most
other nutrients are much lower for the canned product. This can be explained
by looking at the relative moisture contents. Canned foods typically contain
75-78% moisture, whereas dry foods contain only 10-12% water. To make
meaningful comparisons of nutrient levels between a canned and dry product,
they should be expressed on the same moisture basis.
The most accurate means of doing this is to convert the guarantees for both
products to a dry matter basis. The percentage of dry matter of the product
is equal to 100% minus the percentage of moisture guaranteed on the label. A
dry food is approximately 88-90% dry matter, while a canned food is only
about 22-25% dry matter. To convert a nutrient guarantee to a dry matter
basis, the percent guarantee should be divided by the percentage of the dry
matter, then multiplied by 100. For example, a canned food guarantees 8%
crude protein and 75% moisture (or 25% dry matter), while a dry food
contains 27% crude protein and 10% moisture (or 90% dry matter). Which has
more protein, the dry or canned? Calculating the dry matter protein of both,
the canned contains 32% crude protein on a dry matter basis (8/25 X 100 =
32), while the dry has only 30% on a dry matter basis (27/90 X 100 = 30).
Thus, although it looks like the dry has a lot more protein, when the water
is counted out, the canned actually has a little more. An easier way is to
remember that the amount of dry matter in the dry food is about four times
the amount in a canned product. To compare guarantees between a dry and
canned food, multiply the guarantees for the canned food times four first.
It is especially important to look at the moisture guarantee for canned
foods, even when comparing a canned food with another canned. Under AAFCO
regulations, the maximum percentage moisture content for a pet food is 78%,
except for products labeled as a "stew," "in sauce," "in gravy," or similar
terms. The extra water gives the product the qualities needed to have the
appropriate texture and fluidity. Some of these exempted products have been
found to contain as much as 87.5% moisture. This doesn't sound like much
difference until the dry matter contents are compared. For example, a
product with a guarantee of 87.5% moisture contains 12.5% dry matter, only
half as much as a product with a 75% moisture guarantee (25% dry matter).
Nutritional Adequacy Statement
Any claim that a product is "complete," "balanced," "100% nutritious," or
similarly suggests that a product is suitable for sole nourishment that is
not, in fact, nutritionally adequate is a potentially unsafe product. For
this reason, an AAFCO nutritional adequacy statement is one of the most
important aspects of a dog or cat food label. A "complete and balanced" pet
food must be substantiated for nutritional adequacy by one of two means.
The first method is for the pet food to contain ingredients formulated to
provide levels of nutrients that meet an established profile. Presently, the
AAFCO Dog or Cat Food Nutrient Profiles are used. Products substantiated by
this method should include the words, "(Name of product) is formulated to
meet the nutritional levels established by the AAFCO (Dog/Cat) Food Nutrient
Profiles." This means the product contains the proper amount of protein,
calcium, and other recognized essential nutrients needed to meet the needs
of the healthy animal. The recommendations of the National Research Council
(NRC) were once used as the basis for nutritional adequacy, but they are no
longer considered valid for this purpose.
The alternative means of substantiating nutritional adequacy is for the
product to be tested following the AAFCO Feeding Trial Protocols. This means
that the product, or "lead" member of a "family" of products, has been fed
to dogs or cats under strict guidelines and found to provide proper
nutrition. These products should bear the nutritional adequacy statement
"Animal feeding tests using AAFCO procedures substantiate that (name of
product) provides complete and balanced nutrition."
Regardless of the method used, the nutritional adequacy statement will also
state for which life stage(s) the product is suitable, such as "for
maintenance," or "for growth." A product intended "for all life stages"
meets the more stringent nutritional needs for growth and reproduction. A
maintenance ration will meet the needs of an adult, non-reproducing dog or
cat of normal activity, but may not be sufficient for a growing,
reproducing, or hard-working animal. On the other hand, an all life stages
ration can be fed for maintenance. Although the higher levels of nutrients
would not be harmful to the healthy adult animal, they are not really
necessary. Occasionally a product may be labeled for a more specific use or
life stage, such as "senior" or for a specific size or breed. However, there
is little information as to the true dietary needs of these more specific
uses, and no rules governing these types of statements have been
established. Thus, a "senior" diet must meet the requirements for adult
maintenance, but no more. A product that does not meet either of these
methods must state that "this product is intended for intermittent or
supplemental feeding," except if it is conspicuously identified as a snack
Feeding directions instruct the consumer on how much product should be
offered to the animal. At minimum, they should include verbiage such as
"feed ___ cups per ___ pounds of body weight daily." On some small cans,
this may be all the information that can fit. The feeding directions should
be taken as rough guidelines, a place to start. Breed, temperament,
environment, and many other factors can influence food intake. Manufacturers
attempt to cover almost all contingencies by setting the directions for the
most demanding. The best suggestion is to offer the prescribed amount at
first, and then to increase or cut back as needed to maintain body weight in
adults or to achieve proper rate of gain in puppies and kittens.
Feeding directions vary among manufacturers, too, so the number of calories
delivered in a daily meal of one food may be quite different from another.
The number of calories in a product roughly relates to the amount of fat,
although varying levels of non-calorie-containing components, such as water
and fiber, can throw this correlation off. The best way for consumers to
compare products and determine how much to be fed is to know the calorie
content. However, until recently, calorie statements were not allowed on pet
food labels. New AAFCO regulations were developed to allow manufacturers to
substantiate calorie content and include a voluntary statement.
If a calorie statement is made on the label, it must be expressed on a
"kilocalories per kilogram" basis. Kilocalories are the same as the
"Calories" consumers are used to seeing on food labels. A "kilogram" is a
unit of metric measurement equal to 2.2 pounds. Manufacturers are also
allowed to express the calories in familiar household units along with the
required statement (for example, "per cup" or "per can"). Even without this
additional information, however, consumers can make meaningful comparisons
between products and pick the product best suited for their animals' needs.
As with the guaranteed analysis, the calorie statement is made on an "as
fed" basis, so corrections for moisture content must be made as described
above. To roughly compare the caloric content values between a canned and a
dry food, multiply the value for the canned food by four.
Other Label Claims
Many pet foods are labeled as "premium," and some now are "super premium"
and even "ultra premium." Other products are touted as "gourmet" items.
Products labeled as premium or gourmet are not required to contain any
different or higher quality ingredients, nor are they held up to any higher
nutritional standards than are any other complete and balanced products.
The term "natural" is often used on pet food labels, although that term does
not have an official definition either. For the most part, "natural" can be
construed as equivalent to a lack of artificial flavors, artificial colors,
or artificial preservatives in the product. As mentioned above, artificial
flavors are rarely employed anyway. Artificial colors are not really
necessary, except to please the pet owner's eye. If used, they must be from
approved sources, the same as for human foods. Especially for high-fat dry
products, some form of preservative must be used to prevent rancidity.
Natural-source preservatives, such as mixed tocopherols (a source of vitamin
E), can be used in place of artificial preservatives. However, they may not
be as effective.
"Natural" is not the same as "organic." The latter term refers to the
conditions under which the plants were grown or animals were raised. There
are no official rules governing the labeling of organic foods (for humans or
pets) at this time.
Pet owners and veterinary professionals have a right to know what they are
feeding their animals. The pet food label contains a wealth of information,
if one knows how to read it. Do not be swayed by the many marketing gimmicks
or eye-catching claims. If there is a question about the product, contact
the manufacturer or ask an appropriate regulatory agency.