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Exploring the petfood jungle (Proceedings)

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Apr 01, 2008

The massive amount of information and misinformation about petfoods on the World Wide Web, in books and publications, and elsewhere has led to considerable concern and confusion by the pet owning public. The unprecedented recall of petfoods in 2007 has increased scrutiny about how petfoods are manufactured and regulated. The veterinary technician must be knowledgeable of issues surrounding the petfood industry to effectively communicate with clients.

Regulation of petfoods

Petfoods are regulated at two levels. The US Food and Drug Administration (FDA) oversees all petfoods in interstate commerce (virtually everything on the market). Products that are adulterated or misbranded are subject to enforcement action. Federal regulations dictate basic labeling requirements, and lists of approved food additives and GRAS (generally recognized as safe) substances. There are no specific petfood regulations in the Code of Federal Regulations.

Most states also have authority over petfoods distributed in their jurisdictions, typically through the state's department of agriculture or chemist's office. Many require some sort of licensure of companies or registration of products before petfoods may be distributed in that state. Each applies its own set of regulations pertaining to labeling, ingredients, and other matters. The states often coordinate efforts with FDA, with FDA agency offering scientific, nutritional, and technical expertise to the states, and the states initiating the enforcement actions. Even though the state only has jurisdiction within that state's borders, an action against a company to change a product formulation or label by even just one state can have nation-wide impact.

To foster uniformity in regulation between the states, many have adopted the Model Bill along with associated regulations and ingredient definitions published by the Association of American Feed Control Officials (AAFCO). AAFCO is not a government agency, nor does it have any enforcement authority. However, all its members must be government employees. Contrary to many assertions, industry representatives do not have any voting rights within AAFCO, though they can serve as "committee advisors." Model AAFCO petfood regulations address issues of nutrient content, nutritional adequacy, and many other aspects not covered in FDA regulations. While these have no power of law in and of themselves, states that subsequently adopt the models do have the power to enforce them. The number of states that do follow the AAFCO models is sufficient so that they effectively apply to any product in interstate distribution.

Petfood requirements

Under FDA and AAFCO regulations, petfoods are subject to a host of labeling requirements that dictate acceptable product names, proper ingredient lists, nutritional content claims, and declarations of net weight and the manufacturer's or distributor's name and address. Other regulations or guidance dictate the nature and extent of claims such as "low calorie," "natural," and "veterinarian recommended." Claims that expressly or implicitly imply the treatment or prevention of a disease or condition, or to affect the structure or function of the body beyond normal nutrition may be deemed a "drug claim," which is not permitted on products intended to be sold as "foods." Under the law, the therapeutic dog and cat diets often distributed through veterinary facilities could be considered "unapproved drugs." However, FDA generally tolerates their presence in the market as long as claims regarding diet and disease are intended for the veterinarian, not the consumer, and/or the product is only distributed by means of a valid veterinarian/client/animal relationship. Inappropriate use of therapeutic diets by untrained persons without veterinary oversight may be harmful to the animal.