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A peek inside the pet food industry (Proceedings)

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Apr 01, 2008

The United States petfood market has been estimated to be over 18 billion dollars annually. This is many times the size of the entire animal health product industry (e.g., animal drugs, vaccines, pesticides). While therapeutic diets intended for distribution through veterinarians are only a small proportion of total petfood sales, the opinion of the veterinarian as to the merits of a petfood is held in high regard by pet owners. It is no wonder, then, that the marketing of petfood products to the veterinary community is a priority to the industry.

Recent events have brought increased scrutiny as to how petfoods are made and regulated, and many pet owners are concerned. Some of that concern is legitimate, but much misinformation about petfoods on the World Wide Web and elsewhere has caused undue alarm. An accurate understanding of the petfood industry by the veterinarian is important to effectively communicate on these matters with clients.

Industry associations

The Pet Food Institute (PFI) is a major representative of the industry, with all its "active" members petfood manufacturers (affiliate members include ingredient suppliers, equipment and service providers, etc.). In fact, PFI boasts of representing the manufacturers of 98% of the petfood produced in the US. However, that membership is comprised of only about 30 petfood companies. Some members' names are very familiar to the consumer, while others not as much. In many cases, a company may manufacture product for distribution under a variety of names, i.e., "co-pack" for private brands, small companies, or even big companies in the case of specialized manufacturing methods, hence may not be an immediately recognizable force in the market.

The American Feed Industry Association (AFIA) represents a wider consortium of manufacturers of animal feeds, but includes many petfood companies. Many member of PFI are also members of AFIA. The American Pet Products Manufacturers Association (APPMA) includes members who manufacturer a wide variety of pet goods, including pet toys, leashes, beds, cages, drugs, and pesticides. However, a significant number of the 900-plus APPMA members produce some type of petfood product, including complete and balanced foods, treats, chews, supplements, and "specialty pet" (fish, birds, exotics) foods. Members of the National Animal Supplement Council (NASC) are primarily manufacturers of dietary supplement products for companion animals, particularly horses, dogs and cats.

The regulators

The US Food and Drug Administration (FDA) has authority over all animal feeds in interstate commerce (which is virtually everything on the market) under the Federal Food, Drug, and Cosmetic Act of 1938. This includes petfoods, even those containing meat and poultry ingredients. This is in contrast with oversight of human foods, where meat and poultry products are regulated by the US Department of Agriculture (USDA). Within FDA, issues involving petfoods are dealt with by the Center for Veterinary Medicine (CVM). Federal Regulations pertaining to animal feeds include general requirements for labeling, 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. Products found to be misbranded or adulterated may be subject to enforcement action, which may include physical seizure of the violative petfood, injunctions against the company, or in the most egregious cases, criminal charges.

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. The federal agency offers scientific, nutritional, and technical expertise to the states, and the states initiate the enforcement action on that basis. 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.