Pet food labels: Cracking the code (Proceedings)
Petfood labels are regulated at both the federal and state levels. The regulations promulgated by the US Food & Drug Administration (FDA) cover basic aspects of animal feed labeling, including requirements for a statement of identity (e.g., "dog food"), an ingredient declaration, a net content declaration, and the manufacturer's or distributor's name and address. At this time, they do not address issues such as nutrient content or nutritional adequacy. However, states that follow the Model Regulations for Pet Food and Specialty Pet Food as developed and published by the Association of American Feed Control Officials (AAFCO) enforce additional requirements with respect to nutritive value and other aspects.
Several rules within AAFCO regulations dictate the use of ingredient names that comprise a part of product names depending on the relative proportion of the named ingredient in the product. Under the "95%" rule, only products containing at least 95% of the named meat, poultry of fish ingredient(s) can be declared by the ingredient name(s) without qualification (e.g., "beef dog food," "tuna & shrimp for cats"). Water added for processing is excluded from the 95% percentage calculation, but in such a case the product must still contain at least 70% of the named ingredient(s). The ingredient names in the product name and ingredient list must match. For example, "chicken by-products" or "chicken meal" do not support a product name "chicken dog food." When more than one ingredient is named, they must be declared in the product name in the same order as which they appear in the ingredient list. Also, each must be at least 3% of the product formulation. This rule applies primarily to a small number of canned foods and some dried meat treats.The "25%" or "dinner" rule applies to a much broader spectrum of petfoods. In this case, the named ingredient(s), which could be either from plant or animal origin, must comprise at least 25% of the total formulation, exclusive of water for processing (at least 10% inclusive of added water). However, such product names must include a qualifying term to advise the consumer that the product may contain other major ingredients (e.g., "beef dinner for dogs," "rice and chicken meal formula cat food"). The qualifying term must be the same size, color and style as the ingredient name(s) in the product name. Other qualifying terms, such as "entrée," "recipe," and "platter" are also acceptable, but terms that connote form but not a mixture of ingredients (e.g., "slices," "chunks") are not sufficient. Again, the ingredient names in the product name and ingredient list must match, and if more than one ingredient is named, they must be declared in the same order as in the ingredient list and each must be at least 3% of the formulation.
Whether part of the product name or elsewhere, ingredient claims preceded by "with" or like terms must contain at least 3% of each of the named ingredient(s). There are exceptions in the case of nutrients and condiments, so that a "with calcium" claim does not require a minimum of 3% calcium. The qualifying term must be the same size, style, color and letter case as the named ingredient(s). For example, "with REAL BEEF" would not be acceptable. There are also maximum font size limitations on "with" claims to preclude overemphasis of minor ingredients.
There are no minimum percentage requirements for an ingredient when used as part of a "flavor" claim. Also, the named flavor does not necessarily have to match the name of the ingredient in the ingredient list, as long as it can reasonably be expected to impart that flavor. For example, a "fish flavor cat food" may contain fish, or it may contain fish meal, fish by-products, fish digest or other suitable flavor source. The term "flavor" must be the same size and equal degree of conspicuousness as the named flavor. This is actually more stringent than in human food labeling, which only requires the term "flavor" to be half the height of the named flavor.