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 label
The percentages of named ingredients in the total product are dictated by four
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.
Dr. Becker's Real Food for Healthy Dogs and Cats: Simple Homemade Food
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
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
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
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 or treat.
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
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.
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