About The Association Of American Feed Control Officials – AAFCO
The AAFCO is an organization and not a governmental agency such as the FDA. Members include employees of state, federal and provincial agencies as well as employees from pet food companies.
When Is Dog Food Labeled As Complete And Balanced Dog Food?
On top of the FDA rules, the Association of American Feed Control Officials requires compliance to more specific rules regarding product names, ingredient names, guaranteed analysis, nutritional adequacy statements, and flavor designations.
In order for a dog food product to obtain the AAFCO Nutritional Adequacy Statement, it must meet the requirements of proof of safety and nutritional quality. Usage of the term “complete and balanced” on a dog food package means the food meets a defined Dog Food Nutrient Profile.
A dog food product is considered complete & balanced when it meets the Nutrient Profile (based on laboratory testing) OR when it has successfully passed a feeding trial (using live testing dogs).
The Canine Nutrition Expert (CNE) Subcommittee has set these levels after considering the scientific information about good dog nutrition at that date.
Two Nutrient Profiles Are Defined
Two Nutrient Profiles Have Been Designed For Dogs
- Adult maintenance.
- Growth, lactation, and reproduction.
The required nutrient levels are expressed on a “dry matter” basis so excluding water content in the food. The dog food label will list the ingredients including their water content (on an “as fed” basis really, but it makes comparisons more difficult).
Restate the guaranteed analysis on the label to “dry matter” basis before you compare dog food labels.
Dog food nutrients must be above the defined minimum (to avoid deficiencies) and below-defined maximum levels (to avoid toxicity effects and also out of a concern of over-nutrition rather than under-nutrition with today’s dog food products). This provides the dog food manufacturers with practical guidelines.
The dog food label should clearly state to which of these two profiles the nutritional adequacy statement refers. As a third option, the product may also declare itself as “fit for all life stages” when it is compliant with the more stringent Nutrient Profile for growth and reproduction.
The AAFCO has not set Nutrient Profiles for senior dogs, specific breeds, working dogs or large breed dogs. This is because there is not enough scientific data at the moment to support different profiles. Dog foods labeled as “senior dog food” as such only needs to meet the requirements for adult maintenance.
Dog food products that do not meet either Nutrient Profile can be legal products! They just aren’t allowed to display terms as “complete”, “balanced” or “100% nutritious” on the bag. These products can be intended to be used as treats or snacks or should state these are intended for the intermittent or supplemental feeding of dogs.
Feeding Trial Protocol
The AAFCO sets the protocols for conducting feeding trials and publishes these in their Official Publication (OP).
Only 8 dogs (healthy adults) need to participate. Six of them need to complete the trial period, which is 26 weeks (so half a year). During this period, the dogs get only water and the food that’s being tested. At the end, the animals are inspected by a veterinarian and multiple medical tests are run to determine their health status.
The Testing Food Passes This Mini Trial If…
- Animals appear healthy and show no clinical signs of nutritional deficiencies or excess.
- Six out of 8 dogs complete the full 26 weeks evaluation period.
- No dog looses more than 15% of its starting body weight.
- Blood testing results fall within the specified range for hemoglobin, packed cell volume, serum alkaline phosphatase, and serum albumin.
In my opinion, this feeding trial seems to be a bit limited in its scope and size; that’s why I called it a ‘mini-trial’. Only 6 dogs need to complete the test and these can be of any breed, sex, and age (as long as these are healthy adults). Also, a mild deficiency or excess may not be detected within 26 weeks but can show when a dog is typically fed for years on the same food product.
With such a testing protocol… what are the chances a low-quality dog food passes the feeding test but doesn’t comply with the Nutrient Profiles? On the other hand, the Nutrient Profiles for example only look at total protein content without taking the source into account. As dogs can more easily digest and utilize protein coming from meat sources than vegetable sources, bioavailability becomes an important aspect that is better addressed in a feeding trial.
Whitelisting Of Dog Food Ingredients
Any dog food ingredient that is NOT on the list is forbidden, so there is no blacklist available.
The only substances that are allowed in dog food are already sanctioned substances, GRAS substances, substances that pass the Food Additive Petition, substances that pass the New Animal Drug rules and FDA reviewed substances. Any company that includes an unapproved substance (any substance that is not on the list) is adulterating their products.
Not all approved ingredients are listed on the Official Publication (OP), so there appears to be not one single list. Some allowed substances are listed in the Federal CFR.
Partnership With The FDA
An FDA representative serves on the AAFCO Board of Directors and the FDA/CVM staff also collaborates with the AAFCO on standing committees (such as the Pet Food Committee) and as investigators.
As the FDA is limited in its budget and resources and primarily focuses on the safety of human foods, the collaboration between CMV and AAFCO is vital to the regulation of pet food safety.
The AAFCO has more detailed regulations for pet food labeling than the Federal regulations. Most States adopt the AAFCO guidelines.
It is the intention of the AAFCO to reach uniformity across states to an ultimate national standard that can become enforceable by the states. Also, it is their perspective that process controls could proactively complement existing regulations as a preventative measure.
The AAFCO promotes prevention and process control. As such the document “Guidance for best management practices for Manufacturing, Packaging, and Distribution of animal feeds and feed ingredients” was published along with a checklist. At this moment its just guidance – not law and pet food manufacturers are not obliged to use it.
Some Definitions Used By The AAFCO
Salvage Pet Food
Salvage pet food is a product resulting from pet food manufacturing. This product may consist of, but is not limited to, start-up and over-run product, unfinished pet food, pet food fines and other product not suitable for packaging for retail sale.
Distressed Pet Food
Distressed pet food is a product resulting from pet food distribution, but which is no longer available for retail sale. This product may be pet food in, but not limited to, dented cans, torn bags, product past its sell-by date, or returned product that is suitable for use in feed. It may consist of a single formula, still in the original packaging, or a variety of formulas commingled into one bulk container and containing none of the original packaging or labeling.
And in both cases, the following addendum applies:
If it contains, or may contain, any material identified by 21 CFR 589.2000 as prohibited from use in the feed of ruminant animals, or if it is no longer accompanied by a detailed label listing all of the ingredients in the distressed product, the label must contain the precautionary statement “Do not feed to cattle or other ruminants”. It shall be free of foreign materials harmful to animals, suitable for the purpose for which it is being marketed, and properly labeled for its intended use.
Dog Food Recipes
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What else is on the menu?
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