The Ins and Outs of Pet Food Labels

(And How Best to Improve Them)
By Susan Thixton, July 2018

The pet-food world was rocked in 2007 by a recall that was unprecedented in both its scope and its consequences. A true wake-up moment, it dramatically revealed how common it was for manufacturers to put profit ahead of safety. Susan Thixton, who founded TruthAboutPetFood.com that year, was among those galvanized into action. Today, her site—which is 100 percent consumer-supported—is one of the pet food world’s best-known and most reliable advocacy resources. So, when we decided it was time for an update on the current state of pet food labeling, she was our first-choice source. Here’s her take on the topic.


As consumers and pet owners, we base our food-buying decisions on label information, but those labels can be both confusing and deceiving.

After the deadly 2007 pet food recall, Congress required the Food and Drug Administration (FDA) to provide “updated standards for the labeling of pet food that include nutritional and ingredient information.” Congress mandated that this work be completed by September 2009, two years after the Food and Drug Administration Amendments Act was signed into law.

The lawmakers’ goal was to provide us with more information, which would help us make better informed buying decisions. Today, eight years and counting past this legally defined deadline, pet food labels have still not been updated. The FDA has not enforced this requirement, and not a single member of Congress has addressed the failure. So, we’re still on our own when it comes to figuring out what we’re really feeding our pets.

The current regulations require that the following be included on a pet food label:

  • Brand name
  • Product name
  • Species (dog or cat)
  • Quantity statement (weight of the pet food in the container)
  • Feeding guide (directions on how much to feed, based upon size of pet)
  • Guaranteed analysis
  • Calorie Statement
  • List of ingredients
  • Life stage (puppy, adult, senior)
  • Nutritional adequacy statement (complete and balanced, as determined by AAFCO nutrient profiles or feeding trial)
  • Manufacturer or distributor name and address

Let’s look at these in more detail.

PRODUCT NAME

This provides clues to information required by regulation.

One ingredient in the name (i.e., Chicken Adult Dog Food): A minimum of 70 percent of the named ingredient (with the water).

One ingredient and a descriptor, such as Formula, Recipe, Entrée, Dinner or Platter (i.e., Chicken Adult Formula Dog Food): A minimum of 10 percent of the named ingredient (with the water.)

Two or more ingredients (i.e., Chicken & Rice Adult Dog Food): A minimum of 3 percent of each named ingredient.

The word “with” (i.e., Adult Dog Food with Chicken): 3 percent of the named ingredient.

The word “flavor” (i.e., Chicken Flavor Adult Dog Food): 0 percent of the named ingredient; because this pet food is only flavored with the named ingredient, it is not required by regulation to include it.

FEEDING GUIDE

Existing pet food regulations do not require the feeding directions on labels to reflect scientifically based canine or feline caloric needs. Always pay attention to your pets’ weight when changing foods. If they appear to be gaining weight (or losing it when it’s not intended) when you’re feeding the recommended amount, adjust accordingly.

GUARANTEED ANALYSIS

Currently, pet food regulations require only the following information:

Protein, fat and fiber numbers are stated as “crude,” which refers to the method of testing; crude is a simple, or basic, method.

The Association of American Feed Control Officials (AAFCO) is currently working on adding carbohydrate content to the label, but it is unknown how long it will take for these changes to be implemented.

Guaranteed Analysis
Crude Protein   xx% minimum
Crude Fat   xx% minimum
Crude Fiber   xx% maximum
Moisture   xx% maximum

One more thing to understand regarding the guaranteed analysis: a fair amount of math is needed to compare the guaranteed analysis of a dry pet food to that of a wet pet food. In the guaranteed analysis, protein, fat and fiber are given “as fed” to your pet. To make a comparison of these elements between a dry and a wet food, the moisture content needs to be considered.

The FDA provides a method to compare guaranteed analysis information on different styles of pet food (see end of article for details).

CALORIE STATEMENT

This statement must be expressed on a “kilocalories per kilogram” basis. A “kilogram” equals 2.2 pounds. Kcals must also appear in a more familiar unit like “per cup,” “per treat”. Similar to guaranteed analysis this is expressed as a “as fed” basis, so a correction for moisture content must be made. To make a rough comparison between canned and dry food, multiple the Kcal for the canned food by four.

INGREDIENTS

This is a concern for everyone who purchases pet food. Ingredients used in these products have very specific legal definitions that are often quite different from what we understand them to be for our own human-grade food. Thus, while the label provides us with a list of ingredients, we are not provided with the definitions of those ingredients. We don’t know what they really mean.

For example, many pet food labels tout “Made with Real Chicken” or “Chicken Is the 1st Ingredient.” This actually means made with real pet food quality chicken or pet food quality chicken is the first ingredient, not necessarily the same type of chicken you would eat yourself. Regulations define “chicken” to include USDA-inspected and -passed chicken meat (as required in human food), or it could include USDA-inspected and -condemned chicken (chicken deemed inedible and rejected for human food). The label does not tell us which type of chicken is in the food; either is acceptable.

Consumers should be aware that the FDA openly allows pet food to include ingredients sourced from diseased animals and animals that have died otherwise than by slaughter, which is absolutely prohibited in human food. Just one example from the FDA website: “Pet food consisting of material from diseased animals or animals which have died otherwise than by slaughter, which is in violation of 402(a)(5), will not ordinarily be actionable, if it is not otherwise in violation of the law. It will be considered fit for animal consumption.”

Ingredient definitions are written with this FDA attitude in mind; not one pet food ingredient definition is required to be the same as those applied to human food. And to make matters worse, all of those ingredient definitions are corporately owned by AAFCO; unlike definitions for human food, they are not public information. To read ingredient definitions and understand exactly what we are feeding our pets, we must pay AAFCO $100 a year.

Even worse, manufacturers may change the ingredients without immediately changing the label. No regulation requires ingredient listings on labels to be current; the FDA only suggests they are updated “as soon as practical.”

Besides the required information, pet food manufacturers will often include beautiful images of meat and fresh vegetables and fruit on their labels to lure the consumer into believing these ingredients are found in the food. However, in almost all instances, these images are nothing more than misleading marketing. Although regulations prohibit misleading images— “vignette, graphic or pictorial representation of a product on a pet food label shall not misrepresent the contents of the package” —this prohibition is never enforced. It is best to ignore images on pet food labels.

The most meaningful words found on a pet food label are “human grade.” Regulatory authorities consider most pet foods to be “feed grade.” This is how condemned meats and other material end up in pet food: they are “feed,” not “food.” But when we see “human grade” on the label, we can be sure that every ingredient (including supplements) is edible by humans. Further, it provides assurance that the pet food was manufactured according to food-safety laws, which feedgrade pet foods are not required to do.

Be aware that many pet food manufacturers make a “human grade” claim on their websites, but that claim may or may not be true; regulatory authorities do not scrutinize these sites. So, while we can trust the claim on the label, we should be skeptical about it on a website.

WHAT INFORMATION SHOULD BE ON PET FOOD LABELS?

Quality of ingredients. Consumers absolutely deserve to know the quality of ingredients used in a pet food. As recent recalls have shown, some pet food manufacturers source highly inferior ingredients or do no quality assurance testing on the ingredients used in their products. Because regulatory authorities allow these highly inferior ingredients to be included in pet food, labels should include a declaration of quality.

Country of origin. The 2007 pet food recall, the deadliest in history, was caused by tainted ingredients that originated in China. Today, many consumers want to know the country of origin of each ingredient provided in the pet food.

Carbohydrate content. As mentioned, a requirement to add the carbohydrate content to the label is currently being discussed by regulatory authorities, but we don’t know how long this will take. Until this is required, we can take out our calculators and do the math. With the information provided on the label under Guaranteed Analysis, add the protein, fat, moisture and ash percentages (if ash content is not provided, add another 5 percent). Subtract the total from 100 percent and you’ll have the carbohydrate content.

While buying a pet food should be a simple task, it’s not. Understanding the rules governing pet food help, but many of us still have questions. Don’t hesitate to ask the manufacturer for answers. Remember, our pets’ lives depend on it.

Susan Thixton, founder of the Association for Truth in Pet Food, is one of a handful of consumer advocates fighting to hold the pet food industry accountable to existing food safety regulations.

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