Ingredient Statement Overview
Ingredients must be listed in order of predominance by weight, on an “as formulated” basis. The ingredient that makes up the highest percentage of the total weight as it goes into the product is listed first. Each ingredient must be listed by its appropriate name. There is no allowance to group ingredients smaller than some percentage (like 1% or 2%). There is no allowance in pet foods to use a collective term for replacing individual ingredient names with a group term, like combining wheat, corn and oats into one ingredient name “grain products”.
The ingredients used must be AAFCO officially defined animal feed ingredients, or be common or usual names of feed ingredients, be approved food additives in 21 CFR 573, or be considered GRAS (Generally Recognized as Safe) animal feed additives. Just because an ingredient is used in human food does not mean that it is acceptable to use in animal feed or pet foods. It is important that if an AAFCO defined name exists, then that is the name that must be used in the ingredient statement.
Some AAFCO defined ingredients and some ingredients listed in the Code of Federal Regulations have restrictions for which animals can consume the ingredient or restrictions on how much of the ingredient can be used. You need to check to be sure that the ingredients that you use are approved for use in animal feeds. Many regulators will immediately reject product registration requests if they find unapproved ingredients in the ingredient list.
Additionally, there is no allowance for dietary supplements for animals. DSHEA does not apply to animals. For animals there are only two categories: food or drug. Be advised that some ingredients used in dietary supplements for humans cannot be used as pet food ingredients.
Federal and state officials can help you to determine if an ingredient is an approved ingredient.
So can’t I use "JUST ANY" ingredient in my product?
The short answer is NO. The ingredients used in pet food must be appropriate for the pet. Some ingredients have been defined via the AAFCO Ingredient Definition Process. Any ingredient with an AAFCO defined name must be listed in the ingredient statement by that name. Some ingredients are common or usual in the pet’s diet. Some ingredients are feed additives that are “Generally Recognized As Safe” (GRAS) by the FDA. All ingredients used in any pet food must be acceptable either via the AAFCO ingredients definition process, via formal FDA-CVM review or via Self-Affirmed GRAS. All of these methods require extensive amount of information including a substantial portion that must be in the public domain. Not just any ingredient can be used, especially ‘new’ ingredients that might be used a dietary supplements for humans. Such ingredients are not always safe for animals.
The legalese says the labels of foods must have the ingredients listed in descending order of predominance by weight. This means that the weight and not the volume of each ingredient must be determined. Then the ingredient list is assembled by listing each ingredient by its proper name starting from the most and proceeding down to the least. All ingredients must be listed.
“I mix up these ingredients to make a food and feed them to my pet; I must be making them fine.”
Any pet food sold must be safe and appropriate for the pet. It is a big responsibility to make food for someone else’s animal. AAFCO has developed regulations called Model Good Manufacturing Practices for Feed and Feed Ingredients. These provide guidance about the way to make animal feed including pet food.
Do I need a professional or inspected kitchen to make pet food or pet treats?
No, however, the Federal Drug and Cosmetic Act requires that pet foods, like human foods, be pure and wholesome, contain no harmful or deleterious substances and be truthfully labeled. The FDA and individual states always retain the right to inspect production facilities, particularly under the 2011 Food Safety Modernization Act (FSMA). Go HERE for more information on canned food processing requirements.