Labeling pet foods
The label of a pet food is a very important piece of communication. It is very highly regulated both on a federal and a state level. The federal regulations are published in the Code of Federal Regulations (CFR), Title 21CFR.
The AAFCO OP contains model regulations for pet foods and a checklist for labels. The AAFCO OP also contains the Model Bills for pet food and animal feed; it also contains labeling information and a checklist for labels. Click HERE to see the general pet food and treat label requirements. AAFCO also sells the Pet Food and Specialty Pet Food Labeling Guide and occasionally provides a workshop on pet food labeling.
The regulations cover not only the label attached to the pet food, but also labeling which is defined as communication about the product in various types of media. Labeling and its compliance with regulations is subjective and it depends highly on the context. What might be acceptable is small print might not be acceptable in giant print.
AAFCO members discuss and approve model legislation that is recommended to the states for adoption as individual state laws and regulations. AAFCO does not regulate, approve, certify or endorse animal feed or pet food in any way, and AAFCO does not review an individual company’s label or labeling. It is the states, and their designated regulatory officials, which have the legal authority to review a feed or pet food label and approve or disapprove products for distribution in their state according to the requirements of their state feed law and regulations.
Overview of Label Requirements for Pet Foods, including Pet Treats
The primary regulations for pet food focus on product labeling and the ingredients which may be used. There are certain items which must be included on product labels, and specific requirements for each of these items. There are also rules for non-required, or descriptive information included on labels. In particular, this information must not be false or misleading in any way.
A pet food label has eight required items. If the label is placed only on the front of the package, all items must appear there. If a front and back label are used, there are three items which must be included on the PDP (Principal Display Panel) on the front of the package. These are: brand and product name, species for which the food is intended, and the quantity statement. The other five items may be included on the front label or elsewhere on the package, such as on a back or side label (called the “information panel”).
The eight required label items are listed below. There is an excellent explanation of each label item on the Pet Food website of the Food and Drug Administration Center for Veterinary Medicine (FDA-CVM) website.
Required Label Items –
(Click for a printable version of the “Required Label Items list) — (Check back on this page for an example of a label – the verbiage for the label is still being developed)
- Brand and Product Name:
These rules address the use of ingredient names in the product name. How ingredients may be included in the product name depends on the percentage of that ingredient in the product, and the use of certain descriptors. For example, there are different rules for “Beef Dog Food”, “Beef Recipe Dog Food”, “Dog Food with Beef” and “Beef Flavor Dog Food”.
- Name of Species for which the pet food is intended:
This must be conspicuously designated in words on the principal display panel, but may be included in the product name, such as “Beef Dog Food” or “Salmon Treats for Cats“.
- Quantity Statement:
This is the net weight or net volume, and it must be expressed in the correct units and placed on the lower third of the principal display panel. For net weight or volume, both avoirdupois (“pound/ounce”) and metric units must be used.
- Guaranteed Analysis:
This lists the percentage of each of the nutrients in the food. The minimum percent of crude protein and crude fat, and the maximum percent of crude fiber and moisture are always required. Note that “crude” refers to the analysis method, rather than the quality of the nutrient. Guarantees for other nutrients may be required to support claims made in labeling (such as “High in calcium and vitamin A”), and you may include voluntary guarantees for other nutrients. The guarantees must be given in a particular order, in specified units and as a minimum or maximum, depending on the nutrient. Refer to the Laboratory section for a list of laboratories that take in service samples. Be sure to contact the laboratory you choose before sending in samples.
- Ingredient Statement:
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. The ingredients used must be GRAS (“Generally Recognized As Safe), approved food additives, or otherwise sanctioned for use in animal feeds (for example, defined by AAFCO). Ingredients must be declared by the correct AAFCO-defined name, where one exists, or the “common or usual” name.
- Nutritional Adequacy Statement:
This is a statement that indicates the food is complete and balanced for a particular life stage, such as growth, reproduction, adult maintenance or a combination of these, or intended for intermittent or supplemental feeding only. Products conspicuously identified on the principal display panel as a snack, treat, or supplement are exempt.
- Feeding Directions:
All pet foods labeled as complete and balanced for any or all life stages must include feeding directions that, at a minimum, state “Feed (amount of product) per (weight) of dog/cat”. Feeding frequency must also be stated. Feeding directions are optional for treats, as long as they are not complete and balanced and labeled as snacks or treats.
- Name and address of manufacturer or distributor:
This names you or your company as guarantor of the product, and gives you or your company’s location. The street address may be omitted the named entity is listed in the local telephone directory, but the city, state and zip code must be shown. If someone else makes the product for you, you must show that relationship by using the words “manufactured for:” or “distributed by:” in front of your address.
In addition to the required items, other aspects of the label may be conditionally required. For example, a “lite” or “low calorie” claim requires a calorie content statement following specified methods and format. The product must not exceed maximum calorie limits depending on the moisture content of the food and intended species.
How do I calculate the Guaranteed Analysis in my pet treats?
Unless the product is formulated through use of sophisticated computer software with a complete and accurate database on nutrient content of all ingredients used in the product, the best means of determining appropriate guarantees is by laboratory analysis.
How do I calculate the Caloric Content for my pet treats or food?
Where a label calorie content statement is required or simply desirable, it may be calculated from the same proximate analysis data used for setting guarantees. Unlike guarantees, it is NOT declared as a minimum or a maximum, but as an average based on multiple proximate analysis data.
Can I put "vet recommended" on a label? If so, what are the requirements? Is that determined by each individual state, or is this something there is a consensus on?
The AAFCO Pet Food Committee (PFC) has discussed this issue. AAFCO Model Regulations for Pet Food and Specialty Pet Food Regulations, Regulation PF2(f) states, “A personal or commercial endorsement is permitted on a pet food or specialty pet food label provided the endorsement is not false or misleading.”
First of all, this regulation allows you to include endorsements on product labels. What this regulation does not tell you is how do you support such an endorsement as “veterinarian recommended” so that the claim is not false or misleading. The AAFCO Pet Food Committee has determined that a statistically sound survey of veterinarians would be adequate to support such a claim as “veterinarian recommended.” This means surveying one or two veterinarians is not adequate. So how many veterinarians should you survey? I can’t tell you that, since there is so much variation in determining “statistically sound”.
I would think that the number of veterinarians should be relevant to the product type, what similar product is your product being compared to (i.e., this product is recommended over what other product?), the number of customers you would normally expect to buy your product, and then the number of veterinarians who would normally handle that number of customers. I’ve seen companies’ data that included survey results from about 300 or so veterinarians. The survey questions were not lengthy, and I believe the products were complete and balanced products. There is no set format for a survey, but whatever you use, it should be able to support your claim. State control officials may ask for data to substantiate any claims that are made on product labels.
It should be pointed out that while “veterinarian recommended” requires a survey of a statistically sound number of veterinarians who recommend your product, it only takes one veterinarian to support the claim “veterinarian formulated”, or “veterinarian developed”, assuming that fact can be sufficiently documented.
Can I put "Veterinarian Approved" on my labels?
No, veterinarians do not approve labels or products, only state regulatory agencies can do that. However, you can state “veterinarian recommended”, “veterinarian formulated”, or “veterinarian developed” if you can meet the criteria listed in the previous question’s answer.
Where can you find the definitions/parameters for the various descriptions of the nutritional levels of dog food? For instance, what exactly does it mean when the label states that the food meets the AAFCO standards for "maintenance" and "growth and maintenance" and "all life stages"?
All pet foods, including snacks, treats, cookies, chews, rawhides, supplements, and complete & balanced products are regulated by the states under the state’s feed law and pet food regulations, if the state has adopted such legislation. Under most state pet food regulations, there are four categories of pet foods: snacks & treats; intermittent or supplemental pet foods; complete & balanced pet foods and special purpose products.
What are AAFCO's nutritional standards for complete and balanced pet foods?
A pet food company has several options approved by AAFCO. These options are substantiation of nutrient content and feeding trials.
I am trying to find a pet food nutrient calculator, so I can find the total crude protein percentage in certain pet foods.
AAFCO does not have a “pet food nutrient calculator”. That means you must calculate the required protein yourself.
Are claims such as "low fat" and "high protein" allowed on pet food labels?
The AAFCO model pet food regulations contain requirements for claims regarding calorie and fat content. Please check the section for Model Pet food Regulation PF10, Descriptive Terms.
What is DSHEA?
The FDA regulates dietary supplements under a different set of regulations than those covering “conventional” foods and drug products (prescription and over-the-counter). Under the Dietary Supplement Health and Education Act of 1994 (DSHEA), the dietary supplement manufacturer is responsible for ensuring that a dietary supplement manufacturer is responsible for ensuring that a dietary supplement is safe before it is marketed. DSHEA does not apply to animal feeds.
Can you call an animal feed supplement a dietary supplement?
No, as DSHEA does not apply to animal foods.
What are considered to be drug claims on an animal feed label?
If there are claims on a label that show the intended use of the product as other than providing taste, aroma, or nutritive value of the food, these are considered to be drug claims and unacceptable on an animal feed label. Examples include “reduces inflammation”, “cures cancer”, “improves joint function”.
Can I put "Made in the USA" on my pet food label?
The FTC governs this aspect of labeling. The rule states that: “all or virtually all means” that all significant parts and processing that go into the product must be of US origin. That is, the product should contain no – or neglible – foreign content. So just putting together ingredients inside the US is not enough. Additionally, just getting ingredients from a broker within the US is not enough. If ingredients are imported, then it is very difficult to justify the use of the phrase “Made in the USA.” Please go HERE to see an FTC Fact Sheet on “Made in the USA”.
I use ingredients from the grocery store; I want to tell customers that my product is human grade. Can I do that on the label?
Claims on animal foods should not be false or misleading. A claim that something is “human-grade” or “human-quality” implies that the article being referred to is “edible” for people in legally defined terms. The terms “human grade” or “human quality” have no legal definition. When one or more human edible ingredients are mixed with one or more non-human edible ingredients, the edible ingredients become non-human edible. To claim that a product composed of USDA inspected and passed chicken, plus poultry meal, which is not human edible, plus other ingredients is made with human-grade chicken is misleading without additional qualification and disclaimers in the claim because the chicken is no longer edible. Thus, for all practical purposes, the term “human grade” represents the product to be human edible. For a product to be human edible, all ingredients in the product must be human edible and the product must be manufactured, packed and held in accordance with federal regulations in 21 CFR 110, Current Good Manufacturing Practice in Manufacturing, Packing, or Holding Human Food. If these conditions exist, then human-grade claims may be made. If these conditions do not exist, then making an unqualified claim about ingredients being human grade misbrands the product.