VALUE OF BYPRODUCTS
PET PRODUCTS
Understanding Pet Food and Pet Treats
Note: The following information is adapted from the Flower Hill Institute’s Resource Guide: Pet Products: A Hidden Opportunity for Smaller Meat & Poultry Processors.
Pet food and treats are classified as animal feed. Animal feed regulations largely fall under the jurisdiction of state departments of agriculture, along with some oversight from the U.S. Food and Drug Administration. Without coordination, this could lead to more than 50 differing—and even contradictory—sets of regulations.
Slightly over a century ago, state feed officials realized that it made little sense to have a patchwork of different regulations across the country, so they organized a nonprofit organization called the Association of American Feed Control Officials, or AAFCO. Today, AAFCO’s membership comprises feed officials from all 50 states, along with some of the staff of FDA’s Center for Veterinary Medicine.
These members meet twice a year to develop model regulations covering all types of animal feed, including food and treats for dogs and cats. The model regulations are then printed in the AAFCO Official Publication, which is issued annually. Because all states recognize AAFCO, that Official Publication serves as the de facto set of regulations for the pet products industry.
Pet Food Requirements Are Stringent
Under the AAFCO Model Regulations, any pet product labeled as “food” must be formulated to be “complete and balanced” for each species and specific life stages (puppy, adult, etc.) by providing all of the nutrients in the proper balance as determined by the National Academy of Science’s Nutritional Requirements for Dogs and Cats. The rationale for this requirement is that companion animals rely on or twice daily bowls of food for all of their nutritional needs.
The AAFCO model regulations specify the minimum and maximum levels of crude protein, crude fat minerals, and vitamins. Software designed to help create complete and balanced diets is generally costly. However, there are several consultants who will formulate a food product for a fee.
Pet Treats Are Easier to Produce
Pet treats are much easier to produce and, with some exceptions, have a much lower bar for regulatory compliance. That’s because treats are “intended for intermittent and supplemental feeding,” according to the AAFCO guidelines.
Treats can often be made in equipment like smokers and dehydrators that may already be used for human food products. Smoked bones, jerky, and dehydrated organs can be packaged and marketed as pet treats. However, AAFCO’s model regulations specify that treat labels meet all eight of the general requirements listed in Appendix A.
Exceptions to the “low bar” for regulatory compliance for pet treats arise when specific claims are included in the product label or marketing materials. For example, any dental or tartar control claims must be substantiated. Any claims implying specific health benefits may throw the product into the category of a health supplement, which will fall under a very stringent set of FDA regulations.
Labeling Requirements
Courtesy of the American Association of Feed Control Officials (AAFCO)
All pet products sold in the retail marketplace are required to meet the following labeling requirements:
1. Name (& purpose) of the brand/product:
[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 and the use of specific descriptors. For example, there are different rules for "Beef Dog Food", "Beef Recipe Dog Food", "Dog Food with Beef" and "Beef Flavor Dog Food". You should also specify the purpose of the product (nutrition, supplement, treat)]
2. Name of the animal species the product is for:
[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"]
3. Net Quantity Statement:
[The net quantity statement tells the consumer how much product is in the container. It 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.]
4. The Guaranteed Analysis (on an "as fed" basis):
[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 nutrient quality. 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.]
5. 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.]
6. Nutritional Adequacy Statement, if required:
[If you call your product a complete and balanced food, the claim must be substantiated. The Nutritional Adequacy Statement will also state for which life stage(s) the product is suitable, such as for maintenance or for growth. This statement 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.]
7. Feeding directions, if required:
[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.]
8. Manufacturer's Name and Address:
[This names you or your company as guarantor of the product and gives your or your company's location. The street address may be omitted if 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 establish that relationship 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.
Articles & Resources
WEBSITE
Association of American Feed Control Officials
AAFCO represents the de facto regulatory body for the pet industry. AAFCO’s annual Official Publication is considered the industry bible for manufacturing all pet products. AAFCO also offers a helpful pet product labeling guidebook.
WEBPAGE
How Do I Start a Pet Food Business? (FDA)
US Food & Drug Administration
The FDA is the primary federal agency overseeing pet product regulations. This document provides a helpful overview of the legal requirements for pet products.
WEBSITE
Pet Food Institute
The Pet Food Institute is the primary advocacy organization for the pet food industry. They are a good source of information on new pet product developments.
SEARCH TOOL
PIDA Find a Distributor
Pet Industry Distributors Association
If you grow your business beyond your ability to distribute to outlets, you may want to engage a pet food distributor to service your customers. This site contains a directory of many of those distributors.
GUIDE
AAFCO Pet Food Labeling Guide
Association of American Feed Control Officials
This is an extremely easy-to-read and comprehensive guide to pet food labeling, complete with examples of properly and improperly labeled packaging. An updated Pet Food Labeling Guide will be available for purchase in early 2024.
WEBSITE
Pet Sustainability Coalition
Pet Sustainability Coalition is a nonprofit organization representing pet product brands dedicated to producing and marketing responsibly sourced and processed products.
Guide
Nutritional Value of Beef (and Some Pork) Offal
This document, prepared by Dr. Ty Lawrence of West Texas A&M University, lists the nutritional value of most beef, and some pork, offal.