Confused By Pet Food Labels? Why Not...It's Fuzzy Math
Or How 95% + 5% = 70%
There are three entities that can influence pet food labeling, which on the one hand can reassure pet owners that labeling is being thoroughly scrutinized, while on the other hand can lead to confusion.
The honcho in this triumvirate is the U.S. Food and Drug Administration (FDA), which establishes standards that apply to all animal feeds. Specifically these standards include proper identification of product, net quantity statement, manufacturer's name and address, and proper listing of ingredients.
Individual states comprise the next level of regulation as they are free to enforce their own, additional labeling standards. This could lead to some confusion if neighboring states set different standards or regulations.
Theoretically, if you lived in a border community, you could buy some pet food at a local store that would contain different label information than the exact same product bought in a store in your neighboring community across the border.
The third regulator is the Association of American Feed Control Officials (AAFCO), which covers product name, the guaranteed analysis, the nutritional adequacy statement, feeding directions, and calorie statements.
If Not a Government Agency, Then What Is AAFCO?
It could mistakenly be perceived as a paper tiger since the Association has no regulatory authority of its own. But being a voluntary membership group of regulators from each state, plus Puerto Rico, Costa Rica, Canada, the FDA and the U.S. Dept of Agriculture (USDA), it has very impressive credentials. And it has clout, too.
How seriously AAFCO is taken is evidenced by the fact that manufacturers who comply are in voluntary compliance with their standards, and it would be a challenge to find a manufacturer that declines to do so.
There is also a Memorandum of Understanding between FDA and AAFCO that, through September 1, 2015, allows FDA to formally recognize the Association's list of feed ingredients.
It also defines the role FDA can play in deciding on the suitability of feed ingredients offered for addition to the list.
Most states that establish their own regulations follow AAFCO standards.
So What About the Fuzzy Math?
They call it the 95% rule. In the early 2000s you may have noticed the introduction of canned dog food prominently labeled 95% Lamb or 95% Chicken, etc.
Several manufacturers put out such products in response to pet owners’ demands for higher quality products.
The 95% refers to the named meat. If it says 95% Lamb, then the total weight has to be 95% lamb, exclusive of “condiments” and any vitamin/mineral package.
Sounds pretty good so far, right? But wait! There’s more!
Manufacturers are allowed to weigh the meat before the water necessary for processing is added.
When you factor in the water, the regulation says that the actual volume of meat must be at least 70%.
So, that 12 ounce can of dog food that boasts 95% Whatever Meat, could be, in reality, only 70% meat. Still a pretty good product compared to the other cans on the shelf, but certainly misleading.
If there are two named meat sources, say 95% Turkey & Giblets, the first named must also be the most by volume.
In this example, if the giblets outweighed the turkey, the manufacturer would be in violation.
Then There's the "25%" or "dinner" Rule
Under this rule, if the named ingredients total at least 25% of the product, minus water sufficient for processing, but less than 95%, the name must include a “qualifying descriptive term.”
Commonly used qualifying descriptive terms might be words such as: dinner, platter, entrée, and formula, for example.
So, if you see a can of Beef & Salmon Dinner, its meat content is somewhere between 25% and 94%. Makes it sort of hard to compare brands, doesn’t it?
And What Are Regs Without the "3%" or "with" Rule
You’ll often see a pet food label sporting a colorful burst exclaiming “With Lamb” or some other ingredient. While the design is to impress you, and maybe it does, what it really means is that the named ingredient comprises less than 3% of the weight. It was unclear to me where water sufficient for processing comes into play.
And Last, but Not Least, the "flavor" Rule
I’ll let FDA say it because they say it best: Under the "flavor" rule, a specific percentage is not required, but a product must contain an amount sufficient to be able to be detected.
There are specific test methods, using animals trained to prefer specific flavors, which can be used to confirm this claim.
In the example of "Beef Flavor Dog Food," the word "flavor" must appear on the label in the same size, style and color as the word "beef."
The corresponding ingredient may be beef, but more often it is another substance that will give the characterizing flavor, such as beef meal or beef by-products.
With respect to flavors, pet foods often contain "digests," which are materials treated with heat, enzymes and/or acids to form concentrated natural flavors.
Only a small amount of a "chicken digest" is needed to produce a "Chicken Flavored Cat Food," even though no actual chicken is added to the food.
Formore detail, follow this link:
The World of Kibble Can Be Similarly Confusing
Dry dog and cat foods can become complicated when choosing what you think is best. For example, some dog foods exclaim “Real Chicken Is The #1 Ingredient.” Chicken, as defined by AAFCO, is the meat with the moisture still in it. Chicken is about 70% water.
I wonder what they mean by "real" chicken, anyway. If it says "chicken" that ingredient has an AAFCO definition. There's no such thing as fake chicken in pet foods. Pet owners don't realize that what pet food manufacturers tout as real chicken is actually about 70% water. Chicken meal, which doesn't sound like real chicken (but is) contains less than 10% water and can contain up to three times the protein as " real chicken."
Think of a one-pound boneless, skinless chicken breast. That’s basically a pound of slop. If you squeezed most of the water out of it, you’d end up with about a third of a pound of meat.
Because chicken is so watered down, manufacturers have to add another protein source to get the protein level up to the value stated in the guaranteed analysis.
So, on a bag of dog food that says chicken is the first ingredient, look a few ingredients down the panel and you’ll see chicken by-product meal or poultry by-product meal.
Some folks are under the impression that meal is an inferior ingredient. The fact is, chicken meal is that same meat, but with the moisture extracted; down to about 8%. Meat meals have up to 300% more protein than the raw meat of the same named species.
If your dog food has chicken meal as the first ingredient, you won’t see the by-product meals because the first ingredient is a stand alone protein source and is sufficiently rich in protein to meet the claim on the guaranteed analysis.
There’s nothing wrong with chicken and chicken by-product meal, except that it’s akin to buying chuck, but paying sirloin prices.
By-products, by the way, isn’t the beaks, feet and feathers as some would have you believe. It's mostly organ meat, albeit the organs we wouldn't eat, such as reproductive organs and digestive organs, for example. While they sound most unappealing, they are nutritious and would be consumed by the dog or cat in the wild.
So, there’s a glimpse into our triple-barreled regulatory regimen. It’s probably the best there is; and pet foods have never been under such regulatory scrutiny as they are now.
But from what I've read, and from talking with pet owners, that doesn’t seem to bolster public confidence in the safety of pet food and treats.