A Cook College Pet Seminar, April 10, 1994
By David A. Dzanis, DVM, Ph.D., DACVN
Center for Veterinary Medicine
Net Quantity Statement
Manufacturer's Name and Address
Nutritional Adequacy Statement
Other Label Claims
As Americans become more health conscious with respect to food for their own consumption, they are reading food labels and choosing products more carefully. Many people are extending this scrutiny to food for their pets as well. New regulations for nutrition labeling of human foods are designed to help people make proper food choices. Pet food labels are regulated by different rules than are foods for human consumption, but reading and understanding a pet food label will enable consumers to make proper food choices for their pets, too.
Pet food labeling is regulated at two levels. The federal regulations, enforced by the Center for Veterinary Medicine of the U.S. Food and Drug Administration, establish standards applicable for all animal feeds: proper identification of product, net quantity statement, manufacturer's address, and proper listing of ingredients. Some states also enforce their own labeling regulations. Many of these follow the model pet food regulations established by the Association of American Feed Control Officials (AAFCO). These regulations are more specific in nature, covering aspects of labeling such as the product name, the guaranteed analysis, the nutritional adequacy statement, feeding directions, and calorie statements.
The product name is the first part of the label noticed by the consumer, and can be a key factor in the consumer's decision to buy the product. For that reason, manufacturers often use fanciful names or other techniques to emphasize a particular aspect. Many product names incorporate the name of an ingredient to highlight its presence in the product. Consumers are often confused, however, as to how much of a named ingredient is actually in the product. The percentages of named ingredients in the total product are dictated by four rules.
The "95%" rule applies to products consisting primarily of meat, poultry or fish, such as some of the canned products. They have simple names, such as "Dave's Beef for Dogs," In this example, at least 95` of the named ingredient must be beef, exclusive of water for processing. Counting the added water, it still must comprise 70% of the product. Since ingredient lists must be in the proper order of predominance by weight, "beef" should be the first ingredient listed, followed often by water, and then other components such as vitamins and minerals. If the name includes a combination of ingredients, such as "Dave's Chicken 'n Fish Cat Food," the two together must comprise 95\ of the total weight, and there must be more chicken than fish.
The ''25%" or "dinner" rule applies to many canned and dry products. If the named ingredient(s) comprise at least 25% of the product exclusive of water for processing, but less than 95%, the name must include a qualifying descriptive term, such as "Dave's Beef Dinner for Dogs." Many descriptors other than "dinner" are used, however. "Platter," "entree," "nuggets" and "formula" are just a few examples. Because, in this example, only one-quarter of the product must be beef, it would most likely be found third or fourth on the ingredient list. Since the primary ingredient is not the named ingredient, and may in fact be an undesired ingredient, the ingredient list should always be checked before purchase. For example, a cat owner telephoned me, complaining that her cat's "chicken dinner" smelled like fish. She avoided buying fish, since her cat did not like it, but she was more concerned that the food was spoiled. However, reading the ingredient list to me over the phone, we discovered together that the primary ingredient was indeed fish.
If more than one ingredient is included in a "dinner" name, they must total 25` and be listed in the same order as found on the ingredient list. Each named ingredient must be at least 3` of the total, too. Therefore, "Dave's Chicken n' Fish Dinner Cat Food" must have 25` chicken and fish, and at least 3% fish.
The "3%" or "with" rule is intended to apply to ingredients highlighted on the label but outside the product name. This is to allow manufacturers to point out the presence of minor ingredients that are not or cannot be added in sufficient quantity to merit a "dinner" claim. For example, a "Bacon Dinner," with 25% bacon, would not be feasible, nor would it most likely be palatable or nutritionally sound. However, both "Dave's Beef Dinner for Dogs" and "Dave's Chicken Dinner for Dogs" could include a side burst "with bacon" if at least 3% bacon is added. If the burst read "with bacon and cheese," it must contain at least 3% bacon and 3% cheese.
Some manufacturers have been using the "with" designation as part of the product name, which may give the impression that more of an ingredient is present than in reality. For example, one may not expect a "Dave's Dog Food with Beef" to contain as much as "Dave's Beef Dinner," but not as little as 3%. The AAFCO Pet Food Committee is considering new regulations to address this issue.
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, that can be used to confirm this claim. In the example of "Dave's 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. Pet foods often contain "digests," which are materials treated with heat, enzymes and acids to form concentrated natural flavors. Stocks or broths are also
occasionally added. Whey is often used to add a milk flavor. Often labels will bear a claim of "no artificial flavors." Actually, artificial flavors are rarely used in pet foods. The major exception to that would be artificial smoke or bacon flavors, which are added to some treats.
Net quantity statement:
The net quantity statement tells you what you're paying for. It is important to check the quantity statement when comparing products. Today, many canned products are sold in non-standardized sizes, so even though the products look the same, one may be a better buy. Also, dry products may differ greatly in density, especially some of the "lite" products. Thus, a bag that may typically hold 40 pounds of food may only hold 35 pounds of a food that is "puffed up."
New federal regulations are going into effect to require "dual declarations" on pet food labels. Thus, not only will the customary "pound" or "ounce" declaration be made, but a unit of metric measurement, such as "kilogram" or "gram" ("kg" or "g") will also appear on the label. Many pet food labels already bear both measurements.
Manufacturer's name and address:
The "manufactured by..." statement identifies the party responsible for the quality and safety of the product and its location. A consumer who has a question or complaint about a product should not hesitate to contact the manufacturer. Not all labels include a street address along with the city, state, and zip code, but by law, it should be listed in either a city directory or a telephone directory.- Many manufacturers also include a "800" telephone number on the label for consumer inquiries. If the label says "manufactured for..." or "distributed by...," the food was manufactured by a third party.
As mentioned above, ingredients are required to be listed in their proper order of predominance by weight. The weights of ingredients are determined as they are added in the formulation, with their inherent water content. This latter fact is important when evaluating relative quantity claims, especially when ingredients of different moisture contents are compared.
For example, one pet food may list "chicken" as its first ingredient, and "corn" as its second. The manufacturer doesn't hesitate to point out that its competitor lists "corn" first (chicken meal is second). However, chicken is very high in moisture (approximately 75% water). On the other hand, water and fat are removed from chicken meal, so it is only 10` moisture. If we compared both products on a dry matter basis, one could see that the second product had more chicken meal than the first product had chicken.
That is not to say that the second Product has more chicken, or in fact, any chicken at all. Chicken meal is not chicken per se, since all the fat and water have been removed by rendering. Ingredients must be listed by their "common or usual" name. Most ingredients on pet food labels have a corresponding common definition in the AAFCO Official Publication. For example, "meat" is defined as the "clean flesh of slaughtered mammals and is limited to...the striate muscle. .with or without the accompanying and overlying fat and the portions of the skin, sinew, nerve and blood vessels which normally accompany the flesh." On the other hand, "meat meal" is "the rendered product from mammal tissues, exclusive of any added blood, hair, horn, hide trimmings, manure, stomach and rumen contents." Meat meal may not be very pleasing to think about eating yourself, even though it's probably more nutritious. Regardless, the distinction must be made in the ingredient list.
Further down the ingredient list, the "common or usual" names become less common or usual to most consumers. The majority of ingredients with chemical-sounding names are, in fact, vitamins, minerals, or other nutrients. Other possible ingredients may include artificial colors, stabilizers, and preservatives. All must be either "Generally Recognized As Safe (GRAS)" or approved food additives for their intended uses.
If scientific data are presented that show a health risk to animals of an ingredient or additive, CVM can act to prohibit or modify its use in pet food. For example, propylene glycol is used as a humectant in semimoist pet foods, giving these products their unique texture and taste. It was affirmed Generally Recognized As Safe (GRAS) for use in human and animal food before the advent of semimoist foods. It was known for some time that propylene glycol caused Heinz body formation in the red blood cells of cats, but it could not be shown to cause overt anemia or other clinical effects. However, recent reports in the veterinary literature of scientifically sound studies have shown that propylene reduces the red blood cell survival time, renders red blood cells more susceptible to oxidative damage, and has other adverse effects in cats consuming the substance at levels found in semimoist food. In light of this new data, CVM is taking steps to amend the regulations to expressly prohibit the use of propylene glycol in cat foods.
Another pet food additive of some controversy is ethoxyquin. Ethoxyquin was approved as a food additive over thirty years ago for use as an antioxidant chemical preservative in animal feeds. Approximately six years ago, CVM began receiving reports from dog owners attributing the presence of ethoxyquin in the dog food with a myriad of adverse effects, such as allergic reactions, skin problems, major organ failure, behavior problems, and cancer. However, there is a paucity of available scientific data to support these contentions, or to show other adverse effects in dogs at levels approved for use in dog foods. As such, there is no sound scientific basis to warrant a change in the regulatory status of ethoxyquin at this time.
At minimum, a pet food label must state guarantees for minimum percentages of crude protein and crude fat, and maximum percentages of crude fiber and moisture. The "crude" term refers to the specific method of testing the product, not to the quality of the nutrient itself.
Some manufacturers include guarantees for other nutrients as well. Maximum ash is often guaranteed, especially on cat foods. Cat food commonly also bear guarantees for taurine and magnesium as well. For dog foods, minimum levels of calcium, phosphorus, sodium, and linoleic acid are found on some products. If the guarantees don't include information on a particular nutrient that you are interested in, ask the company, or don't buy the product.
Comparing the guaranteed analyses of dry and canned products, one will note that the levels of crude protein and most other nutrients are much lower for the canned product. This can be explained by looking at the relative moisture contents. Canned foods typically contain 75-78% moisture, whereas dry foods contain only 10-12% water. To make meaningful comparisons of nutrient levels between a canned and dry product, they should be expressed on a similar moisture basis. To roughly approximate this, the guarantees for the canned product should be multiplied by four.
When buying a canned food, look at the moisture guarantee. The maximum moisture content for a pet food is 78%, except for products labeled as a "stew," "in sauce," "in gravy," or similar terms. The extra water gives the product the qualities needed to have the appropriate texture and fluidity, but you are paying for it.
Nutritional adequacy statement:
A "complete and balanced" pet food must be substantiated for nutritional adequacy by one of two means. The first method is for the pet food to contain ingredients formulated to provide levels of nutrients that meet an established profile. Presently, the AAFCO Dog or Cat Food Nutrient Profiles are used. The recommendations of the National Research Council (NRC) were once used as the basis for nutritional adequacy, but they are no longer considered valid. If a pet food label still bears a "meets or exceeds NRC" claim, that means the product is old or the manufacturer has yet to comply with the new regulations.
The alternative means of substantiating nutritional adequacy is for the product to be tested following the AAFCO Feeding Trial Protocols. These products should bear a nutritional adequacy statement that begins "Animal feeding tests...." Not all products that bear the claim are the ones actually tested, however. Some may be members of a "family," formulated to be nutritionally similar or superior to the product tested. Because of some concerns regarding the application of the family concept by manufacturers, AAFCO is considering new regulations.
The nutritional adequacy statement will also state for which life stage(s) the product is suitable, such as "for maintenance, or "for growth." A product intended "for all life stages" meets the more stringent nutritional needs for growth and reproduction A maintenance ration will meet the needs of an adult, non-reproducing dog or cat of normal activity, but may not be sufficient for a growing, reproducing, or hard-working animal. On the other hand, an all life stages ration can be fed for maintenance. Although the higher levels of nutrients would not be harmful to the healthy adult animal, they aren't really necessary, however.
Feeding directions instruct the consumer on how much product should be offered the animal. At minimum, they should include verbiage such as "feed ___ cups per ____ pounds of body weight daily." On some small cans, this may be all the information that can fit. However, feeding directions for other pet foods are much more elaborate, especially on dry product labels.
The feeding directions should be taken as rough guidelines, a place to start. Breed, temperament, environment, and many other factors can influence food intake. The best suggestion is to offer the prescribed amount at first, but don't be afraid to increase or cut back as your eye guides you.
Feeding directions tend to overestimate requirements more often than underestimate them. There can be several explanations for this phenomenon, and the one you believe depends on how cynical you are. The more suspicious in nature will assume that the manufacturers simply want to sell more food. However, a more understanding explanation is that due to the wide variations in energy needs among individual animals, the manufacturers attempt to cover almost all contingencies by setting the directions for the most demanding.
Until recently, calorie statements were not allowed on pet food labels. New AAFCO regulations were developed to allow manufacturers to substantiate calorie content and include a voluntary statement.
If a calorie statement is made on the label, it must be expressed on a "kilocalories per kilogram" basis. Kilocalories are the same as the "Calories" consumers are used to seeing on food labels. A "kilogram" is a unit of metric measurement equal to 2.2 pounds. Manufacturers are also allowed to express the calories in familiar household units along with the required statement (for example, "per cup" or "per pound"). Even without this additional information, however, consumers can make meaningful comparisons between products and pick the product best suited for their animals' needs. As with the guaranteed analysis, to roughly compare the caloric content values between a canned and a dry food, multiply the value for the canned food by four.
If a calorie statement does not appear on the label, the calorie content of a pet food can be roughly estimated by using values given in the guaranteed analysis. To do this, perform the following calculations:
|Example:||Crude protein||24% x 3.5 = 84|
|Crude fat||10% x 8.5 = 85|
|NFE (100-52=48)||48% x 3.5 = 168|
|Calorie content = 337 X 10 = 3370 kcal/kg|
Although this calculation will give you a reasonable approximation of calories for most foods, it will likely somewhat underestimate the calorie content of very digestible foods, and overestimate the value of high fiber and low quality foods.
Other label claims:
Many pet foods are labeled as "premium," and some now are "superpremium" and even "ultrapremium." Other products are touted as "gourmet" items. However, none of these terms have any official regulatory standing. Products labeled as premium or gourmet are not required to contain any different or higher quality ingredients, nor are they held up to any higher nutritional standards than are any other complete and balanced products.
The term "natural" is often used on pet food labels, although that term does not have an official definition either. For some human foods, it is used to denote that the product is minimally processed. No pet food meets this criterion. It could also mean that the product approximates the natural diet of the animal. Wild dogs and cats eat whole bodies of birds and small mammals. A quick purview of any pet food label will fail to disclose these ingredients. Some interpret it to be equivalent to "no artificial ingredients." However, all complete and balanced products must contain some chemically synthesized ingredients, such as vitamin supplements. Thus, some products will include the disclaimer "natural ingredients with added vitamins and minerals."
For the most part, "natural" can be construed as equivalent to a lack of artificial flavors, artificial colors, or artificial preservatives in the product. As mentioned above, artificial flavors are rarely employed anyway. Artificial colors are not really necessary, except to please the pet owners eye. If used, they must be from approved sources' the same as for human foods. Especially for high-fat dry products, some form of preservative must be used to prevent rancidity. Natural-source preservatives, such as mixed tocopherols (a source of vitamin E), can be used in place of artificial preservatives. However, they are not as effective. If a product smells bad, or your pet doesn't eat it or gets sick from a product, take it back to the store or contact the manufacturer.
Following trends in the human food industry, many pet foods on the market claim to be ''lite" or "light" products. However, unlike new regulations for human foods, there are presently no standards for light pet foods. A manufacturer's light product is only light relative to another of the company's products. In some cases, one company's light product may contain more calories than the regular product of another's. Therefore, be careful when switching brands of light products, or you may be feeding your pet too much. Hopefully new AAFCO regulations will address this problem.
Pet owners have a right to know what they are feeding their animals. The pet food label contains a wealth of information, if one knows how to read it. Don't be swayed by the many marketing gimmicks or eye-catching claims. If there is a question about the product, contact the manufacturer or ask an appropriate regulatory agency.