By Dr. Becker
In a meeting in January, the Association of American Feed Control Officials (AAFCO) voted – after eight years of debate -- to approve changes to its regulations that will:
- Require calorie content statements on all dog and cat food labels
- Require that calorie content be expressed in terms of per-kilogram AND per-common unit (can, cups, pieces, etc.)
- Require identification of method of determination (“calculated” vs. “fed”)
The Association did not settle the matter of how long it will give pet food companies to comply with the new regulations. AAFCO’s Pet Food Committee and board of directors recommended a delay of 18 months before enforcing the regulations for new products, and three years for existing products.
The Association also didn’t determine whether the compliance clock should start when the new regulations are published in 2014, or whether it should start with the January 2013 meeting. Presumably that matter will be settled during the August 2013 meeting.
Proposed Change to the “95% Rule”
The AAFCO Pet Food Committee also accepted a proposed amendment to the “95% Rule” which was designed to keep manufacturers honest when it comes to naming their formulas. According to the FDA:
“The product name 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 of the product. Because many consumers purchase a product based on the presence of a specific ingredient, many product names incorporate the name of an ingredient to highlight its inclusion in the product.”
The “95% Rule” currently applies primarily to canned products containing ingredients of animal origin (typically meat, poultry or fish). If a formula is named “Salmon for Cats,” for example,” at least 95 percent of the ingredients must be salmon, not counting water added for processing, and “condiments.” When the water is counted, the salmon must still comprise at least 70 percent of the product.
If a product contains two meat, poultry or fish ingredients, for example, “Salmon and Turkey for Cats,” the salmon and turkey together must be 95 percent of the total weight, and there must be more salmon than turkey in the formula since it is named first.
Because the “95% Rule” as it currently stands applies only to ingredients of animal origin, if a product is named “Chicken and Rice Dog Food,” it must contain at least 95 percent chicken or it is considered misbranded.
The proposed amendment to the “95% Rule” (sponsored by the American Pet Product Association) would remove the ingredients-of-animal-origin-only restriction. According to PetfoodIndustry.com:
“This would make the 95% Rule consistent with other AAFCO naming regulations and allow companies to call out a broader range of ingredients in the product names.”
It’s difficult to say at this time whether the proposed amendment to the rule will benefit pets. It’s a given it will benefit pet food companies. In any event, the amendment still has to make it through the Model Bill and Regulations Committee, the AAFCO board and its membership before it becomes enacted.
Proposed New Minimum Requirements for Omega-3 Fatty Acids
Another project AAFCO is working on is a revision to their dog and cat food nutrient profiles and feeding trial protocols to include new minimum requirements for ALA, EPA and DHA (omega-3 fatty acids). If these changes are approved in August as expected, they will appear in the 2014 AAFCO Official Publication.
While I appreciate AAFCO’s efforts to add omega-3s to its nutrient profiles, I don’t believe processed pet food is the best delivery system for essential fatty acids. Omega-3 fats are very vulnerable to damage from heat and can easily lose their bioavailability during the kibbling or canning process. They are also very sensitive to oxygen and can become damaged quickly.
Krill oil is the supplement I recommend to insure your dog or cat is getting enough omega-3 fats in his diet.
Approval of New Uses for Xanthan Gum in Pet Food
Also of note is AAFCO’s Ingredient Definitions Committee approval of the use of xanthan gum not to exceed .25 percent in canned dog and cat foods. This ingredient, while widely used in human food products, was previously restricted to use in calf milk replacers and liquid feed supplements for cattle, sheep and other ruminants. According to PetfoodIndustry.com, the new uses of xanthan gum will require further action by AAFCO before approval.
For those of you unfamiliar with xanthan gum, it is made by fermenting corn sugar with Xanthomonas compestris, a bacteria. In processed foods xanthan gum is used as an emulsifier, a thickener, and increasingly as an ingredient in gluten-free products. Nutritionally, xanthan gum is a carb with about seven grams of fiber per tablespoon.
Xanthan gum is derived from a variety of sources, including corn, wheat and soy -- ingredients I always recommend avoiding in pet food. I don’t feel this ingredient is an appropriate addition to dog or cat food.