By Dr. Becker
As I’ve discussed in past articles, I view the Association of American Feed Control Officials (AAFCO) as playing a necessary role in establishing basic nutritional standards for feeding animals.
Before AAFCO existed, countless pets died from diet-related diseases because human caretakers could only guess at what food to offer them. Unable to use their natural instincts to feed themselves properly, pets were and still are utterly dependent on humans to nourish them in a manner that meets their basic nutritional needs.
Fortunately, AAFCO has taken away some of the guesswork. In order for a commercial dog or cat food to be labeled “complete and balanced,” it must meet the minimum nutritional standards established by AAFCO.
There are still many people who don’t understand AAFCO’s role in pet food production. And there are also those who feel AAFCO’s nutritional guidelines are irrelevant or misleading. As the pet food market continues to grow and people learn more about how to provide better nourishment for their furry companions, I believe an understanding of AAFCO’s role in how pet food is produced, labeled and marketed in the U.S. is important in assembling all the pieces of the puzzle.
What AAFCO Is and Does
AAFCO describes itself as a “voluntary membership association of local, state and federal agencies charged by law to regulate the sale and distribution of animal feeds and animal drug remedies.”
AAFCO doesn’t test, approve, certify or regulate pet foods. Its stated goals are to provide protection for consumers, safeguard the health of animals and humans, and provide “a level playing field of orderly commerce for the animal feed industry.”
Pet food manufacturers are wholly responsible for formulating, labeling and advertising their products in compliance with local, state and federal laws. State feed control officials are charged with regulatory oversight of pet foods to enforce compliance.
AAFCO guidelines for pet food cover eight areas: brand and product name; species for which product is intended; directions for feeding; name and address of manufacturer; statement of net quantity; guaranteed analysis; ingredient list; and statement of nutritional adequacy.
Generally speaking, pet owners focus on just a few of these eight areas, including the guaranteed analysis, the ingredient list, and nutritional adequacy information.
The guaranteed analysis on a pet food label lists the minimum percentage of crude protein and fat contained in the product, and the maximum percentage of crude fiber and moisture.
The crude protein percentage indicates the total protein content of the food and not necessarily the amount of protein that is digestible. The actual amount of protein your pet’s body will be able to use depends on its source and quality.
The crude fat percentage is an estimate of the lipid content of the food; crude fiber is an estimate of the insoluble fiber content. As with crude protein, these percentages are not an indication of the quality or digestibility of the fat and fiber contained in the pet food.
Since the guaranteed analysis on most commercial pet foods doesn’t give an accurate picture of the amount of each nutrient, we have to do a little math to understand what’s really going on.
Here are the guaranteed analyses for a high quality and poor quality dog food:
|Raw, Sold Frozen
||'Premium' Dry Dog Food
|Guaranteed Analysis (as fed)
|Protein (not less than)
||Crude Protein (min)
|Fat (not less than)
||Crude Fat (min)
|Moisture (not more than)
|Carbohydrate (not less than)
|Fiber (not more than)
||Crude Fiber (max)
At first glance, it appears the dry dog food has a much higher amount of protein than the raw food, and slightly more fat. But to accurately compare the two foods, we have to convert the ingredients to dry matter using the following formula:
100 Percent - Percent Moisture = Percent Dry Matter (DM)
Using this formula, we can determine the percent dry matter (DM) of each food as follows:
|Raw food has 71% moisture
100% – 71% = 29%
The raw food is 29% DM
|Dry food has 14% moisture
100% – 14% = 86%
The dry food is 86% DM
Now that we know the dry matter content of each food, we can compare the true protein amounts with this formula:
Percent Protein / Percent DM = Percent Protein on a DM Basis
Using this formula, we can determine the percent protein of each food as follows:
Raw food: 12% protein, 29% DM
12% / 29% = 41%
Raw food has 41% DM protein
|Dry food: 25% protein, 86% DM
25% / 86% = 29%
Dry food has 29% DM protein
You can use the same calculations to compare the other guaranteed analysis ingredients on a DM basis as follows:
|Raw food: 8% fat
8% / 29% = 28%
Raw food has 28% DM fat
|Dry food: 10% fat
10% / 86% = 12%
Dry food has 12% DM fat
|Raw food: .5% fiber
.5% / 29% = .02%
Raw food has .02% DM fiber
|Dry food: 4% fiber
4% / 86% = .05% fiber
Dry food has .05% DM fiber
As you can see by this apples-to-apples comparison, the raw food has significantly higher percentages of the three most important pet food ingredients: protein, fat, and moisture.
As many of you are aware, the ingredient list on pet food labels has a specific hierarchy. Per AAFCO guidelines, ingredients must be listed in descending order by weight, and must be listed by their common or usual name. In addition, most of the primary ingredients will have a corresponding definition in the AAFCO Official Publication.
But here’s where it gets confusing. The weight of each ingredient is calculated before moisture is removed. Animal meat weighs considerably more before it is processed to remove all the moisture. This is how pet food manufacturers can list an animal protein as the first ingredient in grain-based pet foods. Once the moisture is removed from the meat, a re-weighing of the ingredients would reveal a single grain or mixture of grains to be the primary ingredient – not animal protein.
This method of weighing and listing ingredients makes it impossible to tell which proportions of nutrients are derived from each ingredient. It’s also impossible to tell the quality and digestibility of the food from the ingredient list.
Using the same foods from the guaranteed analysis example above, look at the stunning difference in ingredient lists between the two. Which would you prefer to feed your canine companion?
|Ingredients (Raw Dog Food)
||Ingredients (“Premium” Dry Dog Food)
Free-Range Meat = 69%
chicken meat including bone, chicken gizzards, chicken hearts and chicken livers
Organic Vegetables = 29.3%
carrots, squash, yams, zucchini, celery, romaine, parsley, apple cider vinegar
Special Nutrient Mix = 1.7%
kelp, sea salt, inulin, zinc, copper and iron amino acid chelates, vitamin E
|Ground yellow corn, corn gluten meal, whole wheat flour, animal fat preserved with mixed-tocopherols (form of Vitamin E), soy protein concentrate, soy flour, water, rice flour, pearled barley, sugar, tricalcium phosphate, propylene glycol, animal digest, dicalcium phosphate, salt, phosphoric acid, sorbic acid (a preservative), calcium carbonate, potassium chloride, L-Lysine monohydrochloride, dried spinach, dried apples, dried sweet potatoes, choline chloride, calcium propionate (a preservative), added color (Red 40, Yellow 5, Blue 2, Yellow 6), Vitamin E supplement, zinc sulfate, ferrous sulfate, manganese sulfate, niacin, Vitamin A supplement, copper sulfate, Vitamin B-12 supplement, DL-Methionine, calcium pantothenate, thiamine mononitrate, garlic oil, pyridoxine hydrochloride, riboflavin supplement, Vitamin D-3 supplement, calcium iodate, menadione sodium bisulfite complex (source of Vitamin K activity), folic acid, biotin, sodium selenite
If you’d like to learn more about what ingredients to look for and which to avoid in commercial pet food, there are a number of videos and articles here at Mercola Healthy Pets you’ll find helpful. I recommend starting with You Asked for It ... The 3 BEST Pet Foods You Can Buy and Part 2 - Your Pet's Food: Exposing Manufacturers' Dirty Tricks.
Nutritional Adequacy Statement
AAFCO requires pet food manufacturers to include validation of the nutritional adequacy of their formulas before they can print a nutritional adequacy statement on the label. This means the food meets AAFCO’s definition of complete and balanced nutrition in one or more canine or feline life stages.
To provide validation of nutritional adequacy, pet food manufacturers can either prove by formulation that a product contains required levels of all essential nutrients, or they can use AAFCO-approved feeding trials.
What About Pet Food Manufacturers Who Don’t Comply with AAFCO Guidelines?
If a manufacturer can’t provide validation of nutritional adequacy, the product label must state that the food is intended for supplemental or intermittent feeding only.
Problems can arise when pet food manufacturers choose not to formulate products using AAFCO’s minimum nutrient standards, because the standards have been established through scientific research into the minimum specific nutrients dogs and cats require at different stages of life.
Every pet food company has an obligation to have their formulas analyzed and their products clearly labeled with easy-to-understand information for consumers. If companies choose not to abide by the minimum nutrient guidelines set forth by AAFCO, they have a responsibility to explain their reasoning and how they are providing balanced nutrition for pets while bypassing AAFCO standards.
AAFCO provides basic nutritional guidelines that I view as a foundation upon which to build. These guidelines aren’t perfect, but if they are totally disregarded, it’s very easy to cause entirely avoidable nutritional health issues in pets.
Some people are able to create balanced, species-appropriate diets for their pets from scratch. Not everyone has the time, knowledge or desire to do this. Fortunately for those pet owners, AAFCO guidelines insure they can offer a minimally nutritious diet to their dog or cat by purchasing pet foods that meet AAFCO standards for complete and balanced nutrition.
In the near future, however, I would very much like to see AAFCO switch to optimal nutrient requirements rather than minimums and maximums, and factor digestibility and absorbability into their recommendations as well. There is much room for improvement with the basic guidelines set forth by this organization, but at least there are some basic standards in place.
And just like with the human food industry, pet owners are still left to decide what quality food they will feed their pet (ingredients can be terrible quality and/or rendered); how it is preserved (many commercial pet foods still contain carcinogenic additives and preservatives and GMO ingredients); if it is species-appropriate (many pet foods are not); and if the food contains optimal phytonutrients, antioxidants, essential fatty acids and food-sourced vitamins and minerals for their pet’s current age and health status. AAFCO addresses none of these issues, and educated pet parents often find themselves frustrated by the lack of industry standards in these areas.