W H A T Y O U N E E D T O K N O W

This publication isprovided by Associ-ation for Truth in PetFood, as educationfor pet food con-sumers.

Associationfor

Truth inPet Food

The information provided in this booklet is intended as education for pet food consumers.

Unless the product is noted ‘for sup-plemental feeding’, all types of com-mercial pet food are considered‘complete and balanced’. This state-ment means the pet food is requiredto provide your pet with various nutri-ents as outlined by the Association ofAmerican Feed Control Officials (AAF-CO) specific to species (cats or dogs).More information on Complete andBalanced on the left of this page.

Only basic nutritional information isprovided on the pet food label, statedas ‘Crude’ (Crude Protein, Crude Fatand Crude Fiber). The term ‘crude’ de-fines the basic method of testing used(crude or basic testing) to determineprotein, fat, and fiber levels.

Pet food (in the U.S.) is primarily regu-lated by the Food and Drug Adminis-tration (FDA); specifically the divisionCenter for Veterinary Medicine (CVM).Each State Department of Agriculturehas authority over pet food (state law)but all states follow FDA’s authority.

The laws that govern pet food are theFederal Food, Drug, and CosmeticAct, and to a lesser extent state lawswritten by the Association of Ameri-can Feed Control Officials (AAFCO).However, many applicable laws arenot enforced.

One of the most important things forconsumers to know is that pet food

regulated as food. It is called food

– cat food or dog food – but most donot abide by food laws; most pet ‘foods’ are not food.

Cat food and dog food are termed‘food’, but most are not food as con-sumers understand the term (food).Through a series of confusing lawsand conflicting FDA Policies, most petfoods are regulated as animal feed(such as cattle feed, chicken feed).Animal feed does not follow food safe-ty law; feed is allowed to include any-thing from wholesome foodingredients to illegal material allowedby FDA to be disposed of in animalfood/pet food.

One of the most dangerous, illegalfeed/animal food ingredients - allowedby FDA into pet foods - is materialsourced from diseased or dead/non-slaughtered animals. Source: FDACompliance Policy 690.300, and FDACompliance Policy 675.400.

Pet foods that meet the requirementsof food are classified as human gradepet foods. Human grade pet foods aremanufactured in a certified humanfood facility, include 100% humanfood quality ingredients (USDA in-spected and approved human edible),and include 100% human quality sup-plements. Human grade pet foods arefood, exactly how pet owners are fa-miliar with the term food. ‘Humangrade’ will be stated on the pet foodlabel if the product meets the legalrequirements.

Other than human grade pet foods, all

What to know before you shop for pet food.

C O M P L E T E A N DB A L A N C E D

Most pet foods are sold as ‘Completeand Balanced’ nutrition. The claim isextremely misleading.

To be labeled as Complete and Bal-anced, one of two requirements mustbe met. 1. The pet food must meet theAAFCO nutritional profiles (for dogs orcats); or 2. The pet food passed anAAFCO certified feeding trial.

Most Complete and Balanced petfoods follow option one above.

The AAFCO nutrient profiles includeminimum requirements, with only afew maximums, as needed by catsand dogs. As example, for cat anddog foods there is a minimum require-ment of fat, however there is no es-tablished maximum for fat. Pet foodswith 5% fat and pet foods with 50% fatare both considered ‘balanced’ nutri-tion. The same holds true for manyother nutrients including vitamins andminerals. Again, the Complete andBalanced claim is misleading to con-sumers.

AAFCO certified feeding trails aremost commonly performed on catsand dogs in kennel laboratory set-tings; not on pets in real life situations.In recent years, some pet food manu-facturers are changing tradition per-forming feeding trials on real pets inhomes.

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pet foods can include inferior/illegalingredients; emphasis .Some, but not all, pet foods utilizeinferior/illegal ingredients.

As all pet food labels are required byregulation to look similar, the chal-lenge for pet food consumers is learn-ing which pet foods includeinferior/illegal ingredients. Questionsfound on the left side of this page willhelp consumers determine the qualityof the pet food (ingredients) they arepurchasing. Always ask questions ofthe manufacturer before you pur-chase.

The following list of pet food ingredi-ents are allowed through legal defini-tion to be sourced from diseasedanimals or dead/non-slaughtered ani-mals (inferior sources):

Chicken by-productsChicken by-product mealPoultry by-productsPoultry by-product mealMeat and bone mealBeef and bone mealAnimal fatAnimal digestMeat mealBeef mealLamb mealVenison meal

If a pet food contains one of the aboveingredients, ask the manufacturer fora guarantee in writing to quality of in-gredients. Ask: Are meat ingredientssourced from USDA inspected andapproved human edible sources?

For pet foods or treats to make the‘Made in the USA’ claim, the require-ment is the product is manufacturedin the U.S., and all ingredients aresourced from the U.S. However, thisrequirement is not enforced; anothermisleading marketing trick ignored byregulatory authorities.

Some pet food companies manufac-ture their own brands, some do not. Aco-packer is the term used for a manu-facturer that makes pet food for anoth-er brand. Ask who manufactures thepet food, ask about the recall historyof the co-packer.

Meat meals are ingredients unique topet food/animal feed (not used in hu-man food). The term ‘meal’ means theingredient has been cooked prior tothe cooking process of the pet food.Meat, and commonly bone and inter-nal organs are ground fine and cookedto become a powder-like substance(the meat meal).

Some believe meat meals providemore nutrition as the moisture is re-moved from the meat (meat containshigh levels of moisture). Others be-lieve the high level of processing de-creases the nutritional value (cookedonce in the processing of the meatmeal, cooked twice in the processingof the pet food).

Meat meals are most commonly used

What to know before you shop for pet food.

Q U E S T I O N S T O A S KP E T F O O D

Are meat, vegetable, grain, and fruitingredients human edible?

Are supplements human grade orfeed grade?

What is the country of origin of all in-gredients, including all supplements?

Who manufactures the pet food?

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in kibble pet foods.

Regulatory authorities ignore labelinglaws allowing pet foods to display im-ages of food (grilled steak, roastedchicken) when nothing in the pet foodlooks similar to the images displayed.Misleading images on pet food labelsare a direct violation of federal lawand many state laws, but currently noauthority enforces those laws. Imagesof food on pet food labels are in mostcases only marketing. Do not allowthem to influence your purchase deci-sions.

Pet foods that include the word ‘Fla-vor’ in the name – such as T-boneSteak Flavor – are not required to in-clude the named meat. The only re-quirement is the pet food to be‘flavored’ with the named meat; suchas T-bone steak flavor. (See more petfood name regulations left side of thispage.)

Kibble pet foods are probably themost popular style of pet food, not be-cause it is superior in nutrition; allcommercial pet foods are required toprovide the same nutrition. Kibble petfoods are the most popular simply be-cause of convenience. Most kibble petfoods are made via extrusion, a pro-cess where ingredients are cookedthrough pressure and steam. Kibble iscooked again in the drying process

and finally sprayed with flavoring (inmost cases) to enhance the taste.Cooking times vary with each manu-facturer.

The closest comparison of kibble petfood to human food – in manufactur-ing process only - is a fortified break-fast cereal (fortified meaning withadded vitamins and minerals; as ex-ample Total cereal). Cereal is madethrough a similar extrusion process.

Currently, there are no human gradekibble pet foods. The manufacturingprocess could become human grade,but thus far no manufacturer has cer-tified their facility.

Kibble pet foods, on average, containhigh amounts of starchy carbohy-drates. This is required due to themanufacturing process; needed tohold the kibble shape.

It is best to store kibble in its originalpackaging, bag placed inside an air-tight container. Original packaging isrequired if a pet becomes sick fromthe food.

Most kibble pet foods have a shelf lifebetween 6 months and 2 years (prod-uct is required to stay fresh and pro-vide required nutrition for the durationof the shelf life).

Canned pet food is similar to humancanned food, again – only through themanufacturing process. The pet foodis cooked in the can, not prior to can-ning. Varieties of canned pet foods

What to know before you shop for pet food.

P E T F O O D N A M E S

Just as with pet food ingredients, thenames of pet foods can be confusing.Below are explanations to variousregulations of pet food productnames.

Named MeatIf a pet food name is (example) BeefDog Food or Tuna Cat Food, regula-tions require the pet food to contain aminimum of 70% of the named meat(moisture removed).

If the pet food name includes twomeats (example: Beef and Tuna PetFood), the pet food is required to con-tain a minimum of 70% of the twonamed meats (moisture removed).

Dinner, Entree, FormulaIf a pet food name includes the wordsDinner, Entree, or Formula (example:Beef Dinner for Dogs or Chicken En-tree Cat Food) regulations require thepet food to contain a minimum of 10%of the named meat (excluding mois-ture). If the pet food name includestwo meats (Chicken and Liver Din-ner), the two meats combined are re-quired to be a minimum of 10% of thefood (excluding moisture).

WithIf a pet food name includes the wordWith (example: XYZ Pet Food WithBeef), regulations require the pet foodto contain a minimum of 3% of thenamed meat.

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include those in loaf style and thoseas a stew or with gravy.

Some canned pet foods include piec-es of actual meat; others containchunks of fabricated meat. Fabricatedmeat is an extruded meat productmade from meat slurry with addedvegetable starches to help hold thedesired shape. There is no disclosureon the pet food label to use of fabricat-ed meat. Consumers can learn someinformation from the ingredient listingto determine if the pet food containsactual meat or fabricated meat. Lookfor multiple gums (carrageenan, cas-sia gum) and or multiple starches(gluten, flour, or vegetable proteins).

Cooking/canning times vary with eachmanufacturer.

Most canned pet foods have a shelflife between 2 and 5 years.

Currently there are no human gradecanned pet foods. There are moist petfoods that are human grade, sold fro-zen in tubs. Because canned foods areso popular in human food, canned petfood could easily become humangrade if the manufacturer followed allfood regulation (human grade ingredi-ents and supplements). But to ourknowledge there are no human gradecanned pet foods currently.

While not as popular as canned petfood, another style of moist pet food issold frozen or sold in shelf stable

packaging. These products are mostoften cooked prior to packaging.

Shelf life varies with style, but com-monly these products have a shelf lifebetween 6 months and 1 year.

Some of these types of products arehuman grade, others are not. Thepackaging will state ‘Human Grade’ ifthe pet food meets the legal require-ments.

Commercial raw pet food is relativelynew to the market as compared to kib-ble and can, but actually this style ofpet food is the oldest form of cat anddog food. Long before commercial petfood, both cats and dogs consumedraw prey – such as birds, mice andrabbits.

Raw pet food is highly scrutinized byFDA; the only style of pet food FDAhas issued a consumer warningabout. FDA's concern is the spread ofbacteria; “raw pet food is more likelyto be contaminated with disease-caus-ing bacteria, such as and

This FDA warning is incorrect and ex-tremely misleading. FDA pet food re-call history details many more recallsfor dangerous bacteria with kibblefoods than raw (millions of pounds ofkibble recalled as compared to onlythousands of pounds of raw pet foodrecalled).

Shelf life varies between 6 monthsand 1 year frozen.

What to know before you shop for pet food.

P E T F O O DI N G R E D I E N T Q U A L I T Y

Pet food uses a different languagethan human food. As example, ‘chick-en’ in human food means USDA hu-man edible chicken meat. In pet food‘chicken’ can be USDA human ediblechicken meat, USDA condemnedchicken meat, or chicken skin andbones (no meat).

To make matters a little more chal-lenging for consumers, pet food ingre-dient definitions are not publicinformation. The AAFCO organizationholds control over all pet food ingredi-ent definitions, charging $100 for ac-cess. For consumers to understandthe ingredients in pet food, they mustpay the $100 fee or trust the manufac-turer.

Consumers should not assume thatpet food chicken, or any pet food in-gredient is similar to the same ingredi-ent in human food. Ask the pet foodmanufacturer for a detailed explana-tion to what type of chicken (or anyingredient) is used in the pet food. Isthe meat human edible meat?

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Some raw pet foods are human grade,however achieving the official humangrade status is challenging for raw petfood. FDA and the AAFCO require hu-man grade pet foods to be manufac-tured in a human food facility, butboth organizations neglect to recog-nize the United States Department ofAgriculture’s (USDA) role in humanfood. USDA oversees the productionof meat. Some raw pet foods are man-ufactured under constant inspection(same as human food) by USDA. Con-sumers can ask the manufacturer:was the pet food made under constantUSDA inspection and are supple-ments human grade? If yes, the petfood can be considered human grade.

Both of these styles of pet food are amethod used to preserve the food byremoving the moisture. Both styles ofpet food require the consumer to addmoisture back to the food before feed-ing.

There are human grade options in thiscategory.

Treats for cats and dogs are intendedas supplemental feeding, never as thesole source of food. The same lack ofenforcement of law and inferior quali-ty of ingredients apply to treats. Askthe same questions to a treat manu-facturer you would a food manufactur-er.

Should your pet become sick or dieand you believe the illness or death islinked to a pet food, the incidentshould be reported to proper authori-ties. Pet owners can report to FDA on-line or phone, for information ClickHere. Or report to state authorities. Tofind your state’s representatives ClickHere. Your veterinarian should reportthe food incident too.

return the food for a refund,packaging information will be neededfor investigation by authorities. All vet-erinary records relating to your pet’sillness should be provided to authori-ties; should the worst happen, anecropsy will benefit investigators.

What to know before you shop for pet food.

L A W S

The Federal Food Drug and CosmeticAct defines food as:

“The term "food" means (1) articlesused for food or drink for man or otheranimals, (2) chewing gum, and (3)articles used for components of anysuch article.”

The Federal Food Drug and CosmeticAct defines an adulterated (illegal)food as (in part):

“(3) if it consists in whole or in part ofany filthy, putrid, or decomposed sub-stance, or if it is otherwise unfit forfood; or”

“(5) if it is, in whole or in part, theproduct of a diseased animal or of ananimal which has died otherwise thanby slaughter;”

However, the FDA openly tells the petfood industry law will not be enforced:

“Pet food consisting of material fromdiseased animals or animals whichhave died otherwise than byslaughter…will be considered fit foranimal consumption.”

Do not assume your choice of petfood contains safe ingredients. Al-ways ask questions; Does this petfood abide by all food laws?

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Association for Truth in Pet Food (AT-PF) is a consumer association; a petfood consumer stakeholder group.Founder Susan Thixton represents petfood consumer members at AAFCOpet food regulatory meetings and withFDA.

One of the efforts ATPF has estab-lished is a voluntary pet food transpar-ency program titled Pledge to Qualityand Origin. To learn more and viewPledges received Click Here.

ATPF members and consumer non-members also performed the largestconsumer funded testing of pet food.To view those results Click Here.

Choosing a pet food is one of the mostimportant decisions a consumer mustmake. Association for Truth in PetFood provides this pet food education-al document to assist consumers inthat decision. This pet food booklet isnot all inclusive;

For print versions of this document,below are links provided within.

FDA Compliance Policieshttp://www.fda.gov/ICECI/ComplianceManuals/CompliancePolicyGuidanceManual/ucm074710.htm

http://www.fda.gov/ICECI/ComplianceManuals/CompliancePolicyGuidanceManual/ucm074717.htm

Report a sick pet to FDAhttp://www.fda.gov/AnimalVeterinary/SafetyHealth/ReportaProblem/ucm182403.htm

Report a sick pet to Statehttp://www.aafco.org/Regulatory

Association for Truth in Pet Foodhttp://associationfortruthinpetfood.com/

Susan Thixtonhttp://truthaboutpetfood.com/

What to know before you shop for pet food.

W H E R E T O P U R C H A S EY O U R P E T F O O D

Locally owned, independent pet foodstores are often the only source topurchase human grade pet foods.Many independent stores highly scru-tinize the products they carry andmost often are well informed aboutthe brands they carry.

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