Tag Archives: AAFCO


The Association of American Feed Control Officials (AAFCO) regulates — or perhaps more appropriately, regulates the regulation of — pet food at the state level. In essence, AAFCO is a trade association comprised of representatives from various states’ agricultural departments who individually help to regulate animal feed and pet food in their home states. Thus, although AAFCO lacks regulatory authority itself, it is comprised of officials that do have such authority. These officials meet numerous times throughout the year and establish and modify model regulations on animal feed and pet food that nearly all states adopt. The Model Pet Food Regulations establish standards of nutritional adequacy and labeling. Therefore AAFCO is the de facto regulator of pet food in most states.

Should pet food consumers rely on AAFCO? The short answer: no. AAFCO is concerned with nutritional adequacy[1], not optimization. Because of this lower threshold focus, AAFCO, like the FDA, allows things like dead zoo animals and road-kill to be introduced into pet food through innocuous sounding ingredients such as “Meat and Bone Meal”, which can include the “rendered product from mammal tissues, including bone, exclusive of any added blood, hair, hoof, horn, hide trimmings, manure, stomach and rumen contents except in such amounts as may occur unavoidably in good processing practices.”[2]This lawfully includes any dead mammal — even dead pets.

Similarly, an understanding of AAFCO’s labeling standards reveals that AAFCO’s aim may not be completely focused on making pet food labels simple for consumers to understand. For instance in a hypothetical dog food labeled “Beef Entrée for Dogs” the named ingredient “beef”, “must comprise at least 10% of the total product by weight and at least 25% of the product by weight not including the added water” so long as a qualifying word like “dinner” or “platter” is used.[3] The label undeniably implies that a majority of the meal should contain beef. How is a reasonable consumer supposed to know that a pet food manufacturer could add one of these qualifying words, and lawfully decrease the amount of beef to 25% of the total?

This unfortunate potential outcome may stem from AAFCO having the dual mandate of establishing standards for both animal feed and pet food. The former is feed for animals being raised for commercial purposes. The latter should be food for a loved family member. Perhaps they should be regulated separately.

[1] http://talkspetfood.aafco.org/faq
[2] http://talkspetfood.aafco.org/whatisinpetfood
[3] http://talkspetfood.aafco.org/readinglabels

Federal Regulation of Pet Food

According to the Food and Drug Administration (the FDA) the

…regulation of pet food is similar to that for other animal feeds. There is no requirement that pet food products have premarket approval by the FDA. However, the Federal Food, Drug, and Cosmetic Act (FFDCA) requires that pet foods, like human foods, be pure and wholesome, safe to eat, produced under sanitary conditions, contain no harmful substances, and be truthfully labeled.[1]  [Emphasis added].

The Federal Food, Drug and Cosmetic Act (the Act) defines food:

…(f) The term “food” means (1) articles used for food or drink for man or other animals…(3) articles used for components of any such article.[2] [Emphasis added].

Thus the Act that Congress passed to give the FDA its governing authority does not distinguish between food for humans and food for animals. Both should be held to the same standard.

In order for an article to be considered a food, it cannot be adulterated, which the Act also defines:

A food shall be deemed to be adulterated-
…(5) if it is, in whole or in part, the product of a diseased animal or of an animal which has died otherwise than by slaughter;…[3]

Despite this explicit ban on diseased or deceased animals not explicitly killed to become food, the FDA has determined that it will not enforce this provision of federal law:

Pet food consisting of material from diseased animals or animals which have died otherwise than by slaughter, which is in violation of 402(a)(5) will not ordinarily be actionable, if it is not otherwise in violation of the law. It will be considered fit for animal consumption.[4]

That is, if a pet food manufacturer complies with all other aspects of the Act, it can sell diseased animals and animals that died in a manner not intended for food, so long as it is cooked at an adequate temperature[5].  In other words, a dead rabid raccoon found on the roadside could lawfully be placed in your pet’s food so long as it is cooked.  You, the consumer, have no way of knowing this (more on labeling in another post).   Thus by not enforcing federal law  the FDA allows adulterated food to be used in pet food.  Unfortunately, this example is one of many of the FDA avoiding its congressional mandate with regard to pet food.  It is no wonder that pet food gets recalled so frequently.

Because we cannot rely on the federal government to protect our pet food supply, perhaps we should look to the state regulating authorities. Indeed, according to the FDA,

The best source of information about State rules is the Association of American Feed Control Officials (AAFCO). To promote uniform labeling requirements across all States and territories of the United States, AAFCO has developed a set of “Model Regulations for Pet Food and Specialty Pet Food” that are contained in AAFCO’s Official Publication. Since the AAFCO “Model Regulations” were developed consistent with Federal requirements, they are a useful resource for information on the regulation of pet food.[6]

We’ll take a look at AAFCO in a later next post.

[1] See http://www.fda.gov/ForIndustry/FDABasicsforIndustry/ucm238614.htm
[2] See 21 USC Section 321(f)
[3] See 21 USC Section 342(a)(5)
[4] See CPG Sec. 690.300
[5] Ibid.

What are Byproducts?

AAFCO defines “byproducts”, or “by-products” as “secondary products produced in addition to the principal product.”[1] In the case of pet food, byproducts are typically “the excess material left over after processing human foods.”[2]

The USDA separates animal byproducts into three categories: hides, inedible offal, and edible offal, with variety meats being a subcategory of the latter.[3] In addition to skeletal muscle, or what you typically order at the butcher for yourself, certain parts of animals are considered edible when certain conditions are met. Beef liver and tongue are two examples.

The inedible offal, or byproducts, remain and “include hide or skin, hair, horns, teeth, fats, bone, ligaments and cartilage, feet, glands, blood, and lungs” (emphasis added), as well as the otherwise edible offal that has been deemed inedible, and they may be used in pet food if they are either canned or rendered.[4] In Hill’s Science Diet Adult Light with Liver, a canned dog food, for instance, the third ingredient after water and corn, is “pork by-products”[5]. These can include any of the items just mentioned.   Moreover, save of “pork liver”, these “pork-by products” are the only meat in this dog food.

If not canned, however, the inedible animal byproducts can still be used to make pet food if they are rendered. Processors render byproduct meal by overcooking it and skimming off the fat. Sometimes the constituent animal of the byproduct meal is identified,  as in “chicken by-product meal”, “turkey by-product meal”, “beef by-product meal” and “poultry by-product meal.” (Chicken by-product meal is further subdivided into two categories: feed grade and pet food grade.) Other times this byproduct meal is identified generically, with names such as: “meat meal”, “meat and bone meal”, “meat by-product meal” and “animal by-product meal”. This byproduct meal lawfully includes, but is not limited to, road-kill, dead zoo animals, euthanized house pets and diseased livestock.

Alpo Prime Cuts Dry Dog Food, for example, contains, after corn, “meat and bone meal”[6], which according to AAFCO is a “rendered product from mammal tissues, including bone, exclusive of any added blood, hair, hoof, hide trimmings, manure, stomach and rumen contents.”[7] Neither a specific animal nor its condition is mentioned.  In short, there is no way in knowing with any degree of specificity what this ingredient is.  It could be filet mignon, or a euthanized pet.


[1] http://talkspetfood.aafco.org/byproducts
[2] Ibid.
[3] United States Department of Agriculture LDP-M-209-01; November 2011, Where the (Not) Meat? Byproducts from Beef and Pork Production. (Link).
[4] Ibid.
[5] http://www.hillspet.com/en/us/products/sd-canine-adult-light-canned
[6]  https://www.alpo.com/products/dry-dog-food/prime-cuts-dry/
[7] AAFCO, 2016 Edition, or http://www.aafco.org/Consumers/What-is-in-Pet-Food

What is Human-Grade?

AAFCO’s website nicely summarizes “human-grade” as it pertains to pet food:

There have been “human-grade” claims on some pet foods for a few years. This term has no definition in any animal feed regulations. Extremely few pet food products could be considered officially human edible or human-grade. A pet food that actually met these    standards would be expensive. While pet owners can buy what they feel is best for their pet, they should understand the definitions and the odds. [Emphasis added.]

The U.S. Department of Agriculture (USDA) defines products fit for human consumption to be officially “edible.” These foodstuffs have been processed, inspected and passed manufacturing regulations (i.e. process control regulations) that are designed to assure safety for consumption by humans.

Edible is a standard; human-grade is not. For a product to be deemed edible for humans, all ingredients must be human edible and the product must be manufactured, packed and held in accordance with federal regulations in 21 CFR 110, Current Good Manufacturing Practice in Manufacturing, Packing, or Holding Human Food. If these conditions are met for a pet food, human-grade claims may be made. If these conditions are not met, then it is an unqualified claim and misbrands the product. [Emphasis added.]

Misbranding a feed is a prohibited act subject to enforcement action on the responsible party. The presence of human-grade on a label implies a product or ingredients may meet the legally-recognized edible standard.[1]

Thus in order for a pet food to be “human-grade”, it must be legally “edible”, which pertains not only to the ingredients, but also to the conditions in which they were prepared and handled.[2]   Few pet foods meet this requirement.

Instead, most pet foods are feed-grade, or derive from “material that is safe, functional, handled, and labeled appropriately for its intended use in animal food.” By definition, this feed is inedible; that is, not safe for human consumption.

However, even if a pet food’s ingredients are “edible”, they must be prepared in accordance with Section 21 of the Congressional Federal Register, which has 100 regulations concerning food safety.  AAFCO, contrastingly, has only 15 of such regulations, which are considerably laxer.

Thus for pet food to truly be “human-grade” it needs to overcome two hurdles. First, it must be “edible”. Second, it must be prepared in accordance with regulations concerning human food. Despite many claims to the contrary, few pet foods prevail on these two tests.

[1] http://talkspetfood.aafco.org/humangrade