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, 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.”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. 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.