Tag Archives: Road-Kill


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

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