By Linda Bren

The nutritional adequacy statement assures consumers that a product meets all of a pet’s nutritional needs. The Association of American Feed Control Officials (AAFCO), an advisory body of state and federal feed regulators, develops recommended standards for nutrient contents of dog and cat foods. AAFCO also publishes ingredient definitions and regulations.

The FDA’s CVM works in partnership with AAFCO to determine safe pet food ingredients and testing protocols. In addition to federal regulation of pet food, most state governments regulate pet foods and labeling through their agricultural departments. AAFCO has created a model feed bill that states often adopt in their own laws.

CVM gives scientific and regulatory advice to AAFCO and the states on pet food issues, and CVM representatives serve on AAFCO committees and meet regularly with AAFCO’s board of directors. CVM investigators also team with AAFCO to check out questionable pet food ingredients or claims.

Manufacturers can show their food meets AAFCO’s standards for nutritional adequacy by calculations or by feeding trials. Calculations estimate the amount of nutrients in a pet food either on the basis of average nutrient content of its ingredients, or on results of laboratory tests–but not animal feed tests. If the calculations show that the food provides sufficient nutrients to meet the specific AAFCO nutritional profile referenced, the pet food label will carry a statement like: “(Name of product) is formulated to meet the nutritional levels established by the AAFCO (Dog or Cat) Food Nutrient Profiles for (specific life stage).”

Feeding trials signify that the manufacturer has tested the product (or a similar product made by the same manufacturer) in dogs or cats under strict guidelines. Products found to provide proper nutrition based on feeding trials will carry a statement such as: “Animal feeding tests using AAFCO procedures substantiate that (name of product) provides complete and balanced nutrition for (specific life stage).”

Regardless of the method used, the nutritional adequacy statement on a cat or dog food label must also tell which life stage the product is suitable for. AAFCO has established two nutrient profiles each for dogs and cats–growth/lactation and maintenance–to fit their life stages.

Every product must meet at least one of these two profiles. A product intended for growing kittens and puppies, or for pregnant or lactating females, must meet AAFCO’s nutrient profile for growth/lactation. Products that meet AAFCO’s profile for maintenance are suitable for an adult, non-reproducing dog or cat of normal activity level, but may not be adequate for an immature, reproducing, or hard-working animal. A product may claim that it is for “all life stages” if it is suitable for adult maintenance and also meets the more stringent nutritional needs for growth and reproduction.

Growth/lactation and maintenance are the only nutrient profiles authorized by AAFCO and CVM, so terms like “senior” or “formulated for large breed adults” mean the food meets the requirements for adult maintenance–and nothing more.

Snacks and treats that are clearly identified as such are not required to include a nutritional adequacy statement. But these foods, in all other respects, must meet FDA and state regulations for pet food labeling. Dog chews made from rawhide, bone, or other animal parts (such as pig ears) are also considered “food” since pets eat them. These products must bear a list of ingredients and provide the manufacturer’s name and address, but they are not required to give a guaranteed analysis, nutritional adequacy statement, or feeding instructions.

Ingredients

Like human foods, pet foods are regulated under the Federal Food, Drug, and Cosmetic Act, and must be pure and wholesome and contain no harmful substances. They also must be truthfully labeled. Foods for human or pet consumption do not require FDA approval before they are marketed, but they must be made with ingredients that are “generally recognized as safe” (GRAS) or ingredients that are approved food and color additives. If scientific data show that an ingredient or additive presents a health risk to animals, CVM can prohibit or modify its use in pet food.

Pet food ingredients must be listed on the label in descending order by weight. However, the weight includes the moisture in the ingredient, which makes it tricky to interpret. “A moist ingredient, such as chicken, which may be 70 percent water, may be listed ahead of a dry ingredient, such as soybean meal, which is only 10 percent water–yet the soy actually contributes more solids to the diet,” says Susan Donoghue, V.M.D., owner of Nutrition Support Services, Inc., and past president of the American Academy of Veterinary Nutrition.

Similar materials listed as separate ingredients may outweigh other ingredients that precede them on the list of ingredients. For example, chicken may be listed as the first ingredient, then wheat flour, ground wheat, and wheat middlings. The consumer may believe that chicken is the predominant ingredient, but the three wheat products–when added together–may weigh more than the chicken.