9

Chapter

Pet Foods
Labels
Philip Roudebush
David A. Dzanis
Jacques Debraekeleer
Hilary Watson

“Tell me what you eat and I will tell you what you are.”
Anthelme Brillat-Savarin, 1825

the production, marketing and sales of commercial pet foods in

different countries. Each agency or organization has different
INTRODUCTION
responsibilities with varying degrees of authority (Table 9-1).
The pet food label is an important means by which specific Some of these agencies and organizations regulate the informa-
product information is communicated between a manufacturer tion found on pet food labels whereas others influence the reg-
or distributor and consumers, veterinarians and regulatory offi- ulatory process.
cials. Commercial pet foods differ from human food products Pet foods are regulated at their point of sale. As an example,
in that the final consumer, the animal, is not the purchaser. pet food manufactured in the United States for sale outside the
Thus, there are two different “customers” with regards to safe- United States must meet the labeling requirements established
ty, nutritional balance and palatability. Pet food label informa- by the country in which the food is sold. Conversely, pet foods
tion is not directed to the final consumer, but to the owner or manufactured outside the United States must conform to Food
veterinarian who decides what the animal will be fed. and Drug Administration (FDA) and state pet food labeling
Implementation of the Nutrition Labeling and Education requirements when sold in the United States.
Act of 1990 and the Dietary Supplement Health and Education
Act of 1994 in the United States has led to increased consumer
awareness of the contents and effects of various human foods. PET FOOD LABELS IN THE
Consumer interest in human food label information has UNITED STATES
increased awareness of information available on pet food labels.
The regulations governing pet food labeling are similar to Regulation in the United States
human food labeling rules in many respects, but deviate signifi- Association of American Feed Control Officials
cantly in some important ways. Thus, veterinarians and pet Early regulators recognized the need for uniform and consis-
owners need to understand the rules specific to pet food label- tent regulation of animal feeds by forming the Association of
ing to obtain and best interpret information about a pet food. American Feed Control Officials (AAFCO) in 1909. AAFCO
is a private organization, not a regulatory body per se. However,
The Label as a Legal Document all AAFCO members must be state or federal government offi-
The pet food label is more than an attractive package cover cials. Members include animal feed control officials from indi-
designed to sell the product; the pet food label is also a legal vidual U.S. states and territories, federal agencies such as FDA
document. A number of agencies and organizations regulate and government representatives from Canada and Costa Rica.
192 Small Animal Clinical Nutrition

Table 9-1. Major governing agencies and organizations for commercial pet food manufacturers.

Agency Key functions

Association of American Feed Control Officials (AAFCO) Sets nutrient standards for substantiation of claims
Provides model regulations for the states
Provides ingredient definitions
U.S. Food and Drug Administration (FDA) Specifies some label requirements
Regulates health claims
Ensures food safety
Approves food additives
U.S. Department of Agriculture (USDA) Regulates some pet food ingredients
Inspects animal research facilities
State Department of Agriculture (or similar agency) Adopts and enforces animal food regulations
National Research Council (NRC) Evaluates and compiles nutrition research
Makes nutrient recommendations
Pet Food Institute (PFI) Trade organization that represents major pet food manufacturers in the
United States
Canadian Veterinary Medical Association (CVMA) Administers voluntary product certification in Canada
European Commission The main legislative body in the European Union responsible for creating
new directives and regulations
European Council of Ministers Approves directives and regulations
Creates basic laws
National Government (Ministry of Agriculture) Implements European legislation and controls its application
Houses national experts
European Federation of the Pet Food Industry (FEDIAF = Trade organization that represents major pet food manufacturers in Europe
Fédération Européenne de l’Industrie des Aliments pour
Aminaux Familiers)
Confederation of the Food and Drink Industries of the EU Trade organization that represents human food manufacturers in Europe
(CIAA = Confédération des Industries Agro-Alimentaires Works closely with FEDIAF on matters of mutual interest
de l’UE)

Representatives from pet food trade associations such as the Pet “lean” and “reduced calorie.” The Pet Food Committee has also
Food Institute (PFI) and the American Pet Products developed criteria for the official definition of product “fami-
Manufacturers Association and professional organizations such lies” whose lead member has been tested via the AAFCO feed-
as the American Veterinary Medical Association, Canadian ing trial protocol.
Veterinary Medical Association and American College of Many pet owners recognize the need to feed their animals
Veterinary Nutrition cannot be members of AAFCO, but do nutritionally balanced pet foods. As a consequence, consumers
attend AAFCO meetings and often serve as advisors to various usually purchase pet foods that are labeled “complete and bal-
AAFCO committees and investigators. anced.” One means of ensuring nutritional adequacy of a food
AAFCO provides a forum for local, state and federal feed requires that the food be formulated so essential nutrients meet
regulatory officials to discuss and develop uniform and equitable specified levels. Nutrient minimums before the early 1990s
laws, regulations and policies. In that capacity, AAFCO has were based on the recommendations of the National Research
developed model laws and regulations, which although are not Council (NRC). In 1990 and 1991, AAFCO established the
directly enforceable (because AAFCO is not a government Canine Nutrition Expert (CNE) and Feline Nutrition Expert
agency), have become the foundation for most state laws and (FNE) Subcommittees to establish updated practical profiles
regulations for all animal feeds. AAFCO addressed the need for based on commonly used ingredients. The CNE and FNE
information about pet nutrition and pet food regulations by Subcommittee reports formed the basis for new dog and cat
forming a permanent Pet Food Committee in 1959. Model reg- food nutrient profiles to be used as minimum standards for the
ulations applying specifically to pet foods were adopted in 1967. formulation of dog and cat foods (AAFCO, 2007). Two sepa-
Amendments to the AAFCO Model Pet Food Regulations rate AAFCO profiles exist for each species: one for growth and
occur frequently as needed to address new information and reproduction, and one for adult maintenance. Lower amounts
issues relating to pet foods and nutrition. They have been adopt- of some nutrients were established for adult dogs and cats,
ed in various degrees by approximately two-thirds of the states. eliminating unnecessary excesses. In addition, maximum levels
Today, individual members look to AAFCO for guidance when were established for some nutrients in dog foods, including cal-
establishing and revising state laws and regulations. cium, phosphorus, magnesium, fat-soluble vitamins and many
In addition, AAFCO remains the recognized information trace minerals. Maximum methionine, zinc and vitamin A and
source for pet food labeling, ingredient definitions, official D levels were established for cat foods. The AAFCO Dog and
terms and standardized feed testing methodology. The Model Cat Food Nutrient Profiles have replaced NRC recommenda-
Pet Food Regulations include calorie content statement guide- tions as the basis for the substantiation of label claims.
lines and definition of the pet food descriptive terms “light,” AAFCO (2007) also publishes minimum feeding protocols
 Pet Food Labels 193

for dog and cat foods. These are minimum testing protocols 2006). Before that, the most current NRC recommendations
used by manufacturers for substantiating the nutritional ade- for dogs and cats were published in 1985 and 1986, respective-
quacy of pet foods via feeding trials and determining metabo- ly (1985, 1986). Before the development and acceptance of
lizable energy of dog and cat foods. AAFCO’s Dog and Cat Food Nutrient Profiles, the NRC pub-
lications on nutrient requirements for normal dogs and cats
Food and Drug Administration were the recognized authority for substantiation of label claims
Under the Federal Food, Drug, and Cosmetic Act, the FDA on commercial pet foods. The AAFCO Dog and Cat Food
has broad responsibilities, including authority over pet foods. Nutrient Profiles have replaced the NRC recommendations as
Today, the Center for Veterinary Medicine (CVM), in FDA, the standard to be used by pet food manufacturers in the
regulates pet foods in cooperation with the individual states. United States for formulating foods for normal dogs and cats.
FDA is responsible for: 1) establishing certain animal food Currently, pet food labels in the United States that make ref-
labeling regulations, 2) specifying certain permitted ingredients erence to NRC nutritional recommendations are considered to
such as drugs and additives, 3) enforcing regulations about be misbranded. The NRC recommendations are still used by
chemical and microbiologic contamination and 4) describing some pet food manufacturers in countries other than the
acceptable manufacturing procedures. Feed control officials United States and reference to NRC is still found on some pet
within each state inspect facilities and enforce these regulations. food labels. With the most recent NRC edition, it is anticipat-
Health claims on pet food labels or literature accompanying the ed that AAFCO will reconvene its expert panel to review and
product are subject to regulation by CVM. A health claim is update the AAFCO Dog and Cat Food Nutrient Profiles in
defined as the assertion or implication that consumption of a light of the new NRC recommendations. AAFCO is not
food will treat, prevent or otherwise affect a disease or condi- expected to reinstate the NRC recommendations as the author-
tion (Dzanis, 1994). ity cited on pet food labels.

United States Department of Agriculture Pet Food Institute

The United States Department of Agriculture (USDA) is The PFI was organized in 1958 as the national trade association
responsible for ensuring that pet foods are labeled so they are of dog and cat food manufacturers in the United States. Active
not mistaken for human foods. The USDA inspects animal members of PFI produce 95% of the total dog and cat food ton-
ingredients used in pet foods to ensure proper handling and to nage in the United States (PFI, 1994). Affiliate members of PFI
guarantee that such ingredients are not used in human foods. include the leading suppliers of equipment, ingredients, packag-
The USDA also inspects and regulates animal research facili- ing and services to the United States pet food industry.
ties. All animal research facilities owned and operated in the PFI works closely with veterinarians, humane groups and
United States by pet food companies must fulfill USDA local animal control officers to sponsor public affairs and owner
requirements for: 1) record keeping, 2) physical structure, hous- education programs that encourage responsible dog and cat
ing and care of animals, 3) food and water quality and 4) sani- ownership. It also represents the industry before legislative and
tation. Research facilities are subject to unannounced inspec- regulatory bodies at the federal and state levels. In the past 20
tions by USDA officials at least annually. years, PFI has sponsored research on amino acid requirements
of dogs and cats, as well as research on the benefits of pet own-
National Research Council ership and the beneficial role of pets in society.
The NRC is a private, nonprofit organization that evaluates
and compiles research conducted by others. The NRC func- Individual States
tions as the working arm of the National Academy of Sciences, Each individual state is responsible for adopting and enforcing
the National Academy of Engineers and the Institute of pet food regulations. Many, but not all, states have adopted pet
Medicine (Phillips, 1992). The National Academy of Sciences food regulations that follow the model bill and model regula-
was created in 1863 to advise the United States federal govern- tions established by AAFCO. The State Department of
ment about scientific and technological matters (Phillips, Agriculture, Regulatory Protection Division or State Chemist
1992). The NRC was created in 1916 in response to the administers pet food regulation and enforcement in most states.
increased need for scientific and technical services during
World War I (Phillips, 1992). The NRC is not part of the Label Design
United States government, is not an enforcement agency and is A pet food label is divided into two main parts: 1) the principal
not a basic research organization with laboratories of its own. display panel and 2) the information panel (Figure 9-1). The
The NRC includes a Board on Agriculture and Natural principal display panel is defined by FDA as “the part of a label
Resources. One of the major activities of the Board has been that is most likely to be displayed, presented, shown or exam-
the development of nutrient requirement recommendations for ined under customary conditions of display for retail sale.”
domestic animals. Numerous ad hoc committees have assisted The principal display panel is the primary means of attracting
in developing the series, Nutrient Requirements of Domestic the consumer’s attention to a product and should immediate-
Animals. As part of that series, a new edition of Nutrient ly communicate the product identity. The information panel
Requirements of Dogs and Cats was published in 2006 (NRC, is defined as “that part of the label immediately contiguous
194 Small Animal Clinical Nutrition

Principal Display Panel Information Panel

Nutrition claim Manufacturer’s name Brand name Guaranteed or Feeding guide Ingredient list
typical analysis

Breed Very small Small Medium Large

size Up to 10 lbs 10-20 lbs 20-50 lbs 50-90 lbs
Daily Up to 1/2 to Up to 1 1/2 to
amount 1/2 can 1 can 1 can 2 cans

Ingredients: Water, Chicken, Liver, Soy flour, Poultry

® by-product meal, Cracked barley, Ground corn, Iodized
salt, Calcium carbonate, Vegetable oil, Choline chloride,
Minerals, Vitamins

Guaranteed Analysis:
Crude protein..........min. 8.0%
Crude fat...................min. 5.0%
Crude fiber...............max. 1.5%
Moisture...................max. 75.0%
Ash.............................max. 3.0%

Complete and balanced diet for adult canine

maintenance based on AAFCO feeding studies.
PETRITE Nutrition, Inc.
Box 234 • Hometown, USA • 10010

net wt 22 oz (623 g)

Quantity of Product name Designator Product Name and address Nutrition Universal
contents (statement vignette of manufacturer adequacy product
of intent) statement code

Figure 9-1. Typical pet food label with all elements.

Table 9-2. Key elements found on pet food labels in the United
focus on the major features found on these two portions of the
States and Canada. pet food label.
Principal display panel Information panel
Product identity Ingredient statement*
Principal Display Panel
Manufacturer’s name Guaranteed analysis* PRODUCT IDENTITY
Brand name Nutritional adequacy or nutritional The product identity is the primary means by which a spe-
Product name* purpose statement (product
description)*
cific pet food is identified by consumers. In the United States,
Designator (intended species)* Feeding guidelines* the product identity must legally include a product name but
Net weight* Statement of calorie content may also include a manufacturer’s name, a brand name or
Product vignette Manufacturer or distributor*
Nutrition claim Universal product code
both. The brand name is the name by which pet food prod-
Bursts and flags Batch information ucts of a given company are identified and usually conveys the
Freshness date overall image of the product. The product name provides
*Elements required on pet food labels in the United States, information about the individual identity of the particular
on labels certified by the CVMA Program and in some other product within the brand. The manufacturer or distributor is
countries. not required to include its name as part of the product iden-
tity on the principal display panel, but must include its name
and address on the label.
and to the right of the principal display panel” (FDA) and Initial assessment of pet foods is best determined by looking
usually contains important information about the product. In at the product name on the principal display panel. The prod-
the United States and some other countries, several items are uct name is usually descriptive of the food and in the United
required by law to be included on the principal display and States is subject to AAFCO regulations about composition of
information panels (Table 9-2). The following discussion will ingredients. Percentage rules are important; beef ingredients
 Pet Food Labels 195

Interpretation: Interpretation:
Chicken and egg Beef is at least 25%
ingredients are used of total product
in the product, but are
probably less than 3%
of total product

Interpretation: Interpretation:
Shrimp is at least 3% Tuna is at least 70%
of total product. Moisture of total product
content is greater than 78%
since the descriptor “in jelly”
is used

Figure 9-2. Examples of pet food descriptor terms.

will be used as an example (Figure 9-2): 1) unqualified use of Percentage rules also apply to product names and moisture
the term “Beef ” in a product name requires that beef ingredi- content of foods. In the United States, the maximum moisture
ents be at least 95% or more of the total weight of all ingredi- content in all pet foods should not exceed 78%. However, pet
ents exclusive of water used in processing, but in no case less foods can have moisture contents higher than 78% if they are
than 70% of the total product, 2) use of the term “Beef ” with a labeled as a stew, gravy, broth, juice or milk replacer. High-
qualifier such as “Beef dinner,” “Beef platter,” “Beef entree,” moisture pet foods in cans, pouches or tins will contain terms
“Beef formula,” or any similar designation requires that beef such as “in sauce,” “in aspic,” “in gravy” or some similar desig-
ingredients be at least 25% of the total weight of all ingredients nation in the product name.
exclusive of water used in processing, but in no case less than
10% of the total product, 3) the term “With Beef ” is intended DESIGNATOR
to highlight minor ingredients and this example requires that The words “dog food,” “for cats” or some similar terminolo-
beef ingredients be at least 3% of the total product and 4) the gy must appear conspicuously on the principal display panel of
term “Beef flavor” does not stipulate a minimum percentage. pet foods sold in the United States. These terms clearly identi-
The beef flavor designation usually indicates that beef is less fy the animal for which the product is intended and that the
than 3% of the total product. An ingredient that gives the char- product is not for human consumption.
acterizing flavor (e.g., beef digest, beef by-products) can be used
instead of the actual named flavor, beef. In fact, some ingredi- NET WEIGHT
ents may be less than 1% of the total product and still appear in FDA regulations state that the principal display panel shall
the product name as a flavor. This type of regulation is also bear a declaration of the net quantity of contents. The term
found in human foods in which the product names cranberry “Net Weight” is used most often and must be displayed in
juice, cranberry juice cocktail and cranberry drink indicate dif- conspicuous and easily legible print. Most often, “dual decla-
ferent levels of actual juice in the product. rations” are made, so that the net weight is stated in avoirdu-
196 Small Animal Clinical Nutrition

NUTRITION CLAIM
Box 9-1. AAFCO Guidelines for “Natural” Nutrition statements appearing on the principal display
Claims. panel are usually brief. Examples include the terms “complete
and nutritious,” “100% nutritious,” “100% complete nutrition”
“Natural” ingredients must be from animal or plant origin or a or some similar designation. A nutritional adequacy statement
mined product (e.g., salt). Processes such as extraction, hydroly- on the information panel must substantiate nutrition claims on
sis and fermentation are permitted. the principal display panel. If the nutritional adequacy state-
Any chemical synthetic process, such as addition of a chemi- ment on the information panel is for a limited lifestage (e.g., for
cal moiety to a vitamin, is not “natural” under AAFCO definitions. maintenance only), the principal display panel claim must be
A pet food bearing an unqualified “natural” claim may not con-
suitably qualified, such as “100% complete nutrition for adult
tain ANY ingredients that do not meet the AAFCO definition for
“natural.” dogs.” Manufacturers can substantiate these nutrition claims by
“Natural” pet foods may contain synthetic nutrients provided a meeting the appropriate AAFCO nutrient profile or success-
qualifying disclaimer is added, e.g., “Natural ingredients with fully completing a protocol feeding trial. Nutrition claims sub-
added vitamins, minerals and taurine,” but not other synthetic stantiation for “natural” foods is discussed in more detail below
substances such as artificial preservatives or colors. (Box 9-1).
The term “natural” may also be used to characterize a single
ingredient, e.g., “natural cheese flavor,” provided it does not imply BURSTS AND FLAGS
that the product itself is “natural.” Bursts and flags (Figure 9-3) are areas of the principal dis-
play panel that are designed to highlight information or provide
specific information with visual impact. Table 9-3 lists the type
of information often included in bursts and flags. New prod-
Table 9-3. Examples of words used on bursts and flags on pet ucts, formula or ingredient changes and improvements in taste
food labels.
are most often highlighted. The time allowed for a burst or flag
5 pounds more to be on the label varies with the type of information. “New” or
Even fewer calories than _____ “New & Improved” can only appear on the label for six months,
Freshness guaranteed
Great new taste
whereas a comparison such as “Preferred 4 to 1 over the lead-
Great taste ing national brand” can remain on the label for one year, unless
More delicious taste than _____ resubstantiated.
New
New & improved
New flavor Information Panel
New formula INGREDIENT STATEMENT
New pâté style
New recipe
Pet foods sold in the United States must list each ingredient
New taste of the food in the ingredient statement. Ingredients are listed in
No artificial colors and flavors descending order by their predominance by weight according
Pleasant aroma
Soy free
to the product’s formula. AAFCO has established the name
Taste preferred 4 to 1 over leading national brand and definition of a wide variety of ingredients. The ingredient
Taste preferred over leading dog biscuit names must conform to the AAFCO name (e.g., poultry by-
product meal, corn gluten meal, powdered cellulose) or when a
suitable AAFCO name does not exist, should be identified by
pois (pounds and ounces) and metric (kilograms or grams) the common or usual name (e.g., beef, lamb, chicken).
units. The regulation of net weight declarations is complex. Ingredients listed as “meat” or “meat by-products” must desig-
Net weight descriptions must be placed on the principal dis- nate the mammal from which the ingredients are derived unless
play panel within the bottom 30% of the panel in lines gener- the meat or meat by-products are derived from cattle, swine,
ally parallel to the base of the package, and they must be sep- sheep or goats. For example, ingredients derived from deer
arated from all other text above, below and to each side by would be listed as venison or venison by-products. Brand or
minimum specifications. The regulations also specify mini- trade names cannot be used in the ingredient statement and no
mum type sizes depending on the square inch area of the reference to quality or grade of ingredients can be made.
principal display panel. Collective terms (e.g., “animal protein products”), allowed for
use on livestock and poultry feed labels, are not allowed on pet
PRODUCT VIGNETTE food labels in the United States (Table 9-4).
The term product vignette refers to a vignette, graphic or pic- The list of ingredients may be helpful, although it has some
torial representation of a product on a pet food label. This rep- shortcomings that limit its usefulness for evaluating pet foods.
resentation should not misrepresent the contents of the pack- The nutritive value of ingredients can be estimated, but not
age. This means that a picture or other depiction of the prod- definitively determined, from the ingredient statement alone. A
uct or ingredients on the label should not look better than the consumer must rely on the reputation or word of the manufac-
actual product or ingredients. turer to assess the nutritive value of the ingredients appearing
 Pet Food Labels 197

on the list. A serious limitation of the ingredient statement is

that terms such as “meat by-products” are difficult to evaluate.
The nutritive value of various meat by-products varies widely.
As an example, meat by-products such as liver, kidney and
lungs have excellent nutritive value whereas other meat by-
products such as udder, bone and connective tissue have poor
nutrient availability.
Because individual ingredients are listed in descending order
by weight for the product as a whole, careful reading of the
ingredient list may be needed to fully understand the true rela-
tive proportions of ingredients in the product. A pet food that
lists several related ingredients or different forms of the same
ingredient separately (e.g., wheat germ meal, wheat middlings,
wheat bran, wheat flour) could make wheat-based ingredients
appear to be a lower portion of the food than is the fact. Also,
Figure 9-3. One label with a flag and one label with a burst.
because an ingredient’s position on the list includes its inherent
water content, this allows dry ingredients to appear lower on
the list than ingredients that are naturally high in moisture.
This basic principle is commonly used in moist meat-type Table 9-4. Ingredient statement from the same dry dog food as
dog foods in which textured vegetable protein (TVP) is a major it would appear on pet food labels from selected countries.
portion of the product. The ingredient list may look like this for United States
a food named a “beef dinner:” Water sufficient for processing, Ingredients: Corn Meal, Chicken Meal, Soybean Meal, Animal
meat by-products, beef, soy flour, cornstarch…. In this kind of Fat (Preserved With Mixed Tocopherols And Citric Acid),
Natural Chicken Liver Flavor, Vegetable Oil, Dried Egg Product,
food, water is typically combined with soy flour to produce Flaxseed, Salt, Calcium Carbonate, Minerals (Ferrous Sulfate,
TVP. The TVP makes up a predominant portion of the food, Zinc Oxide, Copper Sulfate, Manganous Oxide, Calcium Iodate,
but soy flour appears lower on the ingredient statement because Sodium Selenite), Vitamins (Choline Chloride, Vitamin A
Supplement, Vitamin D3 Supplement, Vitamin E Supplement, L-
it is a “dry” ingredient whereas other components of the food Ascorbyl-2-Polyphosphate [A Source Of Vitamin C], Niacin,
are added as “wet” ingredients. The consumer thinks he or she Thiamine Mononitrate, Calcium Pantothenate, Pyridoxine
is purchasing a beef-based food when in fact, there is more soy Hydrochloride, Riboflavin, Folic Acid, Biotin, Vitamin B12
Supplement), Beta-Carotene.
flour than beef when the two are compared on an equal mois-
ture (“dry matter”) basis. Canada
This same principle is used in dry pet foods in which “fresh” Ingredients: Grain Products, Poultry Products, Soybean Meal,
Stabilized Poultry and/or Animal Fat, Vitamins and Minerals.
meats are highlighted. The ingredient list may look like this for CVMA-Certified Product
a lamb and rice dog food that claims to provide “real lamb Ingredients: Corn Meal, Chicken Meal, Soybean Meal, Animal
meat:” Lamb, brewers rice, ground yellow corn, corn gluten Fat, Dried Whole Egg, Vegetable Oil, Salt, Plus All Necessary
Vitamins and Minerals.
meal, oat groats, poultry by-product meal, beef tallow…. Lamb
appears first on the ingredient list because its moisture content Europe*
is higher than that of the other dry ingredients. The predomi- In Europe there are two options:
1) Ingredient groupings
nant portion of the food contains a mixture of grains (rice, corn, Ingredients: Cereals, Meat and Animal Derivatives, Vegetable
oats) rather than “real meat.” Protein Extracts, Oils and Fats, Eggs and Egg Derivatives,
Pet food additives such as vitamins, minerals, antioxidant Minerals.
2) Individual ingredient listing
preservatives, antimicrobial preservatives, humectants, coloring Ingredients: Ground Corn, Chicken Meal, Soybean Meal,
agents, flavors, palatability enhancers and emulsifying agents Animal Fat, Dried Egg Product, Brewers Rice, Vegetable Oil,
that are added by the manufacturer must be listed in the ingre- Iodized Salt, Calcium Carbonate, Magnesium Oxide.
*Antioxidants, preservatives, vitamins and coloring agents are
dient statement. Pet food additives must conform to the not listed under ingredients because they are considered addi-
requirements of the applicable regulations in the United States tives and are declared elsewhere on the label.
Code of Federal Regulations as food additives (21 CFR 573) or
as ingredients generally recognized as safe (GRAS) (21 CFR
582). Some additives are listed only in the sections for human include minimum percentages for crude protein and crude fat
direct food additives or for GRAS substances, but are allowed and maximum percentages for crude fiber and moisture (Table
in pet foods by informal review. With FDA review and concur- 9-5). Guarantees for other nutrients may follow moisture, but a
rence, AAFCO has also established definitions for some addi- nutrient need not be listed unless its presence is highlighted
tives that are not formally codified in the federal regulations. elsewhere on the label (e.g., “contains taurine,” “calcium
enriched”). Guarantees for substances not listed in the
GUARANTEED ANALYSIS AAFCO Dog or Cat Nutrient Profiles (e.g., vitamin C, L-car-
In the United States, pet food manufacturers are required to nitine, glucosamine, chondroitin sulfate) should immediately
198 Small Animal Clinical Nutrition

plant material has been treated with dilute acid and alkali solu-
Table 9-5. Guaranteed or typical analysis from the same dry
cat food as it would appear on pet food labels from selected
tions. It is determined by a specific analytical procedure that
countries. was originally developed for the wood pulp industry and then
applied to animal foods. Although crude fiber is used to report
United States (guaranteed analysis)
Crude protein Minimum 30.0%
the fiber content of commercial pet foods, it usually underesti-
Crude fat Minimum 18.0% mates the true level of fiber in the product. Crude fiber is an
Crude fiber Maximum 2.0% estimate of the indigestible portion of the food for dogs and
Moisture Maximum 10.0%
Vitamin E Minimum 275 IU/kg
cats (Chapter 5). The crude fiber method typically recovers a
Ascorbic acid (vitamin C)* Minimum 50 mg/kg large percentage of cellulose and lignin in a sample, and a vari-
Canada (guaranteed analysis) able percentage of hemicellulose and even ash.
Protein - 30.0%
Fat - 18.0%
Moisture is determined by drying a sample of the product to
Moisture - 10% a constant weight. The drying procedure measures water in the
CVMA-Certified Food in Canada (guaranteed analysis) product as a whole, but does not distinguish between added
Crude protein Minimum 30.0%
Crude fat Minimum 18.0%
water and water in the ingredients. Subtle differences in mois-
Crude fibre Maximum 2.0% ture content of moist products can result in marked differences
Moisture Maximum 10.0% in dry matter content and therefore the economics of feeding a
Ash Maximum 5.0%
Europe (typical analysis)
given pet food. Remember, the dry matter content of the food
Crude protein - 31.3% contains all of the nutrients except water. For example, compare
Crude oils and fats - 21.3% the dry matter content of three different moist cat foods: 1)
Crude fibre - 2.0%
Crude ash - 4.7%
Food A contains 72% moisture, 2) Food B contains 78% mois-
Moisture - 7.5% ture and 3) Food C contains 82% moisture.
Additives (per kg) Food A 100 - 72% water = 28% dry matter
Vitamin A - 17,100 IU
Vitamin D3 - 1,710 IU
Food B* 100 - 78% water = 22% dry matter
Food C** 100 - 82% water = 18% dry matter
*28 - 22 ÷ 22 x 100 = 27% more dry matter in Food A (72%
Vitamin E - 290 mg
Copper (copper chloride) - 21 mg
Contains EU permitted antioxidant
moisture) vs. Food B (78% moisture)
**28 - 18 ÷ 18 x 100 = 55% more dry matter in Food A (72%
Contains EU permitted colorant
*Not recognized as an essential nutrient by the AAFCO Cat
Food Nutrient Profiles. moisture) vs. Food C (82% moisture)
Therefore, what appears to be a small difference in water
content of a food produces a marked difference in dry matter
follow the listing of recognized nutrients and be accompanied content. Guarantees are expressed on an “as is” or “as fed” basis.
by an asterisk referring to the disclaimer “Not recognized as an It is important to remember to convert these guarantees to a
essential nutrient by the AAFCO Dog (or Cat) Food Nutrient dry matter basis when comparing foods with differing moisture
Profiles.” The sliding scale method of listing guarantees as per- content (e.g., moist vs. dry foods).
centage ranges (e.g., minimum 15 to 18%) is not allowed. It is Although a maximum ash guarantee is not required in the
important to recognize that these percentages generally indi- United States, many pet food manufacturers include one on the
cate the “worst case” levels for these nutrients in the food and labels of their foods. In the United States, “low ash” claims are
do not reflect the exact or typical amounts of these nutrients. not allowed because “ash” per se is of no true significance. “Low
This differs from pet food labels in Europe where “typical” per- magnesium” claims on cat food labels are allowed if the food
centages are used. meets certain FDA criteria. In such cases, a maximum magne-
The term crude protein refers to a specific analytical proce- sium guarantee is required. To be labeled as a “low magnesium”
dure that estimates protein content by measuring nitrogen. food, the product must contain less than 0.12% magnesium, on
Crude protein is an index of protein quantity but does not indi- a dry matter basis, and less than 25 mg per 100 kcal metaboliz-
cate protein quality (amino acid profile) or digestibility able energy. Actual analytical values must show that the product
(Chapter 5). consistently meets these levels. The estimation of magnesium
Crude fat refers to a specific analytical procedure that esti- content based on calculation from the guaranteed analyses must
mates the lipid content of a food obtained through either ether meet these criteria as well. The only exception occurs when the
extraction or acid hydrolysis. In addition to lipids, this proce- label bears an AAFCO calorie content statement that is higher
dure also isolates certain organic acids, oils, pigments, alcohols than would be estimated from the guaranteed analysis.
and fat-soluble vitamins. Because fats have more than twice the Ash consists of all noncombustible materials in the food,
energy density of proteins and carbohydrates, crude fat can be usually salt and other minerals. A high ash content in dry and
used to estimate the energy density of the food. If the moisture soft-moist foods generally indicates a high magnesium content.
and crude fiber content of two foods are somewhat similar, the However, the ash content of moist cat foods usually correlates
food with the higher crude fat guarantee will usually have the poorly with the magnesium content. Excessive magnesium
higher energy density. intake may be one risk factor for feline struvite urolithiasis
Crude fiber represents the organic residue that remains after (Chapter 43).
 Pet Food Labels 199

Table 9-6. How to interpret label claims of nutritional adequacy.*

Claim 1: “Good Things Beef Flavor Dog Food is formulated to Things Nutrition Center.”
meet the nutritional levels established by the AAFCO (Association Interpretation: This food (or a family member) has undergone
of American Feed Control Officials) Dog Food Nutrient Profiles for AAFCO minimum protocol feeding studies for adult maintenance
maintenance of adult dogs.” only and has not been tested for gestation/lactation or growth. The
Interpretation: This food has been formulated to meet the nutrient language of the statement is not in compliance with AAFCO regu-
levels in the AAFCO Dog Food Nutrient Profile for adult mainte- lations.
nance. This product does not meet the nutrient profile for
growth/lactation and has probably not undergone AAFCO feeding Claim 6: “Complete and balanced nutrition for all lifestages of the
tests. dog, substantiated by testing performed in accordance with feed-
ing protocols established by AAFCO.”
Claim 2: “Good Things Chicken Recipe Cat Food meets the nutri- Interpretation: This dog food (or a family member) has undergone
ent requirements established by the AAFCO Nutrient Profile for all AAFCO minimum protocol feeding trials for gestation/lactation and
stages of a cat’s life.” growth. The language of the statement is not in compliance with
Interpretation: This food has been formulated to meet the nutrient AAFCO regulations.
levels in the AAFCO Cat Food Nutrient Profile for growth/lactation
and adult maintenance. This product has probably not undergone Claim 7: “Meets or exceeds the nutritional levels established by
AAFCO feeding tests. The language of the statement is not in the National Research Council recommendations for all stages of a
compliance with AAFCO regulations. cat’s life.”
Interpretation: This cat food has been formulated to meet or
Claim 3: “Animal feeding tests using the AAFCO procedures sub- exceed the nutrient levels established for growth, gestation/lacta-
stantiate that Good Things Lamb Meal and Rice Formula Dog tion and adult maintenance by the National Research Council
Food provides complete and balanced nutrition for the growth of (NRC) in the United States. This product has probably not under-
puppies and maintenance of adult dogs.” gone feeding tests. This nutrition statement would be considered
Interpretation: This food has successfully completed an AAFCO misbranded in the United States because the NRC nutrient recom-
minimum protocol feeding trial for growing puppies (10 weeks of mendations have been replaced by AAFCO Cat Food Nutrient
feeding) or is a family member of a tested product. It probably, but Profiles. However, references to NRC are still made on pet foods
not necessarily, is formulated to meet the AAFCO Dog Food sold in countries other than the United States.
Nutrient Profiles for maintenance and growth/reproduction.
Claim 8: “Good Things for Dogs: CVMA Certified; Certified by the
Claim 4: “Good Things Cat Food with Tuna provides complete Canadian Veterinary Medical Association to meet its nutritional
and balanced nutrition for kittens and adult reproducing queens as standards on the basis of comprehensive feeding trials, chemical
substantiated by feeding tests performed in accordance with pro- analysis and on-going monitoring.”
cedures established by the Association of American Feed Control Interpretation: This dog food meets or exceeds the standards
Officials (AAFCO).” established by the CVMA Pet Food Certification Program for adult
Interpretation: This cat food (or a family member) has undergone maintenance. The food meets or exceeds the CVMA standards for
AAFCO minimum protocol feeding studies for gestation/lactation nutrient content, digestibility and labeling requirements. Nutrient
and growth. This food would be nutritionally adequate for adult digestibility is the only feeding test performed after the product is
cats but is not recommended by this manufacturer for long-term initially certified.
maintenance of adult cats. The language of the statement is not in
compliance with AAFCO regulations. *Claims 2, 4, 5 and 6 appear on pet food labels in the United
States market, but Claim 3 is the preferred wording for products
Claim 5: “Complete and balanced nutrition for adult maintenance that have passed an AAFCO protocol feeding trial, and Claim 1 is
based on AAFCO protocol feeding studies conducted at the Good the preferred wording for products that meet the profiles.

NUTRITIONAL ADEQUACY AAFCO (2007) nutrient profiles are published for two cate-
STATEMENT gories: 1) growth and reproduction and 2) adult maintenance.
Since 1984, regulations in the United States have required The formulation method allows the manufacturer to substanti-
that all pet food labels, with the exception of products clearly ate a “complete and balanced” claim by calculating the nutrient
labeled as “treats” and “snacks” (and more recently as “supple- content of a food using standard nutrient information about
ments”) contain a statement and validation of nutritional ade- ingredients or by chemical analysis of the final product. Table
quacy. When a claim of “complete and balanced,” “100% nutri- 9-6 lists some of the wording that connotes this type of claim,
tious” or some similar designation is used, manufacturers must but the only statement that is acceptable in states that follow
indicate the method and lifestage that was used to substantiate AAFCO Model Pet Food Regulations is “(Complete name of
this claim (Table 9-6). product) is formulated to meet the nutritional levels established
AAFCO (2007) regulations allow three basic methods to by the AAFCO Dog (or Cat) Food Nutrient Profiles for
substantiate claims. The formulation method requires that the (lifestage).” The formulation method is less expensive and
manufacturer formulate the food to meet the AAFCO Dog or time-consuming, but has been criticized because it does not
Cat Food Nutrient Profiles. The feeding trial (protocol) account for acceptability of the food or nutrient availability. A
method requires that the manufacturer perform an AAFCO- report in 1991 documented that some commercial pet foods
protocol feeding trial using the food as the sole source of nutri- that made “complete and balanced” claims by formulation
tion. The family method allows product analyses to ensure that methods alone did not provide adequate growth of normal ani-
the pet food is a member of a product family in which the lead mals because of poor availability of nutrients in the food
member has successfully passed a feeding trial. (Huber et al, 1991). However, that study was based on the older
200 Small Animal Clinical Nutrition

NRC recommendations, not the AAFCO Dog Food Nutrient AAFCO-sanctioned metabolizable energy feeding trial, the
Profiles, which had additional safety considerations built in to nutritional adequacy statement as used for the tested product
help mitigate the potential for these types of deficiencies. may also be used for the family members. Although infrequent-
The feeding trial (protocol) method is generally considered ly observed in the market, labels of family members whose calo-
the preferred method for substantiating a claim. Feeding tests rie content was determined by calculation methods must
can be used to support a nutritional adequacy claim for one or state,“(complete product name) provides complete and bal-
more of the following categories: 1) gestation and lactation, 2) anced nutrition for (lifestage), and is comparable in nutritional
growth, 3) maintenance and 4) all lifestages. AAFCO has pub- adequacy to a product which has been substantiated using
lished minimum testing protocols for adult maintenance, AAFCO feeding tests.”
growth and gestation/lactation. A food that successfully com- Pet foods that are clearly labeled as snacks, treats or supple-
pletes a gestation/lactation trial followed by a growth trial using ments may make a nutritional adequacy claim but are not
the offspring from the gestation/lactation trial can make a required to do so. Pet foods that fail to meet AAFCO require-
claim for all lifestages. The required terminology for labels of ments by any of the standard methods and are not clearly
pet foods that have passed these tests is: “Animal feeding tests labeled as snacks, treats or supplements are required to have the
using AAFCO procedures substantiate that (complete product nutritional statement: “This product is intended for intermit-
name) provides complete and balanced nutrition for tent or supplemental feeding only.”
(lifestage).” The wording must appear verbatim. Deviations Veterinary therapeutic/wellness foods are those products that
from the above statement, while occasionally observed on some are intended for use by or under the supervision or direction of
pet food labels, are currently considered misbranded in the a veterinarian. These foods may contain the nutritional state-
United States (Table 9-6). ment “use only as directed by your veterinarian.” In addition to
AAFCO feeding trials are minimum protocols. As an this statement, the label must include the appropriate lifestage
example, the adult maintenance protocol uses eight animals AAFCO nutritional adequacy claim or an “intermittent or sup-
that are fed the food as the sole source of nutrition for six plemental” feeding statement.
months. A veterinarian examines the animals at the beginning
of the study and at the end of 26 weeks for clinical signs of FEEDING GUIDELINES
nutritional deficiency or excess. Body weight is recorded In the United States, dog and cat foods labeled as complete
weekly and minimal laboratory evaluations (total erythrocyte and balanced (including snacks and treats) for any or all
count, hemoglobin, packed cell volume, serum alkaline phos- lifestages must list feeding directions on the product label for all
phatase, serum albumin and whole blood taurine in cats) are lifestages for which the product is intended. These directions
performed. This type of protocol will usually detect the vast must be expressed in common terms and must appear promi-
majority of nutrient deficiencies but might not detect some nently on the label. Feeding directions should, at a minimum,
nutrient excesses that may be harmful when fed over a longer state, “Feed (weight/unit of product) per (weight unit) of dog
period. In this respect, the AAFCO profiles are better because (or cat)” and frequency of feeding. These feeding statements are
maximum levels of some nutrients are also established. general guidelines at best. Because of individual variation, many
Growth protocols include feeding the food for a minimum of animals will require more or less food than that recommended
10 weeks. Because this test is conducted during the most crit- on the label to maintain optimal body condition and health.
ical stage of the puppy’s or kitten’s development, it is very sen- There is an exception to this rule for products that bear the
sitive in detecting deviations from normal growth. The gesta- “use only as directed by your veterinarian” statement. Because
tion/lactation trial considers factors such as litter size and sur- the veterinarian will presumably provide proper instruction
vivability and health of the dam. about feeding of the product, explicit feeding directions are not
The family method of nutritional substantiation is a combi- required. Many veterinary therapeutic/wellness products, how-
nation of the formulation and feeding trial methods. An indi- ever, may still provide specific directions either on the label or
vidual product can be a member of a product family and be in accompanying product literature.
nutritionally similar to a lead product that has undergone
AAFCO feeding tests. AAFCO (2007) has established clear STATEMENT OF CALORIE CONTENT
procedures for establishing pet food product families. To qual- The label of a dog or cat food in the United States may bear
ify, the family member must be the same processing type as the a statement of calorie content provided the statement is sepa-
tested product, sufficiently close to the tested product in metab- rate from the guaranteed analysis and appear under the head-
olizable energy content, analyzed and shown to meet the levels ing “calorie content.” At this time, it is required for “light” and
of the tested product for crude protein, calcium, phosphorus, “less calorie” pet foods, but is voluntary on others. The state-
zinc, lysine and thiamin (plus potassium and taurine for cat ment is based on kilocalories of metabolizable energy (ME) on
foods), meet either the tested product or the AAFCO Dog or an as fed basis and must be expressed as kilocalories per kilo-
Cat Food Nutrient Profiles minimums for all other nutrients gram (kcal/kg) of product. The statement may also be expressed
and meet all established AAFCO Dog or Cat Food Nutrient as kilocalories per familiar household measure (e.g., kcal/cup,
Profiles maximums. When the calorie content of both the test- kcal/can), in addition to, but in lieu of, the kcal/kg value.
ed product and family members are determined by an There are two methods for determining calorie content. The
 Pet Food Labels 201

first is the “calculation method,” wherein analytical values for violations of Canadian labeling legislation and in assessing
the calorie-containing nutrients in the food (protein, fat and complaints about false or misleading pet food labels or adver-
carbohydrates) are used to estimate metabolizable energy by the tising. For this reason, most reputable Canadian pet food com-
“modified Atwater” formula. This formula is based on average panies adhere to the Competition Bureau guidelines.
digestibility of these nutrients in commonly used pet food
ingredients. As such, it tends to underestimate the true calorie CVMA Pet Food Certification
content of very highly digestible foods and overestimate the The Canadian Veterinary Medical Association (CVMA) Pet
calorie content of poorly digestible foods. Food Certification Program was established in 1976 as a volun-
Calorie content may also be determined by conducting tary, third-party, quality assurance program for pet foods sold in
AAFCO-sanctioned feeding trials to obtain a more accurate Canada. The CVMA Program establishes nutrient standards,
measurement of digestibility. The most common method is to lifestage feeding protocols and digestibility feeding protocols
feed animals the pet food in question for five days, then to very for dogs and cats (CVMA, 1999; Allard, 1988). Similar to PFI
carefully measure food intake and fecal excretion for an addi- and NRC, the CVMA is not a regulatory agency but provides
tional five days. Comparing “what goes in” to “what comes out,” a method of voluntary enforcement of certain standards for pet
with some additional estimates for nitrogen loss in urine, is a foods. Involvement in the CVMA Pet Food Certification
more reliable method for determining metabolizable energy. Program is not mandatory.
To differentiate the two methods on a pet food label, a calo- The mission of the CVMA Pet Food Certification Program is:
rie content statement determined by the calculation method “To improve the health and well-being of pets by: 1) provid-
must include the word “calculated.” ing a nutritional standard for pet foods for manufacturers to
meet in order to satisfy the nutritional requirements of a nor-
GENERAL INFORMATION mal pet throughout its life, 2) certifying pet foods that meet
In the United States, the name and address of the manufac- the CVMA nutritional standards and monitoring continu-
turer, distributor or dealer must be found on the label, usually ously those foods to ensure that they continue to meet the
on the information panel. The phrases “Distributed by....” or standards of composition, digestibility and palatability, 3)
“Manufactured for....” or “Imported by....” indicate that a com- providing the consumer with a quality assurance program
pany other than the one selling the product has manufactured and a means of identifying a nutritionally sound pet food in
the pet food. This is a common practice with private label brand the marketplace, 4) ensuring the CVMA Seal of Cer-
pet foods. The manufacturer in this case is called a co-packer. tification becomes synonymous in the Canadian public’s
Regulations require that if the product is manufactured in a mind with quality and integrity by assuring that all advertis-
country other than where it is sold, the manufacturer’s informa- ing statements are fairly presented and can be supported by
tion be accompanied by “Product of (country of origin).” the advertiser and 5) helping pet owners understand the
Although not a legal requirement, most manufacturers importance of proper nutrition in preventive health care and
include the universal product code (UPC) or bar code on the 6) encouraging the funding of small animal nutrition
label. Other information such as batch numbers and date of research” (1999).
manufacture are also frequently found on pet food containers or All CVMA-certified pet foods are allowed to display the
labels. This information is important to know when communi- CVMA Seal of Certification on their labels for products sold in
cating with a manufacturer about product in a specific contain- Canada. Because of AAFCO restrictions, pet food containers
er. Some manufacturers will use a freshness date such as “Best sold in the United States cannot display the CVMA Seal.
before (date)” or list other guarantee policies.
Principal Display Panels
Principal display panels on Canadian pet food containers
PET FOOD LABELS IN CANADA may vary. The Canadian government requires that product
identity and net quantity (net weight) be listed on all prin-
Regulation in Canada cipal display panels of pet foods sold in Canada. Other ele-
The Canadian government has few pet food labeling regula- ments of the principal display panel described under United
tions. The Consumer Packaging and Labelling Act specifies that States regulations may appear on the container depending
three basic mandatory statements must appear in English and on several factors.
French languages on a pet food label for food sold in Canada: The CVMA Pet Food Certification Program requires more
1) product identity, 2) product net quantity (metric units first) extensive labeling requirements than does the Canadian law
3) and the dealer’s name and principal place of business. (Allard, 1988). The CVMA Program labeling requirements
The Canadian government’s Competition Bureau has pub- include product identity, designator and net quantity, which
lished a “Guide for the Labeling and Advertising of Pet Foods” are usually found on the principal display panel (Allard,
(2001). This guide provides a voluntary code of conduct setting 1988). Nutritional claims can be stated but must be substan-
out best practices for the labeling and advertising of Canadian- tiated. Product names can contain ingredients (Beef stew,
produced pet foods. Although these guidelines are not law, the Beef flavor, etc.) as described earlier for United States’ labels
guide is used by the Competition Bureau in evaluating possible and follow roughly the same percentage rules. Pet foods that
202 Small Animal Clinical Nutrition

meet the requirements can display the CVMA mums (not more than 6% dry matter) are
Seal of Certification on the principal display required for cat foods certified by the CVMA
panel (Figure 9-4) (CVMA, 1999). Program, and magnesium maximums (not
Requirements dictate the maximum size of more than 0.1% dry matter) are required for
the logo for different sizes of containers cat foods that make a “low ash” claim.
(CVMA, 1999).
The Competition Bureau voluntary guide- Nutritional Adequacy Statements
lines regarding the principal display panel are The CVMA Pet Food Certification
similar to those for the United States and the Program has published nutrient standards
CVMA Certification Program. These guide- and protocols for digestibility feeding trials
lines require the substantiation of any nutrition- for dogs and cats (1989). Nutrient,
al claims, and provide definitions for ingredients digestibility, feeding protocol and feeding
referenced in the product name (i.e., Beef dog guideline standards have also been pub-
food, Beef dinner etc). The Competition lished for “special foods” including light
Bureau’s guidelines follow similar percentage (lite) foods, calorie-reduced foods, geriatric
rules to those of the United States. foods, growth foods, gestation/lactation
Commercial pet foods produced in the foods and low-ash, low-magnesium cat
United States for sale in Canada will usually foods. Feeding trials are incorporated into
contain the elements of the principal display the standards for geriatric foods (three-
panel legally required in the United States; month period) and growth foods (weaning
namely, 1) a product name, 2) designator and Figure 9-4. The CVMA seal. to six months). Products that meet these
3) net weight. Pet foods produced in Canada standards can display the CVMA Seal of
that are not CVMA certified are not legally Certification and use the following words as
required to conform to the stricter labeling requirements of a nutritional statement: “This product meets nutritional stan-
the United States or CVMA Program, but most Canadian dards established by the Canadian Veterinary Medical
pet foods do follow the comparable guidelines published by Association (CVMA).” In addition to the CVMA certifica-
the Competition Bureau. Other elements of the principal dis- tion logo, products certified as special foods may carry lan-
play panel such as the manufacturer’s name, brand name, guage to the effect that: “This product is formulated to pro-
product vignette and bursts/flags are also found on Canadian vide (claim for level of nutrients)” or “This product meets the
labels. CVMA standard for a (type of special food).”
The Competition Bureau Guidelines state that nutritional
Information Panels adequacy claims can be made if they are based on animal feeding
Ingredient Statements protocols and nutrient profile programs such as those adminis-
Ingredient statements on pet food containers in Canada also tered by the Pet Food Association of Canada, the CVMA or
vary. Canadian government regulations do not require an AAFCO. The guidelines further state that products that are for-
ingredient statement. However, the Competition Bureau mulated for or suitable for only a limited purpose, such as supple-
guidelines state that ingredients must be listed on the label, mental feedings or that are limited to specific lifestages, must
that manufacturers should follow the AAFCO feed ingredient contain a statement to that effect. If a product is intended to be
definitions and ingredients should be listed in descending used under the supervision of a veterinarian, the following claim
order by percentage of weight. The CVMA Program states must be included on the product label: “Use only as directed by
that ingredients should be listed on the label in decreasing your veterinarian.” The guidelines specifically forbid drug claims
order of concentration in the product. Pet foods produced in (i.e., the words “diagnose,” “cure,” “mitigate,” “treat” or “prevent”
the United States and sold in Canada will usually meet the disease must not be used on a pet food label).
United States regulations for ingredient lists. Pet foods pro- Some products in Canada will reference the NRC for com-
duced in Canada that are not CVMA certified generally fol- plete and balanced nutrition claims, although this reference is
low the Competition Bureau’s guidelines even though they are no longer legal in the United States. Based on published
not required to by law (Table 9-4). NRC nutrient standards, these claims refer to the formula-
tion/analysis method. Table 9-6 includes nutritional claims
Guaranteed Analysis that appear on pet foods sold in Canada.
Canadian law does not require guarantees on pet food labels.
The voluntary Competition Bureau Guidelines state that a Other Items on Information Panels
guaranteed analysis must be shown on the label and must In Canada, pet foods certified by the CVMA must provide
include the following on an “as fed” basis: crude protein (mini- feeding instructions on the label if they are sold as light, calorie-
mum %), crude fat (minimum %), crude fibre (maximum %) and reduced or geriatric foods. Pet foods certified by the CVMA
moisture (maximum %). Pet foods certified by the CVMA Program as light, calorie-reduced or geriatric foods have energy
Program must also include the above guarantees. Ash maxi- density (kcal/gram of dry matter gross energy) standards, but
 Pet Food Labels 203

caloric density is not required on the label.

Competition Bureau guidelines also require that feeding Table 9-7. National member organizations of FEDIAF.
instructions appear on the product label. The guidelines Austria: ÖHTV Italy: ASSALCO
also cover misrepresentations with respect to business Belgium: BKVH/CPAF Netherlands: VKH
claims (i.e., rank of the company in the industry, length of Denmark, Norway & Sweden: NPFA Poland: Polikarma
Finland: Lemmikkieläinruokayhdistys Portugal: ALIAN
time in business, etc.) as well as deceptive endorsements or France: FACCO Slovenia: GIZ_PHMZ
testimonials. Germany: IVH Spain: ANFAAC
Greece: GPFMA Switzerland: VHN
Hungary: HPFA United Kingdom: PFMA
PET FOOD LABELS IN EUROPE Ireland: PFAI

Regulation in Europe
The regulations about pet food labeling for Europe, as dis-
cussed in this chapter, apply primarily to the 25 member states These Committees draw up legislative proposals, and amend
of the European Union (EU) and Switzerland. Legislation and adopt Commission and Council proposals. Two
controlling pet food labels originates in EU institutions and is Committees can be involved in pet food legislation: “the
then implemented into national law. Outside the EU, individ- Committee responsible for environment, public health and
ual countries have different structures and rules. food safety” and “the Committee responsible for agriculture
and rural development.”
European Union
COUNCIL LEGISLATIVE PROCESS
The Council of the EU is the EU’s main decision-making Two kinds of legislative pieces can come forth: a directive or
institution. The Council of the European Union is the a regulation. A directive must be implemented into national law
forum within which the ministers of the EU meet. within a period stipulated in the directive. The national law can
Depending on the subject on the agenda, each country is be more restrictive than the European directive but must always
represented by the minister responsible for that particular be within the scope and spirit of the directive. A regulation
subject (e.g., agriculture, public health etc.) There are nine must be adopted by national law without changes and is appli-
different Council “configurations.” cable almost immediately after publication. The directives for
The Council passes laws, usually in cooperation with the EU feeding stuffs contain strict provisions and stipulate definitions
Parliament. In principle, the EU Commission proposes laws for for ingredients, for methods of sampling and analysis and for
the Council, which examines and adopts them or proposes types and maximum levels of permitted additives.
modifications.
NATIONAL AUTHORITIES
EUROPEAN COMMISSION The national, regional or local governments in EU coun-
The Commission acts with complete political independence, tries apply the EU’s health and consumer protection laws.
and must not take instructions from any member state govern- Their job is to ensure traders, manufacturers and food pro-
ment. The Commission has the right to propose new EU leg- ducers in their country observe the rules. After a piece of leg-
islation and ensures that the regulations and directives adopted islation has been published in the Official European Journal,
by the Council and Parliament are implemented. A civil serv- the national government must implement it immediately
ice made up of 36 “Directorates-General” (DGs) and services, (regulation) or, in the case of a directive, translate the legisla-
based mainly in Brussels and Luxembourg, assists the tion into national law within the specified time (Borchardt,
Commission. Each DG deals with specific matters; DG Sanco 1994). The individual countries through their Ministries of
(Health and Consumer Protection Directorate General) large- Agriculture are responsible for controlling the application of
ly regulates pet food and labeling issues. DG Sanco’s work is the law by checking labels and taking samples for analysis.
divided into three main areas: public health, food safety and National experts, who work closely with the European
consumer protection. Commission on legislation, reside under the Ministries of
In most cases, the various DGs of the European Agriculture of the different member states.
Commission prepare an initial text for adoption as a
Commission Proposal. During this preparation phase, national FÉDÉRATION EUROPÉENNE
civil servants, the industry, consumers and other interest groups DE L’INDUSTRIE DES ALIMENTS POUR
and outside professionals may be consulted. AMINAUX FAMILIERS
Established in 1970, the Fédération Européenne de
EUROPEAN PARLIAMENT l’Industrie des Aliments pour Aminaux Familiers (FEDIAF)
The European Parliament is the only supranational institu- represents the pet food industry in Europe and unites the
tion whose 732 members are directly elected by the citizens of national professional organizations of 19 countries, whether
the 25 member states. The European Parliament is involved in they belong to the EU or not (Table 9-7) (FEDIAF, 1993;
legislative activity through its 20 parliamentary committees. PFMA, 1993). FEDIAF represents approximately 450 compa-
204 Small Animal Clinical Nutrition

CONFÉDÉRATION DES INDUSTRIES AGRO-

Table 9-8. Product descriptors used in Europe. ALIMENTAIRES DE L’UE
Claim/description Level of the named ingredient The Confédération des Industries Agro-Alimentaires de
With beef flavor Greater than 0 but less than 4% of the l’UE (CIAA), also known as the Confederation of the Food
Beef flavor named flavor should be present and Drink Industries, is analogous to FEDIAF for human
With rabbit At least 4% of the named species should foodstuffs. Both federations work closely together in matters of
Contains rabbit be present common interest that are regulated by the same legislation.
Advertising, claims and environmental matters are regulated
High in chicken At least 14% of the named species
With extra chicken should be present for human and animal foods by the same law.
Extra chicken

Beef variety At least 26% of the named species

Label Design
Beef dinner should be present Pet food labels in Europe are divided into a Principal Display
Beef recipe Panel and the Statutory Statement, although the distinction
Beef menu may be less visible than that for pet food labels in the United
Beef with cereal
States. The Council Directive on the circulation of compound
Brand name rabbit All contents are of the named origin with feeding stuffs (79/373/EEC, April 1979) regulates the statuto-
no other ingredients present except ry statement. This directive has been updated several times with
gravy, jelly, sauce, permitted additives
and nutrient supplements a major update (Council Directive 90/44/EEC), which has
been in force since January 1992. The pet food industry is also
protected by Directive 2002/32/EC and amendments, which
Table 9-9. Information found in the statutory statements of
regulate maximum residue levels of undesirable substances such
European pet food labels. as heavy metals, mycotoxins and dioxins in feeding stuffs for
animals and ingredients for commercial foods/feeds.
Additives
Address of person (company) responsible for the accuracy of
declarations Principal Display Panel
Complete/complementary food As in the United States, this part of the label gives information
Expiration date and reference to manufacturing date
Ingredient list
about product identity, shows graphics and pictures, includes
Instructions for use marketing claims to promote the product and contains descrip-
Net weight and/or volume tions of meat types and other information that companies may
Reference (batch) number
Registration number of the plant
choose to convey outside of the statutory statements.
Species/category No specific rules apply to the principal display panel other
Typical analysis than general legislation concerning misleading claims that
applies to all advertising (Council Directive 84/450/EEC and
amendments). Labels should not mislead the purchaser; the
nies responsible for producing more than 90% of European pet label must not suggest that the product possesses properties
food. The national organizations represent manufacturers, that it does not have, nor should the label imply that the prod-
packers and importers of prepared pet food, including foods for uct is special when similar properties are found in other prod-
dogs, cats, birds and other pets. ucts. A pet food label must not claim that the product will pre-
FEDIAF’s main role is to represent the European pet food vent, treat or cure disease.
industry in all external forums (FEDIAF, Website 2006). Directive 90/44/EEC, Art. 5.c.4 is the only text directly
FEDIAF cooperates with the European authorities to imple- referring to claims on pet food labels. It allows pet food manu-
ment pet food law designed to ensure the manufacture and dis- facturers to claim a low or high level of a specific ingredient on
tribution of healthy, balanced and quality products. New legis- the condition that the percentage is specified and that the claim
lation is translated by FEDIAF into labeling guidelines, which reflects an essential aspect of that particular food. In the
in some countries is then implemented into a “Code of absence of more specific legislation and to protect the consumer
Practice” for the members. against unsubstantiated claims, a policy for claiming meat and
Through the nutrition working party, FEDIAF publishes flavor varieties has been proposed within the FEDIAF (Table
nutrition guidelines as a policy paper for members. To develop 9-8). These guidelines serve an advisory role and are currently
these guidelines the group uses NRC recommendations, under discussion. Although they are not official law with force
AAFCO guidelines and studies published by internationally of application, in some countries (e.g., France) the authorities
recognized nutritionists, veterinarians and other researchers. use those guidelines to judge labels for misleading claims.
These guidelines are updated yearly.
Through their national organizations, FEDIAF also col- Statutory Statement
laborates with local and national authorities to make pet own- GENERAL
ers more aware of their responsibilities toward their pets and The mandatory and optional declarations are encapsulated in
society. a space provided for that purpose and called “The Statutory
 Pet Food Labels 205

Statement” (United Kingdom) or “Cadre Réservé” (France)

Table 9-10. Common ingredient categories found on European
(Art. 5 of 90/44/EEC). In addition to being visible, legible and pet food labels.
indelible, the statutory statement must be separate from all
other information on the label (Table 9-9). Cereals
All types of cereals, regardless of their presentation, or ingredi-
Some of this information may be outside the statutory ents made from the starchy endosperm
statement, but the statutory statement must indicate where to Derivatives of vegetable origin
find the information. Such information as the “best before” Derivatives resulting from the treatment of vegetable products in
particular cereals, vegetables, legumes and oilseeds
date, net weight and the name and address of the company Egg and egg derivatives
responsible for the product are often found elsewhere on the All egg products, fresh or preserved by appropriate treatment,
label. and derivatives from the processing thereof
Fish and fish derivatives
A pet food label must indicate whether the food is a complete Fish or parts of fish, fresh or preserved by appropriate treatment,
or a complementary pet food (in other words, whether the food and derivatives from the processing thereof
can satisfy all nutritional demands without an additional ration Meat and animal derivatives
All fleshy parts of slaughtered warm-blooded land animals, fresh
[complete] or whether it must be fed with another product or preserved by appropriate treatment, and all products and
[complementary]). For complementary foods, the other food or derivatives of the processing of the carcass
supplement should be stated (Burger, 1993). The description Milk and milk derivatives
All milk products, fresh or preserved by appropriate treatment,
“complete” or “complementary” must be considered in relation and derivatives from the processing thereof
to the intended purpose of the food or to the particular lifestage Minerals
for which it is defined (e.g., adult, growth or all lifestages). All inorganic substances suitable for animal feed
Oils and fats
The species or category of animals must be stated with the All animal and vegetable oils and fats
indication complete or complementary (e.g., Brand X is a com- Various sugars
plete food for adult dogs). This statement of intent is often All types of sugars
Vegetable protein extracts
communicated on the principal display panel, but is repeated in All products of vegetable origin in which the proteins have been
the statutory statement. concentrated by an adequate process to contain at least 50%
crude protein, as related to the dry matter, and which may be
restructured or textured
INGREDIENT LIST Vegetables
In Europe, ingredients are declared by the individual name or All types of vegetables and legumes, fresh or preserved by
grouped under various categories (Table 9-4). These categories appropriate treatment
Yeasts
are designed to provide consumers with some indication of the All yeasts, the cells of which have been killed and dried
source of raw materials used, while allowing the manufacturer
some flexibility in the selection of the ingredients within a spe-
cific category (Burger, 1993). These categories are well defined
and names and descriptions are officially published (Table 9- ADDITIVES
10). Ingredients should be listed in descending order by weight Five types of substances are commonly declared as additives:
of each individual ingredient or category. 1) vitamins, 2) copper, 3) preservatives, 4) antioxidants and 5)
Vitamins are considered additives and are not listed under coloring agents (Table 9-5).
ingredients. Water does not have to be declared as an ingredi- Vitamins A, D and E must be declared when added by the
ent even if added during processing. manufacturer. The added amount should be declared although
some countries ask the manufacturer to declare the total
TYPICAL ANALYSIS amount of the vitamins found in the food. Vitamins are
Contrary to pet food labels in the United States, where declared in IU or in milligrams per kilogram (mg/kg) of food.
minimum and maximum guarantees are stated, the EU regu- Pet foods are regulated by the same legislation that regulates
lations dictate that the typical analysis must be declared for: livestock feed. Although clear exceptions are made for compan-
1) crude protein, 2) crude fat, 3) crude fiber and 4) ash (Table ion animal foods, situations arise in which an unusual nutrient
9-5). Moisture must be declared if it exceeds 14%. Typical must be declared. This is the case for copper because sheep are
analysis (percentage) is the average of the nutrient level calcu- much more sensitive to copper toxicity. If a copper salt is added
lated from several samples and should correspond with the to a pet food, the name of the salt and the total copper content
target level of each nutrient for which precise limits of varia- must be declared.
tion are defined. If a container has a net weight of up to 10 kg, the manufac-
The typical analysis gives the percentages found in the actu- turer can use the following statements: “Contains European
al food. Declaration of nutrients such as calcium, phosphorus, Economic Community (EEC) permitted antioxidant(s),” “con-
sodium, potassium and magnesium is optional. Energy decla- tains EEC permitted preservative(s)” or “contains EEC permit-
ration is forbidden in the EU except for some veterinary dietet- ted colorant(s).” However, if a container has a net weight of
ic pet foods. Other nutrients must be declared if a manufactur- more than 10 kg, the name of the additive must be stated in the
er wants to draw attention to them by saying a food is “high in” following way: “With antioxidant X,” “with preservative Y,” or
or “low in” a particular nutrient. “preserved with Y” and “with colorant Z,” or “colored with Z.”
206 Small Animal Clinical Nutrition

or above the declared net weight statement to ensure that the

Table 9-11. Indications permitted for dietetic pet foods in Europe. consumer receives the full amount purchased. The net weight
Support of renal function in case of chronic renal insufficiency declaration is often mentioned on the front of the label but
Dissolution of struvite uroliths some countries require that the statutory statement declare
Reduction of struvite urolith recurrence where the net weight can be found.
Reduction of urate urolith formation
Reduction of oxalate urolith formation
Reduction of cystine urolith formation OTHER DECLARATIONS
Reduction of ingredient and nutrient intolerances Regulations now incorporate the batch number into the
Reduction of acute intestinal absorptive disorders
Compensation for maldigestion (including exocrine pancreatic obligatory declarations for pet foods as well as the plant-specif-
insufficiency) ic registration number. The name and address of the company
Support of heart function in case of chronic cardiac insufficiency responsible for the product must also appear.
Regulation of glucose supply (diabetes mellitus)
Support of liver function in case of chronic liver insufficiency
Regulation of lipid metabolism in case of hyperlipidemia Dietetic Pet Foods in Europe
Reduction of copper in the liver In July 1995, labeling of dietetic pet foods for dogs and cats
Support of skin function in case of dermatosis and excessive
loss of hair became strictly regulated. Definitions and scope of the legisla-
Reduction of excessive body weight tion are published in Council Directive 93/74/EC, whereas
Nutritional restoration, convalescence Commission Directives (i.e., 94/39/EC and 95/9/EC) give the
applications (Council Directive 93/74/EC; Commission
Directive 93/39/EC; Commission Directive 95/9/EC).
Consequently, a number of statements have appeared on the
Table 9-12. Required information on labels of dietetic pet foods labels of dietetic pet foods. The Commission Directives publish
in Europe.
lists (Table 9-11) with the permitted indications for dietetic
Particular nutritional purpose (Table 9-11) foods (“Particular Nutritional Purposes”), the characteristics of
Essential nutritional characteristics the corresponding foods and specific label declarations (Table
Species or category of animals
Labeling declarations 9-12). The objective of the legislation is to prevent unsubstan-
Recommended length of time for use tiated and misleading claims on pet food labels.
Other provisions The term “dietetic pet food,” and its official translations, is the
only term to be used to indicate that a product falls under this leg-
islation.The new label declarations apply without prejudice to the
Only those additives are declared that have been added during Council Directive on the circulation of compound feeding stuffs
production of the food. Additives (e.g., preservatives or antiox- and other provisions regulating nonveterinary medical pet foods.
idants) added during rendering to preserve raw materials (e.g., The legislation considers most indications for nutritional
meat or fish meals) do not have to be declared on the label. management as “temporary situations” making it mandatory to
Maximum permitted levels of additives are strictly regulated. publish a defined length of use on the labels. This period of time
Additives are only permitted after European authorities accept has been determined by the commission and its experts, and
a dossier that documents efficacy and safety. does not always reflect the manufacturer’s recommendations.
Energy declaration is not permitted on pet food labels other
BEST BEFORE DATE than dietetic foods marketed for obesity and convalescence.
The Best Before Date is listed as a day, month and year. The The energy density is a calculated value expressed in megajoules
date itself can be found outside of the statutory statement in a per kilogram (MJ/kg) of product.
place in which it may be more convenient for printing on the New nutritional purposes may be accepted when new prod-
container (e.g., the can lid or top of the bag). In this case the ucts are marketed and the manufacturer has introduced a
statement “Best before...” must appear within the statutory dossier showing sufficient data to support the claims.
statement with instructions of where to find the date.

FEEDING INSTRUCTIONS REFERENCES

Feeding instructions are compulsory on European pet food
labels but are not as strictly regulated as in the United States. The References for Chapter 9 can be found at
The manufacturer will usually list the weight of the food to feed www.markmorris.org.
per body weight of the animal.

NET WEIGHT
The “net weight” declaration is regulated by packaged goods
regulations. The “e” often seen after the net weight is not spe-
cific for pet foods, but indicates that the net weight is an aver-
age. Strict rules regulate the limits of variation permitted under