Proposed Revision to PF7 & Feeding Protocols
(ATTACHMENT F)
Pet Food Committee Recommendation:
The PFC recommends that the following revisions be considered by the
MBRC for integration into the AAFCO Official Publication.
Background
Revising requirements to the Feeding Protocols to account for the
special nutritional requirements for growth of large size dogs. DRAFT
language.
Note: Revised for correct formatting, clarity and plain language,
and to include wording to be placed in the Protocols Section of
the OP.
Workgroup Recommendations:
Regulation PF7. Nutritional Adequacy
(a) The label of a pet food or specialty pet food which is intended for all life
stages and sizes of the pet or specialty pet may include an unqualified
claim, directly or indirectly, such as “complete and balanced,” “perfect,”
“scientific,” or “100% nutritious” if at least one of the following apply:
(1) The product meets the nutrient requirements for all life stages and
sizes established by an AAFCO-recognized nutrient profile; or
(2) The product meets the criteria for all life stages as substantiated by
completion of the appropriate AAFCO-recognized animal feeding
protocol(s);
A. Unqualified claims of nutritional adequacy that include large
size dogs can be substantiated by completing the appropriate
protocols using large size dogs; or
B. Can be substantiated by completing the appropriate protocols
using dogs less than 70 lbs. adult weight while containing no
more calcium and phosphorus than the maximum limits for
large size dogs listed in the AAFCO Dog Food Nutrient
Profiles; or
(3) The product is a member of a product family which is nutritionally
similar to a lead product which contains a combination of ingredients
that has been fed to a normal animal as the sole source of nourishment
in accordance with the testing procedures established by AAFCO for
all life stages, provided that:
A. The nutritional similarity of the family product can be
substantiated according to the Procedures for Establishing Pet
Food Product Families developed by AAFCO; and
B. The family product meets the criteria for all life stages; and
C. Under circumstances of reasonable doubt, the (State Control
Official) may require the manufacturer to perform additional testing
of the family product in order to substantiate the claim of
nutritional adequacy.
(b) The label of a pet food or specialty pet food which is intended for a
limited purpose (such as size of dog) or a specific life stage, but not for
all life stages and sizes, may include a qualified claim such as “complete
and balanced,” “perfect,” “scientific,” or “100% nutritious” when the
product and claim meet all of the following:
(1) The claim is qualified with a statement of the limited purpose or
specific life stage for which the product is intended or suitable, for
example, “complete and balanced for puppies (or kittens).” The
claim and the required qualification shall be juxtaposed on the
same label panel and in the same size, style and color print; and
(2) The product meets at least one of the following:
A. The nutrient requirements for the limited purpose or
specific life stage established by an AAFCO-recognized
nutrient profile; or
B. The criteria for a limited purpose or a specific life stage as
substantiated by completion of the appropriate AAFCO-
recognized animal feeding protocol(s);
i. Qualified claims of nutritional adequacy that include
large size dogs can be substantiated by completing the
appropriate protocols using large size dogs; or
ii. Can be substantiated by completing the appropriate
protocols using dogs less than 70 lbs. adult weight
while containing no more calcium and phosphorus
than the maximum limits for large size dogs listed in
the AAFCO Dog Food Nutrient Profiles; or
C. The requirements of a product family which is nutritionally
similar to a lead product which contains a combination of
ingredients which, when fed for such limited purpose, will
satisfy the nutrient requirements for such limited purpose and
has had its capabilities in this regard demonstrated by
adequate testing, and provided that:
i. The nutritional similarity of the family product can be
substantiated according to the Procedures for
Establishing Pet Food Product Families developed by
AAFCO; and
ii. The family product meets the criteria for such limited purpose;
and
iii. Under circumstances of reasonable doubt, the (State
Control Official) may require the manufacturer to
perform additional testing for the family product to
substantiate the claim of nutritional adequacy.
(c) Dog and cat food labels shall include a statement of nutritional
adequacy or purpose of the product except when the dog or cat
food is clearly and ….
Language for Insertion into the Feeding Protocols (in
red)
AAFCO Dog and Cat Food Nutrient Profiles—
Introduction
The Pet Food committee recommends that the revisions to the AAFCO Dog and
Cat Food Nutrient Profiles not be enforced until 12 months (1/1/2017) for new
products in development and 24 months (1/1/2018) for existing products after
publication of the revised AAFCO Dog and Cat Food Nutrient Profiles in the print
version of the AAFCO OP.
[…]
The established profiles are the “AAFCO Dog Food Nutrient Profiles” and
“AAFCO Cat Food Nutrient Profiles” as the terms are applied in AAFCO model pet
food regulations referring to nutritional adequacy. Under these model regulations, dog
and
cat foods substantiated for nutritional adequacy by reference to the AAFCO Dog
and Cat Food Nutrient Profiles for a designated life stage(s) must be formulated to
contain at least the minimum concentrations of nutrients specified in the Profiles,
and, for some
nutrients, not more than any maximum concentration listed for that specific nutrient in
the Profiles as shown in this section. Products with their nutritional adequacy
substantiated by AAFCO Feeding Protocols are not mandated to meet the minimum or
maximum concentrations listed in the Profiles, except for large-size dogs growth and
all life stage products substantiated by the protocols using non-large size dogs must
contain no more than the maximum large size breed calcium and phosphorus
concentrations listed in the profiles. Additionally, snacks, treats or products intended
for intermittent or supplemental feeding only are not mandated to meet the
concentrations in the Profiles unless their labeling references the Profiles.
[…]
MINIMUM FEEDING PROTOCOL
FOR PROVING AN UNQUALIFIED REPRESENTATION
OF NUTRITIONAL ADEQUACY
FOR A DOG OR CAT FOOD
The minimum testing necessary to prove an unqualified claim for
nutritional adequacy may be obtained by using the gestation/lactation
and the growth protocols.
[…]
Test puppies or kittens shall receive the test diet as their sole source of
nourishment, other than dam's or queen's milk, during lactation, weaning,
and growth.
Selection of puppies or kittens shall be on a statistically sound basis
from each of the litters qualifying for the gestation/lactation protocol
with equal sex distribution preferred.
Unqualified claims of nutritional adequacy for a product to be fed to
large size dogs can be substantiated by completing the gestation/lactation
and the growth protocols using large size dogs or can be substantiated by
completing the gestation/lactation and the growth protocols with dogs
less than 70 lbs. adult weight in which the product contains no more
calcium and phosphorus than the maximum limits for large size dogs
listed in the AAFCO Dog Food Nutrient Profiles.
[…]
MINIMUM FEEDING PROTOCOL FOR PROVING A GROWTH
CLAIM FOR A DOG FOOD
PUPPIES
A minimum of eight puppies from three different bitches shall be
required to start the test.
[…]
The test group shall have the same gender distribution as the
concurrent control group.
A growth claim of nutritional adequacy for a product that includes
large size dogs can be substantiated by completing the growth protocol
using large size dogs or can be substantiated by completing the growth
protocol using dogs less than 70 lbs. adult weight in which the product
contains no more calcium and phosphorus than the maximum limits for
large size dogs listed in the AAFCO Dog Food Nutrient Profiles.
[…]
