AAFCO Meeting Begins Thursday, August 10, 2017: A Critical Juncture for Pet Food Regulation and Consumer Advocacy

The Association of American Feed Control Officials (AAFCO) is set to commence its bi-annual meeting on Thursday, August 10, 2017, in Bellevue, Washington, marking a significant event for the pet food industry, regulatory bodies, and consumer advocacy groups. This gathering serves as a pivotal forum where crucial decisions regarding pet food ingredient definitions, labeling standards, and regulatory frameworks are deliberated, ultimately shaping the landscape of animal feed products across the United States. The proceedings, accessible to the public online or via conference call, highlight AAFCO’s unique role as a standard-setting body that bridges state regulatory agencies and federal oversight.

Understanding AAFCO’s Pivotal Role in Pet Food Regulation

AAFCO, an independent, non-profit organization, comprises representatives from state departments of agriculture and the U.S. Food and Drug Administration (FDA). Its primary function involves establishing model legislation, ingredient definitions, and labeling standards that are widely adopted by individual states, thereby forming the de facto regulatory backbone for pet food and animal feed. Unlike a federal agency with direct enforcement powers, AAFCO operates through consensus-building among its members, providing a harmonized approach to feed regulation that ensures consistency across state lines. This intricate structure means that while AAFCO doesn’t directly regulate, its guidelines carry substantial legal weight, often being incorporated verbatim into state laws. The organization’s influence extends to defining what constitutes an acceptable ingredient, how it should be named, and the nutritional requirements for various animal life stages, making its meetings central to industry practices and consumer protection.

The pet food market in the United States alone is a multi-billion dollar industry, projected to exceed $40 billion in annual sales by 2020, underscoring the economic significance of AAFCO’s decisions. With millions of households owning pets, the quality, safety, and transparency of pet food are paramount concerns for consumers. AAFCO’s twice-yearly public meetings, held in January and August, are complemented by numerous private webinar sessions throughout the year, allowing for continuous work on complex issues such as the ongoing Pet Food Label Modernization initiative. These public sessions, however, represent critical opportunities for transparency and limited external input, including participation from "stakeholders" such as manufacturers, ingredient suppliers, and consumer representatives.

Key Sessions and Agenda Highlights for the Bellevue Meeting

The 2017 August meeting in Bellevue is particularly anticipated due to several agenda items poised to significantly impact pet food consumers and manufacturers. The opening session is scheduled for 8:00 AM Pacific Time on Thursday, August 10. While various committees convene, two stand out for their direct relevance to pet food consumers: the Ingredient Definitions Committee and the Pet Food Committee, both slated for Friday, August 11.

The Ingredient Definitions Committee: Scrutiny of Pet Food Components

The Ingredient Definitions Committee meeting is scheduled for Friday, August 11, from 10:00 AM to 11:30 AM Pacific Time. This committee is tasked with reviewing, amending, and approving the official definitions of ingredients used in animal feed and pet food. These definitions are critical because they dictate what can legally be included in pet food products and how these components are labeled. A key item on its agenda, "5) Discussions: a) Status on high profile ingredients," has drawn particular attention. While specific ingredients are often not disclosed prior to the meeting, "high profile" could refer to ingredients facing scrutiny regarding their sourcing, processing, nutritional value, or perceived safety.

Historically, the definition and acceptance of ingredients like "meat by-products," "animal digest," or rendered products have been subjects of debate. Consumer advocates often push for more precise and transparent definitions, while manufacturers seek flexibility and cost-effectiveness. The committee’s deliberations could lead to new definitions, revisions of existing ones, or further studies on contentious ingredients. For instance, a decision to tighten the definition of a common ingredient could necessitate changes in sourcing and manufacturing processes for numerous pet food brands, impacting both supply chains and product costs. Conversely, the approval of novel ingredients, such as insect proteins or specific plant-based components, could open new avenues for product innovation and address evolving dietary trends or sustainability concerns within the pet food industry.

The public can access the Ingredient Definitions Committee meeting via WebEx (registration required at fass.webex.com) or by calling US TOLL 1-650-479-3207 with access code 660 195 549#. The full agenda for this session is available on the AAFCO website.

The Pet Food Committee: The "Food vs. Feed" Disclosure Debate Takes Center Stage

Later on Friday, August 11, from 3:00 PM to 5:00 PM Pacific Time, the Pet Food Committee will convene. This committee is often the arena for discussions around labeling requirements, marketing claims, and broader policy issues affecting pet food. A central and highly anticipated topic for this session is the FDA’s expected announcement regarding a "feed/food labeling disclosure." This initiative proposes that pet food labels explicitly state whether the product is considered "food" (implying human-grade ingredients and processing) or "feed" (indicating animal-grade ingredients and processes, which may include materials not suitable for human consumption).

Consumer advocates, including Susan Thixton of TruthAboutPetFood.com and Mollie Morrissette, have been instrumental in championing this disclosure. Their efforts stem from a long-standing concern that current labeling practices can mislead consumers about the actual quality and origin of ingredients in pet food. The distinction between "human edible" and "feed grade" ingredients is significant. Ingredients deemed "feed grade" can include by-products, rendered materials, or ingredients that, while safe for animals, do not meet the stringent standards for human consumption. This proposed disclosure aims to provide greater transparency, allowing consumers to make more informed purchasing decisions based on their understanding of ingredient quality and processing standards.

The Pet Food Label Modernization working group, of which both Thixton and Morrissette are members, is expected to be tasked with drafting a model bill for this future label requirement. The FDA’s stance on this issue is crucial. Advocates report that the FDA expressed full support for this labeling requirement during a meeting in June, and there is considerable hope that the agency will publicly reaffirm this support at the AAFCO meeting. To bolster their case, consumer advocates plan to present thousands of consumer signatures collected through a petition advocating for this "feed/food" labeling disclosure. The deadline for signing this petition was Tuesday, August 8, 2017, underscoring the urgency and broad consumer interest in this issue.

The consumer advocates’ request to the FDA for the feed/food labeling requirement, along with supporting documentation, is publicly available on regulations.gov (document ID: FDA-2016-P-3578-0004). The full agenda for the Pet Food Committee meeting is also accessible on the AAFCO website.

The Pet Food Committee meeting can be viewed via WebEx (registration required at fass.webex.com) or listened to via conference call at US TOLL 1-650-479-3207 with access code 666 808 790#.

Broader Implications and the Future of Pet Food Labeling

The outcomes of these discussions, particularly concerning the "feed/food" disclosure, carry profound implications for the entire pet food ecosystem. For consumers, a clear distinction on labels could demystify ingredient sourcing and processing, empowering them to choose products aligned with their quality expectations and ethical considerations. This could potentially lead to increased demand for products marketed as "human-grade," thereby influencing market trends and product development.

For the pet food industry, implementing a "feed/food" disclosure would necessitate significant changes in labeling practices and potentially in supply chain management. Manufacturers currently using "feed grade" ingredients would be required to clearly state this, which could affect their market positioning and consumer perception. Conversely, companies already using human-edible ingredients could leverage this disclosure as a competitive advantage. The industry as a whole would need to adapt to a new era of enhanced transparency, potentially driving innovation towards higher quality or more clearly differentiated product lines.

From a regulatory perspective, AAFCO’s adoption of such a model bill, followed by its implementation by individual states, would represent a substantial step towards modernizing pet food labeling. It would also highlight the FDA’s growing emphasis on consumer transparency within the animal feed sector. Enforcement mechanisms would need to be established to ensure compliance with the new labeling standards, posing new challenges for state feed control officials.

The discussions at AAFCO also reflect a broader societal trend towards greater scrutiny of food systems, whether for humans or animals. Consumers are increasingly demanding accountability, transparency, and ethical sourcing from manufacturers. The active participation of consumer advocates like Susan Thixton underscores the growing influence of grassroots movements in shaping regulatory policy, pushing for changes that prioritize pet health and consumer trust. Thixton, a long-time pet food safety advocate and author, represents a vocal segment of the public seeking more stringent standards and clearer communication from the industry. Her involvement, along with that of other consumer representatives in the Pet Food Label Modernization working group, signifies a critical step towards incorporating diverse perspectives into the regulatory process.

Challenges and the Path Forward

While the prospects for enhanced transparency are promising, challenges remain. The process of developing and implementing new model legislation within AAFCO is often complex and time-consuming, requiring extensive deliberation and consensus among diverse stakeholders, including industry representatives who may have differing commercial interests. Furthermore, even after AAFCO adopts a model bill, its actual implementation across all states can vary in timeline and interpretation.

The AAFCO meeting in Bellevue, Washington, therefore, is not merely a bureaucratic gathering but a crucial moment in the ongoing evolution of pet food regulation. The decisions made regarding ingredient definitions and, particularly, the "feed/food" disclosure, will reverberate throughout the industry and directly impact pet owners for years to come. The accessibility of these meetings via online platforms and conference calls underscores a commitment to public engagement, albeit with inherent limitations given the technical nature of many discussions.

As the meeting progresses, the pet food community, including manufacturers, veterinarians, retailers, and millions of pet owners, will be closely watching for outcomes that promise to redefine transparency and quality standards in the ever-expanding pet food market. A full report of the meeting’s proceedings and decisions will be provided shortly after its conclusion for those unable to attend or listen in, ensuring that the wider public remains informed about these critical developments. The efforts of advocates like Susan Thixton represent a sustained push for positive change, and the Bellevue meeting offers a significant opportunity to advance that mission.