AAFCO Meeting begins Thursday August 10, 2017

The Association of American Feed Control Officials (AAFCO) is set to convene its annual meeting in Bellevue, Washington, starting Thursday, August 10, 2017, marking a pivotal moment for pet food regulation and consumer advocacy. This gathering brings together state and federal regulatory officials, alongside industry stakeholders and consumer representatives, to deliberate on critical issues impacting the safety, labeling, and nutritional integrity of pet food and animal feed across the United States. For pet owners invested in the quality and transparency of their companions’ diets, the proceedings, particularly those scheduled for Friday, August 11, promise significant developments, especially concerning ingredient definitions and the ongoing push for modernized pet food labeling.

Understanding AAFCO: The Bedrock of Pet Food Regulation

AAFCO, an independent corporation, serves a unique and often misunderstood role in the complex ecosystem of pet food regulation. Unlike a governmental agency, AAFCO operates as a voluntary membership association comprising representatives from state departments of agriculture and the U.S. Food and Drug Administration (FDA). Its primary function is to establish model legislation and regulations that individual states then adopt, either fully or in part, into their own feed laws. This cooperative framework aims to ensure uniformity in feed regulation across state lines, preventing a patchwork of disparate rules that could complicate interstate commerce and regulatory oversight.

Central to AAFCO’s mandate is the development and ownership of legal definitions for all animal feed and pet food ingredients. These definitions dictate how ingredients can be named, what their composition must be, and how they can be used in formulations. Furthermore, AAFCO crafts "model bills," which are comprehensive regulatory frameworks that, once adopted by states, become enforceable law. This includes standards for ingredient lists, guaranteed analysis, nutritional adequacy statements, and feeding instructions on pet food labels. Without AAFCO’s harmonizing efforts, the pet food industry, a multi-billion dollar sector, would face significant hurdles in manufacturing and distributing products nationwide, and consumers would struggle with inconsistent information. The organization’s biennial public meetings, held each January and August, serve as crucial forums for members, industry, and the public to review, debate, and amend these foundational standards.

The Call for Transparency: Public Access and Stakeholder Engagement

Recognizing the public interest in its decisions, AAFCO provides avenues for consumers to engage with its proceedings. The August 2017 meeting, like others, offers remote participation options, allowing interested individuals to listen online via WebEx or by calling into a conference line. This access is vital, as AAFCO’s decisions directly influence the products available on store shelves and the information consumers receive about them.

Beyond public listening, AAFCO actively incorporates "stakeholder" participation. These stakeholders typically include representatives from pet food and animal feed manufacturers, ingredient suppliers, and, importantly, consumer advocacy groups. These groups serve as advisors to various committees, contributing perspectives and data, and are also afforded opportunities to voice opinions during designated public comment periods at the two main annual meetings. However, a significant portion of AAFCO’s work, particularly detailed discussions and preparatory sessions for policy changes, occurs in numerous webinar meetings held throughout the year, accessible primarily to members and designated stakeholder representatives. The outcomes of these more private sessions are then presented and finalized at the public meetings, sometimes leading to calls for greater transparency regarding the interim discussions.

Key Sessions and Pivotal Debates: August 11, 2017

The August 2017 AAFCO meeting agenda highlights two sessions of particular significance for pet food consumers, both scheduled for Friday, August 11. These committees are often where the most impactful decisions concerning pet food composition and labeling are forged.

The Ingredient Definitions Committee (10:00 to 11:30 AM Pacific Time):
This committee holds considerable power, as it is responsible for establishing and refining the official definitions of every ingredient used in pet food. Its discussions are critical because ingredient definitions dictate quality standards, allowable processing methods, and how ingredients are declared on product labels. A key item on its agenda for this session, listed as "5) Discussions: a) Status on high profile ingredients," signals potential updates or re-evaluations of certain components commonly used in pet food. While the specific ingredients were not publicly disclosed in advance of the meeting, such discussions typically involve ingredients that have garnered consumer attention, undergone new scientific scrutiny, or are subject to evolving manufacturing practices. This could include novel proteins, specific by-products, or ingredients that have been linked to past recalls or health concerns. The committee’s work ensures that ingredients are consistently named and meet established compositional and safety criteria, thereby providing a baseline for product integrity. Any changes in ingredient definitions can have far-reaching implications for manufacturers, potentially requiring them to alter sourcing, processing, or labeling practices, and ultimately affecting the types of ingredients pet owners see on labels.

The Pet Food Committee (3:00 to 5:00 PM Pacific Time):
Following the Ingredient Definitions Committee, the Pet Food Committee is slated to address what many consumer advocates consider a paramount issue: pet food label modernization, with a specific focus on the "feed/food labeling disclosure." This session is particularly anticipated because the FDA is expected to publicly announce its support for incorporating this disclosure requirement into the duties of the Pet Food Label Modernization working group.

The Imperative for Label Modernization and the "Food or Feed" Disclosure:
The demand for modernized pet food labels stems from a growing consumer desire for greater transparency and clarity regarding the origin and quality of ingredients. Current labeling regulations, while providing a framework, often leave consumers confused or misinformed about what constitutes "human-grade" versus "feed-grade" ingredients. The "feed/food labeling disclosure" aims to address this ambiguity directly.

At its core, this proposed disclosure seeks to differentiate between ingredients that are deemed fit for human consumption (often referred to as "human-grade" or "edible") and those that are processed and handled under conditions suitable only for animal feed ("feed-grade"). The distinction is crucial because ingredients designated as "human-grade" must adhere to stringent federal regulations governing sanitation, processing, and handling, similar to those applied to food for human consumption. "Feed-grade" ingredients, while safe for animals, typically operate under less rigorous standards, often involving by-products or rendered materials not intended for the human food chain.

For consumer advocates like Susan Thixton of TruthAboutPetFood.com and Mollie Morrissette, who are active members of the Pet Food Label Modernization working group, securing this disclosure is a significant victory. It would empower pet owners with critical information to make more informed purchasing decisions, potentially influencing their perception of product quality and safety. The working group’s ultimate goal is to draft a model bill that would enshrine this "food or feed" disclosure into state law, thereby standardizing the requirement across the nation.

The expectation of FDA’s public endorsement at this meeting follows a June 2017 meeting where the agency reportedly expressed full support for this label requirement. Such an announcement from the FDA would lend substantial weight to the consumer advocates’ efforts, signaling a potential shift in regulatory priorities towards greater transparency. In a demonstration of grassroots support, consumer advocates are also scheduled to present signatures from a petition advocating for this specific feed/food labeling requirement to the committee. The petition, which had a signing deadline of Tuesday, August 8, 2017, underscores the widespread public demand for clearer, more honest pet food labels. The full request submitted by consumer advocates to the FDA regarding this labeling requirement details the rationale and proposed framework for such a disclosure, emphasizing the importance of distinguishing ingredient quality and handling standards.

The Broader Impact and Implications for the Pet Food Industry

The outcomes of the August 2017 AAFCO meeting, particularly concerning label modernization and the "food or feed" disclosure, hold profound implications for the entire pet food industry. Should the FDA’s support for the disclosure translate into a model bill and subsequent state adoptions, manufacturers would face new mandates regarding how they source, process, and label their products.

For Manufacturers: Implementing a "food or feed" disclosure would necessitate a thorough review of supply chains and manufacturing processes. Companies currently using feed-grade ingredients, but marketing their products with language that implies higher quality (e.g., "premium," "natural," without explicitly defining ingredient grade), would need to adjust their labeling and potentially their ingredient sourcing. This could lead to increased operational costs for those opting to transition to human-grade ingredients to meet consumer demand for transparency. Conversely, manufacturers already utilizing human-grade ingredients might gain a competitive advantage by clearly communicating this distinction on their labels. The overall effect could be a push towards higher quality ingredient sourcing and stricter manufacturing standards across the industry, driven by both regulatory pressure and consumer preference.

For Consumers: The primary benefit for pet owners would be enhanced clarity and the ability to make truly informed choices. Understanding whether ingredients meet human-grade standards would provide a new metric for evaluating product quality, potentially influencing purchasing decisions based on perceived safety, nutritional value, and ethical sourcing. This transparency could also foster greater trust between pet food brands and their customer base, as consumers would have a clearer understanding of what they are feeding their pets. It could also lead to a more educated consumer base, better equipped to navigate the often-complex world of pet food marketing claims.

The Ongoing Evolution of Pet Food Standards

The August 2017 AAFCO meeting is not an isolated event but a critical juncture in the ongoing evolution of pet food regulation. The drive for label modernization reflects a broader trend towards increased scrutiny of food production, both for humans and animals. As scientific understanding of pet nutrition advances and consumer expectations for transparency grow, regulatory bodies like AAFCO are continually challenged to adapt and update standards. The debates within committees, the input from diverse stakeholders, and the ultimate decisions made at these meetings shape the future landscape of pet food, influencing everything from ingredient sourcing and manufacturing practices to marketing claims and consumer trust.

The efforts of consumer advocates, coupled with the potential support from federal agencies like the FDA, highlight a collaborative push towards a more transparent and accountable pet food industry. While the process of enacting new regulations can be slow and incremental, each AAFCO meeting represents a step forward in ensuring that pet food labels accurately reflect the contents and quality of the products, allowing pet owners to make the best possible decisions for the health and well-being of their animal companions. The full report promised after the meeting will undoubtedly shed more light on the immediate outcomes and the long-term trajectory of these vital regulatory reforms.