AAFCO’s Mid-Year Meeting: Only three days to go!

The opening session of the AAFCO meeting is scheduled for 8 AM Pacific Time on Thursday, August 10. While AAFCO is an independent, non-profit organization, its influence on pet food regulation is profound. Its membership comprises representatives from State Departments of Agriculture and the U.S. Food and Drug Administration (FDA). AAFCO is responsible for developing and publishing the legal definitions of all pet food and animal feed ingredients. Furthermore, it drafts "model bills" which are frequently adopted by individual states as their governing laws for pet food and animal feed. This unique structure positions AAFCO as a critical, albeit often behind-the-scenes, architect of the regulatory framework for pet food in the United States.

Public engagement is a recognized component of AAFCO’s process, with two public meetings held annually—one in January and another in August. These forums allow for "stakeholder" participation, including advisors to various committees and opportunities for public comment. Stakeholders encompass a diverse group, including pet food manufacturers, ingredient suppliers, and consumer representatives, all of whom contribute to the dialogue. For those unable to attend in person, AAFCO provides avenues for remote participation, offering online streaming via WebEx and dedicated conference call lines for key sessions. This commitment to accessibility ensures broader transparency in discussions that directly impact pet owners and their animals.

The Regulatory Landscape of Pet Food in the United States

The pet food industry in the United States is a robust and growing sector, valued at approximately $30 billion annually in 2017, with projections for continued expansion. This economic significance underscores the necessity of clear and consistent regulatory standards. Unlike human food, which is primarily regulated by the FDA, pet food regulation is a complex interplay between federal oversight (FDA), state enforcement, and AAFCO’s model standards. The FDA’s Center for Veterinary Medicine (CVM) is responsible for ensuring that pet foods are safe, properly manufactured, and accurately labeled. However, the day-to-day enforcement of these regulations largely falls to state feed control officials, many of whom are active members of AAFCO.

AAFCO’s model bills and ingredient definitions serve as the de facto national standard, harmonizing regulations across states and providing a predictable framework for manufacturers. Without AAFCO, the industry would face a fragmented patchwork of 50 different state laws, making compliance and interstate commerce incredibly challenging. This cooperative approach, while efficient, also places significant power in AAFCO’s hands, making its meetings crucial for any developments in pet food policy.

Key Deliberations: Ingredient Definitions and Pet Food Labeling

While AAFCO conducts numerous meetings throughout the year, many of which are private webinars for members and stakeholder representatives, the public meetings in January and August are particularly significant. These are the forums where the outcomes of ongoing working groups and committee discussions are brought forward for broader review and potential adoption. The upcoming Bellevue meeting is expected to unveil information that has been under deliberation in various working groups, including the Pet Food Label Modernization initiative, since the last public meeting in January.

Among the various sessions scheduled, two committees stand out for their direct relevance to pet food consumers: the Ingredient Definitions Committee and the Pet Food Committee. Both are scheduled to meet on Friday, August 11, and are anticipated to host discussions with far-reaching implications.

The Ingredient Definitions Committee: Scrutinizing "High Profile Ingredients"

The Ingredient Definitions Committee meeting is scheduled for Friday, August 11, from 10:00 AM to 11:30 AM Pacific Time. This committee is responsible for the bedrock of pet food transparency: defining what goes into pet food. Its agenda for this session includes an item listed as "5) Discussions: a) Status on high profile ingredients." This particular point is generating considerable interest among consumer advocates.

The term "high profile ingredients" could refer to a variety of components that have either been subject to recent scrutiny, are new to the market, or require re-evaluation based on evolving scientific understanding or consumer demand. Historically, discussions around ingredient definitions have touched upon the source, processing methods, and nomenclature of everything from protein meals (e.g., "chicken meal" vs. "chicken by-product meal") to novel ingredients like insect proteins or plant-based alternatives. Given the increasing consumer awareness regarding ingredient sourcing and quality, any changes or clarifications to these definitions could significantly impact how pet food manufacturers formulate and label their products. For instance, tightening definitions could lead to greater clarity for consumers about the actual content and quality of ingredients, potentially reducing ambiguity surrounding terms like "natural" or "human-grade." Conversely, looser definitions could allow for a broader range of materials to be used under a single label term, which might concern some consumer groups.

To facilitate remote participation, the Ingredient Definitions Committee meeting will be accessible via WebEx (registration required at http://fass.webex.com) and a conference call line (US TOLL 1-650-479-3207, Access code: 660 195 549#). The full agenda for this session is available on the AAFCO website.

The Pet Food Committee: Driving Label Modernization and "Feed/Food" Disclosure

Later on Friday, August 11, from 3:00 PM to 5:00 PM Pacific Time, the Pet Food Committee will convene. This session is poised to be particularly "interesting" for consumers, as it is expected to address critical aspects of pet food labeling, notably the ongoing Pet Food Label Modernization working group and a specific proposal for "feed/food labeling disclosure."

The Pet Food Label Modernization initiative is a comprehensive effort to update and improve pet food labeling standards. Current labeling regulations, some of which date back decades, are often criticized for being confusing, misleading, or failing to provide consumers with adequate information to make informed decisions. The working group, which includes consumer representatives like Susan Thixton (originator of the guest post) and Mollie Morrissette, has been engaged in numerous webinar meetings since the January public session. The goal of this initiative is to draft a future model bill that will mandate clearer, more transparent, and more informative pet food labels.

A central point of discussion within this modernization effort, and a specific focus for the upcoming Pet Food Committee meeting, is the proposal for a "feed/food labeling disclosure." This initiative seeks to mandate that pet food labels clearly distinguish between ingredients that are "food grade" (fit for human consumption) and those that are "feed grade" (intended solely for animal consumption). This distinction is critical for many consumers who prioritize the quality and safety of ingredients in their pets’ diets, often seeking products made with components that meet human consumption standards. The absence of such a disclosure can lead to consumer confusion and a lack of transparency regarding the actual quality and sourcing of raw materials.

The FDA’s role in this proposal is significant. During a meeting in June, the FDA reportedly expressed full support for this feed/food labeling requirement, indicating its intention to publicly announce this support at the AAFCO meeting and formally request that the Pet Food Label Modernization working group incorporate this disclosure into its duties. The hope among consumer advocates is that this public endorsement from the FDA will lend substantial weight to the proposal, moving it closer to becoming a mandatory label requirement in future model legislation.

In a show of public demand, consumer advocates are also scheduled to present signatures from a petition supporting this feed/food labeling requirement to the Pet Food Committee. The petition, which urged consumers to add their names by a deadline of Tuesday, August 8, 2017, serves as a tangible demonstration of widespread consumer interest in greater transparency regarding pet food ingredients. The full request that the FDA asked consumer advocates to submit on the feed/food labeling requirement can be viewed on regulations.gov (document D=FDA-2016-P-3578-0004).

Like the Ingredient Definitions Committee, the Pet Food Committee meeting will be accessible remotely via WebEx (registration required at http://fass.webex.com) and a conference call line (US TOLL 1-650-479-3207, Access code: 666 808 790 #). The agenda for this crucial session is also available on the AAFCO website.

Broader Impact and Implications

The outcomes of these discussions in Bellevue carry significant implications for various stakeholders within the pet food ecosystem.

For Consumers: If the "feed/food" labeling disclosure is adopted, pet owners will gain unprecedented clarity regarding the quality and origin of ingredients in their chosen pet foods. This enhanced transparency could empower consumers to make more informed purchasing decisions that align with their values concerning pet nutrition and safety. It could also alleviate concerns about the use of lower-quality, feed-grade materials without explicit disclosure. The modernization of labels in general aims to reduce confusion and make nutritional information more accessible and understandable, fostering greater trust between pet food brands and their customers.

For the Pet Food Industry: While implementing new labeling requirements, such as the feed/food disclosure, may present initial challenges and costs for manufacturers (e.g., re-evaluating sourcing, updating packaging), it could also serve as an opportunity to build greater consumer trust and differentiate products based on ingredient quality. Companies that already use human-grade ingredients could prominently highlight this, potentially gaining a competitive edge. Conversely, companies relying heavily on feed-grade ingredients would need to clearly disclose this, which might necessitate strategic adjustments in marketing or product formulation. The overall trend towards transparency driven by AAFCO and the FDA suggests a future where ingredient integrity is a key differentiator in the marketplace.

For Regulatory Bodies: The AAFCO meetings reinforce the collaborative nature of pet food regulation. The FDA’s public support for specific consumer-driven initiatives demonstrates a responsiveness to public concerns and a commitment to advancing pet food safety and labeling standards. AAFCO’s role in developing model legislation ensures that these advancements can be efficiently translated into enforceable state laws, creating a more uniform and robust regulatory environment across the nation. This ongoing dialogue and adaptation are essential for keeping pace with industry innovations and evolving consumer expectations.

The AAFCO Annual Meeting in Bellevue, Washington, represents a critical juncture in the ongoing evolution of pet food regulation. With key discussions on ingredient definitions and the potential for groundbreaking changes in pet food labeling, particularly the "feed/food" disclosure, the outcomes of these sessions will undoubtedly shape the future of pet food transparency and consumer confidence for years to come. For those unable to participate directly, a comprehensive report of the meeting’s proceedings and decisions is expected to be made public shortly after its conclusion.