AAFCO Meeting begins Thursday August 10, 2017

The Association of American Feed Control Officials (AAFCO) is set to convene its annual summer meeting in Bellevue, Washington, beginning Thursday, August 10, 2017. This critical gathering, which extends through Friday, August 11, serves as a pivotal forum for shaping the regulatory landscape of pet food and animal feed across the United States. Pet owners and industry stakeholders alike are keenly observing the proceedings, particularly discussions surrounding ingredient definitions and a significant initiative to modernize pet food labeling, including a proposed "feed/food labeling disclosure."

For those unable to attend in person, AAFCO has made provisions for public access, allowing interested parties to listen to key sessions online via WebEx or through a dedicated conference call line. This accessibility underscores AAFCO’s commitment, albeit with certain limitations, to transparency in its decision-making processes, which directly impact the quality, safety, and transparency of products fed to millions of companion animals nationwide.

Understanding AAFCO: The Unseen Architect of Pet Food Regulation

AAFCO, an independent, non-profit organization, plays an indispensable yet often overlooked role in the pet food industry. Unlike a federal agency with direct enforcement powers, AAFCO operates as a voluntary membership association composed of regulatory officials from state departments of agriculture and the U.S. Food and Drug Administration (FDA). Its primary function is to establish and maintain uniform standards for the regulation of animal feeds, including pet foods. This is achieved through the development of "model bills," which are often adopted verbatim into state laws, and the creation of legal definitions for thousands of animal feed ingredients.

The organization’s influence stems from a unique regulatory framework. While the FDA has ultimate authority over the safety of pet food, it largely defers to AAFCO for the specifics of labeling, ingredient definitions, and nutritional standards. This cooperative arrangement means that AAFCO’s guidelines effectively become the de facto national standard, guiding manufacturers on everything from protein content claims to the precise terminology used for ingredients like "chicken meal" or "meat by-products."

Historically, AAFCO emerged in the early 20th century to address inconsistencies in feed regulation across states, a problem that became more pronounced with the growth of industrialized agriculture and the commercial pet food market. Its evolution reflects a continuous effort to balance industry innovation with consumer protection and animal welfare, navigating complex scientific, economic, and ethical considerations. Without AAFCO, the pet food market would likely face a fragmented patchwork of state-specific regulations, making interstate commerce and consistent product quality a significant challenge for both producers and consumers.

The Significance of Bi-Annual Deliberations

AAFCO holds two major public meetings annually—one in January and one in August—supplemented by numerous webinar meetings throughout the year for its members and designated "stakeholder" representatives. These public gatherings are crucial junctures where proposed changes to model bills, new ingredient definitions, and updates to labeling requirements are discussed, debated, and ultimately voted upon.

The term "stakeholder" in AAFCO’s context is broad, encompassing representatives from pet food and animal feed manufacturers, ingredient suppliers, academic researchers, and, critically, consumer advocates. While much of the preliminary work occurs behind the scenes in committee webinars, the public meetings offer the only opportunities for direct public input through open microphone sessions and the formal presentation of committee findings.

These meetings are not merely bureaucratic exercises; they are the crucible where the future of pet food standards is forged. Decisions made here can dictate what ingredients are allowed, how they are described on labels, and what nutritional claims can be made, profoundly affecting everything from product development to consumer purchasing decisions. For instance, a new ingredient definition can open doors for novel pet food formulations, while a change in labeling requirements can force manufacturers to redesign packaging and update their supply chain disclosures.

Key Agenda Items: Spotlight on Consumer-Driven Transparency

Two sessions stand out for their direct relevance to pet food consumers: the Ingredient Definitions Committee meeting and the Pet Food Committee meeting, both scheduled for Friday, August 11.

Ingredient Definitions Committee (Friday, August 11, 10:00 – 11:30 AM Pacific Time)

This committee is responsible for evaluating, approving, and defining all ingredients used in animal feed and pet food. Its agenda often includes discussions on emerging ingredients, revisions to existing definitions, and addressing concerns related to ingredient quality or safety. One item of particular interest listed on the agenda for this session is "5) Discussions: a) Status on high profile ingredients."

While the specific "high profile ingredients" are not detailed in the public agenda, this segment is anticipated to cover materials that have garnered significant attention due to their novelty, perceived controversy, or potential impact on pet health. This could include discussions on:

• Novel Proteins: As pet owners increasingly seek alternative protein sources for pets with allergies or dietary sensitivities, new proteins (e.g., insect-based, cultured meat proteins) require formal definitions to be legally used in pet food.
• Plant-Based Ingredients: The rise of vegan and vegetarian pet food options necessitates clear definitions for a growing array of plant-derived ingredients.
• Rendered Products and By-Products: These ingredients, often misunderstood by consumers, are a staple in many conventional pet foods. Discussions might involve clarifying their definitions, ensuring proper sourcing, or addressing public concerns about their quality and origin. For instance, "meat meal" is a rendered product, and its quality can vary significantly based on the source material and processing. AAFCO’s definitions aim to standardize this, but consumer advocates often push for greater transparency regarding the specific animals and parts used.
• Synthetic Additives and Preservatives: As consumers increasingly scrutinize artificial ingredients, the committee might review the definitions and acceptable uses of certain synthetic compounds, balancing preservation needs with consumer preferences for "natural" alternatives.

The process of defining an ingredient is rigorous. It involves submitting scientific data, safety assessments, and clear descriptions of the ingredient’s composition and intended use. Once defined by AAFCO, an ingredient gains legal standing, allowing manufacturers to incorporate it into their formulations and list it accurately on product labels. The implications are far-reaching: a new definition can unlock new product categories, while a revised definition can impact existing supply chains or necessitate changes in labeling.

Pet Food Committee (Friday, August 11, 3:00 – 5:00 PM Pacific Time)

The Pet Food Committee is arguably the most directly impactful for consumers, as it focuses specifically on the labeling and marketing aspects of pet food. This session is expected to feature a pivotal announcement from the FDA concerning the "feed/food labeling disclosure." The FDA is anticipated to formally request that this critical disclosure be added to the duties of the Pet Food Label Modernization working group.

The "Feed/Food Labeling Disclosure" Initiative: A Quest for Clarity

At the heart of this discussion is a long-standing demand from consumer advocates for clearer differentiation between "feed-grade" and "human-grade" ingredients in pet food. The current regulatory framework often allows pet food ingredients, even those that would be deemed unfit for human consumption (e.g., rendered animals, diseased animal parts, or materials produced under less stringent conditions), to be broadly described on labels without explicit disclosure of their feed-grade status.

• Feed-Grade Ingredients: These are typically produced to standards suitable for animal consumption but may not meet the more rigorous processing, handling, and safety standards required for human food. They can include animal by-products, rendered materials (e.g., from condemned animals, dead stock, restaurant grease), and ingredients processed in facilities not approved for human food production. While often nutritionally sound, the lack of transparency about their origin and processing can be a major concern for pet owners.
• Human-Grade Ingredients: This term implies that the ingredients are fit for human consumption, produced in human food facilities, and handled according to human food safety regulations. Currently, using the term "human-grade" on a pet food label is tightly regulated and requires stringent verification.

The goal of the "feed/food labeling disclosure" is to mandate that pet food labels explicitly state whether the product contains ingredients that are "feed-grade" or "human-grade." This would provide consumers with unprecedented transparency, enabling them to make more informed choices based on their values regarding ingredient sourcing and quality.

Consumer advocates, spearheaded by figures like Susan Thixton of TruthAboutPetFood.com and Mollie Morrissette, have been instrumental in pushing this initiative forward. Both Thixton and Morrissette are members of the Pet Food Label Modernization working group, a body tasked with drafting a new "model bill" for future pet food labeling requirements. Their advocacy stems from a belief that pet owners deserve to know the true quality and origin of the ingredients in their pets’ food, rather than relying on ambiguous terms or marketing claims.

The petition, actively supported by consumers, garnered significant signatures and is set to be presented to the Pet Food Committee. This collective voice underscores the strong consumer demand for enhanced transparency. The FDA’s reported "full support" for this label requirement during a meeting in June is a crucial development, lending significant weight to the advocates’ position and increasing the likelihood of its adoption into future AAFCO model bills. Should the FDA publicly reiterate this support at the AAFCO meeting, it would mark a major step towards realizing this transparency objective.

The Journey Towards Label Modernization: A Broader Context

The push for feed/food labeling disclosure is part of a larger, ongoing effort by the Pet Food Label Modernization working group to overhaul pet food labeling standards. Current labeling regulations, many of which date back decades, are increasingly seen as insufficient in addressing the complexities of modern pet food formulations and the evolving demands of today’s discerning pet owners.

The working group has been actively engaged in numerous webinar meetings since the last public gathering in January, meticulously deliberating various aspects of label reform. These discussions encompass everything from clearer ingredient lists and more understandable nutritional information to improved guidance on marketing claims and allergen disclosures. The results of these extensive internal deliberations are expected to be made public during the current AAFCO meeting in Washington, providing a comprehensive update on the progress and potential direction of future pet food labels.

The overarching aim is to create a model bill that is more intuitive for consumers, more precise for manufacturers, and ultimately fosters greater trust in the pet food industry. This initiative reflects a broader trend across the food industry (human and animal) towards enhanced transparency, driven by consumer interest in traceability, ethical sourcing, and health-conscious choices.

Public Participation and the Power of Advocacy

AAFCO’s commitment to allowing public observation of its meetings, whether in person, via WebEx, or by conference call, represents a vital channel for public engagement. This accessibility enables consumer advocates, media, and concerned pet owners to monitor discussions, understand the challenges in regulatory development, and identify opportunities for input.

The active participation of consumer representatives like Susan Thixton within AAFCO’s working groups exemplifies the evolving dynamic between regulators, industry, and the public. Their presence ensures that the voice of the pet owner is heard directly in the policy-making process, advocating for stricter standards and greater transparency. The presentation of the consumer petition signatures for the feed/food labeling requirement is a tangible demonstration of how organized advocacy can influence regulatory bodies. Such collective action highlights the growing power of pet owners to shape the industry through their purchasing choices and their demands for accountability.

Broader Implications for the Pet Food Industry and Consumers

The potential adoption of a "feed/food labeling disclosure" and other label modernization efforts carries significant implications for all stakeholders:

• For Consumers: Increased transparency would empower pet owners to make more informed decisions aligning with their values regarding ingredient quality, sourcing ethics, and budget. It could lead to a better understanding of what goes into their pet’s food, fostering greater trust in brands that embrace clarity.
• For Pet Food Manufacturers: Companies might face pressure to upgrade their ingredient sourcing to "human-grade" or, at minimum, to clearly label their "feed-grade" products. This could lead to adjustments in supply chains, manufacturing processes, and marketing strategies. While some might view this as a burden, proactive companies could leverage increased transparency as a competitive advantage, building stronger brand loyalty with consumers seeking premium or ethically sourced options.
• For the Industry as a Whole: A more transparent labeling system could elevate overall industry standards, pushing all manufacturers towards greater accountability. It might also stimulate innovation in ingredient sourcing and processing, as companies strive to meet evolving consumer expectations.
• Economic Impact: Implementing new labeling requirements will incur costs for re-packaging, marketing, and potential supply chain adjustments. However, these costs could be offset by increased consumer confidence and market differentiation.

Ultimately, the discussions and decisions made at this AAFCO meeting could set a new precedent for transparency and quality in the pet food industry. The outcome of the "feed/food labeling disclosure" initiative, in particular, will be closely watched as a bellwether for how deeply consumer demands for clarity will penetrate the regulatory framework.

Looking Ahead

Following the conclusion of the AAFCO meeting, the various committees, including the Pet Food Label Modernization working group, will continue their work, incorporating feedback and directives from the Bellevue sessions. The process of developing and eventually implementing a new model bill for pet food labeling is complex and time-consuming, requiring further deliberation, public comment periods, and ultimately, adoption by individual states.

The August 2017 AAFCO meeting represents a critical waypoint in this ongoing journey towards a more transparent and accountable pet food industry. The earnest hope of consumer advocates is that the momentum generated by their efforts, combined with the expressed support from the FDA, will translate into meaningful regulatory changes that benefit pets and their owners for years to come. The dialogue between industry, regulators, and consumers remains dynamic and essential in shaping the future of pet nutrition and welfare.