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

The meeting’s formal proceedings are scheduled to commence with an opening session at 8 AM Pacific Time on Thursday, August 10, 2017. AAFCO, an independent organization comprising representatives from State Departments of Agriculture and the U.S. Food and Drug Administration (FDA), plays an indispensable role in shaping the legal framework for animal feed and pet food across the United States. Its primary functions include developing and owning the legal definitions for all animal feed ingredients, as well as crafting "model bills" that are frequently adopted into state law, thereby governing the production, labeling, and sale of pet food.

While AAFCO holds two public meetings annually—one in January and another in August—much of its work occurs throughout the year in more focused, private webinar sessions involving its members and designated stakeholder representatives. These stakeholders typically include pet food and animal feed manufacturers, ingredient suppliers, and, to a lesser extent, consumer representatives. The results of these intensive, often confidential, interim discussions are then presented and deliberated upon during the public meetings. For instance, the Pet Food Label Modernization working group has conducted numerous webinar meetings since the last public session in January, and the outcomes of these deliberations are slated for public disclosure at the Bellevue meeting. This structure, while allowing for detailed work, also means that critical information is often withheld from general consumer knowledge until these biannual public disclosures.

For the vast population of pet owners, two sessions stand out as particularly significant: the Ingredient Definitions Committee and the Pet Food Committee, both scheduled for Friday, August 11, 2017. These committees are at the forefront of discussions that directly impact the safety, nutritional integrity, and transparency of pet food products available on the market.

Understanding AAFCO’s Pivotal Role in Pet Food Regulation

To fully appreciate the significance of the Bellevue meeting, it is crucial to understand AAFCO’s unique position within the regulatory landscape. Unlike human food, which falls predominantly under direct federal oversight by the FDA and USDA, pet food regulation is a complex tapestry woven with federal, state, and AAFCO-derived standards. While the FDA has authority over the safety and labeling of animal feeds under the Federal Food, Drug, and Cosmetic (FD&C) Act, AAFCO provides the granular detail and practical guidance that states often integrate into their own statutes.

Established in 1909, AAFCO’s initial focus was primarily on livestock feed, ensuring fair commerce and protection for farmers. As pet ownership grew and commercial pet food became widespread in the mid-20th century, AAFCO’s scope naturally expanded to include companion animal nutrition. Its "model bills" cover aspects such as ingredient names, guaranteed analysis, nutritional adequacy statements, feeding instructions, and claims. When states adopt these model bills, they ensure a degree of uniformity across jurisdictions, though variations still exist. This system, while intended to streamline regulation, has also faced criticism for its perceived lack of direct consumer representation and its heavy reliance on industry input. The multi-billion dollar pet food industry, which generated over $44 billion in sales in the U.S. in 2021 according to the American Pet Products Association (APPA), has a significant financial stake in these regulatory discussions.

The Ingredient Definitions Committee: Unpacking "High Profile Ingredients"

The Ingredient Definitions Committee meeting is scheduled for Friday, August 11, 2017, from 10:00 to 11:30 AM Pacific Time. This session is where the very building blocks of pet food are discussed, debated, and legally defined. The committee’s agenda item "5) Discussions: a) Status on high profile ingredients" holds particular interest for consumer advocates. This cryptic phrasing often signals deliberations on ingredients that have either recently emerged in the market, are subject to new scientific findings, or have become points of contention regarding their sourcing, processing, or perceived quality.

The process of defining an ingredient is rigorous. It involves reviewing scientific data, proposed usage, and potential impacts on animal health and industry practices. Once an ingredient receives an official AAFCO definition, it can be legally used in pet food and must be identified on labels according to that definition. This process is vital for ensuring consumer trust and product integrity. Without clear, consistent definitions, manufacturers could potentially use various substances under ambiguous names, leading to confusion and potentially compromising pet health.

"High profile ingredients" could refer to a range of issues. For instance, discussions might involve novel protein sources, which are increasingly used in limited-ingredient or allergen-friendly diets. Alternatively, they could address the definitions and usage of rendered ingredients, animal by-products, or plant-based proteins, all of which have been subjects of debate regarding their quality and appropriateness for pet consumption. Historically, controversies have erupted over the inclusion of "4D" meats (dead, diseased, dying, or disabled animals) in pet food, highlighting the critical importance of robust ingredient definitions and enforcement. Any changes or clarifications to these definitions can have profound implications for ingredient suppliers, pet food manufacturers, and ultimately, the nutritional profiles and safety of pet food products. Pet owners concerned about the origins and quality of ingredients in their pets’ diets will be keen to learn what specific ingredients are under review and what changes might be proposed.

For those wishing to follow this crucial discussion, the meeting is accessible via WebEx, requiring pre-registration at fass.webex.com, or by calling into a conference line: US TOLL 1-650-479-3207, Access code: 660 195 549#. The full agenda for this session can be viewed by clicking here.

The Pet Food Committee: The Push for "Food" vs. "Feed" Disclosure

Later on Friday, August 11, 2017, from 3:00 to 5:00 PM Pacific Time, the Pet Food Committee meeting will convene, promising further "interesting" discussions for consumers. A central point of anticipated debate is the FDA’s expected announcement regarding "feed/food labeling disclosure." The FDA is poised to formally request that this critical disclosure be added to the duties of the Pet Food Label Modernization working group. This initiative aims to establish a future label requirement law (model bill) that clearly distinguishes between "food-grade" (human-edible) and "feed-grade" ingredients in pet food.

This distinction is profoundly important for consumers. The term "food" generally implies ingredients fit for human consumption, adhering to stricter processing, handling, and quality standards. "Feed," on the other hand, refers to ingredients specifically designated for animal consumption, which may have lower quality thresholds or include by-products not typically consumed by humans. Currently, pet food labels often do not explicitly differentiate between these two categories, leading to a significant lack of transparency for pet owners. Consumers are frequently left to infer ingredient quality based on marketing claims or brand reputation, rather than clear regulatory disclosure.

The push for "feed/food labeling disclosure" represents a significant consumer advocacy effort. Susan Thixton, a prominent Pet Food Safety Advocate and author, along with Mollie Morrissette, are active members of the Pet Food Label Modernization working group and have been instrumental in championing this cause. Their efforts include presenting consumer signatures from a petition supporting this specific labeling requirement to the committee. The petition, accessible at thepetitionsite.com/924/546/122/tell-aafco-consumers-support-%E2%80%98food%E2%80%99-or-%E2%80%98feed%E2%80%99-disclosure/, had a deadline of Tuesday, August 8, 2017, for new signatures, underscoring the urgency and broad consumer demand for this change. The collective voice of pet owners through such petitions demonstrates a clear desire for greater clarity and honesty on pet food labels.

The FDA’s full support for this label requirement, expressed during a meeting with consumer advocates in June, is a crucial development. The agency’s public affirmation of this support at the AAFCO meeting would lend substantial weight to the proposal, significantly increasing its chances of being adopted into AAFCO’s model bills and subsequently into state law. This alignment between consumer advocates and a federal regulatory body marks a potentially pivotal moment for pet food transparency.

The broader Pet Food Label Modernization initiative aims to update and clarify pet food labeling laws, which many argue are outdated and contribute to consumer confusion. Labels currently offer limited insight into the true quality or origin of ingredients, making it difficult for pet owners to make informed decisions about their pets’ nutrition. Should the "feed/food labeling disclosure" be adopted, it would represent a monumental step forward, potentially transforming how pet food manufacturers formulate and market their products. It could compel companies to either elevate their ingredient sourcing to human-edible standards for clearer labeling or explicitly disclose the feed-grade nature of their components, thereby fostering a more honest and competitive market based on transparent ingredient quality.

The full request submitted by consumer advocates to the FDA regarding this labeling requirement can be viewed on regulations.gov (document ID: FDA-2016-P-3578-0004). The agenda for the Pet Food Committee meeting is also available by clicking here.

Like the Ingredient Definitions Committee meeting, the Pet Food Committee session is accessible via WebEx (registration required at fass.webex.com) or by conference call: US TOLL 1-650-479-3207, Access code: 666 808 790#.

Broader Implications and the Path Forward

The discussions at the AAFCO meeting in Bellevue carry significant implications for the pet food industry, regulatory bodies, and millions of pet owners. The potential adoption of a "feed/food" disclosure requirement could initiate a paradigm shift, forcing greater accountability from manufacturers and empowering consumers with unprecedented transparency. This would allow pet owners to consciously choose products based on the explicit quality of their ingredients, rather than relying on ambiguous marketing language or brand trust alone.

Such a change could also spur innovation within the industry, as companies might strive to meet higher "food-grade" standards to appeal to a growing segment of informed consumers. Conversely, it might lead to a clearer segmentation of the market, with "feed-grade" products being explicitly differentiated, potentially impacting their pricing and market share. This increased clarity would ultimately benefit pet health by enabling more informed dietary choices tailored to individual needs and owner preferences regarding ingredient quality.

The journey towards enhanced transparency and stricter pet food regulation is an ongoing one, punctuated by these biannual AAFCO meetings. While the process can be slow and often complex, the persistent advocacy of individuals like Susan Thixton and organizations pushing for consumer rights continues to drive change. Their presence and the presentation of thousands of consumer signatures underscore the powerful, collective demand for a more ethical and transparent pet food industry.

For those unable to participate directly in the WebEx or conference calls, comprehensive reports and analyses of the meeting’s outcomes are anticipated to be provided in the days following its conclusion. The hope among consumer advocates is that these discussions will lead to tangible progress, fostering a future where pet food labels are not just compliant, but genuinely informative and reflective of the quality within. The stakes are high, and the outcomes of the Bellevue AAFCO meeting will undoubtedly resonate throughout the pet food community for years to come.