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

Understanding AAFCO’s Pivotal Role in Pet Food Regulation

AAFCO, an independent, non-profit organization, plays a uniquely influential role in the United States’ animal feed and pet food landscape. Unlike federal agencies that enforce laws, AAFCO develops model legislation, regulations, and ingredient definitions that are widely adopted by individual U.S. states. Its membership comprises representatives from state departments of agriculture and the U.S. Food and Drug Administration (FDA). This structure means that while AAFCO’s directives are not federal law, they effectively become the legal backbone for pet food manufacturing and labeling across most states. The organization’s power stems from its authority to define virtually every ingredient used in animal feed and pet food, as well as to craft the "model bills" that states often transpose directly into their own statutes.

The regulatory architecture for pet food in the U.S. is a shared responsibility between federal agencies, primarily the FDA, and state feed control officials. The FDA, operating under the Federal Food, Drug, and Cosmetic Act (FFDCA), sets national standards for the safety and efficacy of animal feeds. However, it relies heavily on AAFCO’s guidelines for specific ingredient definitions and labeling requirements. State regulatory agencies then enforce these AAFCO-derived standards within their respective jurisdictions. This collaborative, yet sometimes intricate, system underscores why AAFCO meetings are indispensable for understanding the current and future state of pet food regulation.

Meeting Structure and Public Engagement

AAFCO convenes public meetings twice annually, typically in January and August, alongside numerous interim committee meetings conducted via webinars throughout the year. These public sessions, such as the one in Bellevue, are significant because they are the primary venues where the outcomes of those private committee discussions are unveiled and debated openly. Stakeholder participation is a hallmark of AAFCO’s process, allowing input from diverse groups including pet food manufacturers, ingredient suppliers, and consumer advocacy representatives. This participatory model is intended to foster a balanced approach to regulation, incorporating industry perspectives, scientific insights, and consumer concerns.

For those unable to attend in person, AAFCO facilitates public access through online webcasts and conference call lines. The August 2017 meeting in Bellevue, for instance, offered consumers the opportunity to listen in, ensuring a degree of transparency in the proceedings. This commitment to public access, while sometimes criticized for its limitations given the technical nature of the discussions, is crucial for fostering an informed public and allowing consumer advocates to monitor developments.

Key Sessions for Consumers: Ingredient Definitions and Pet Food Committee

The August 2017 meeting agenda highlighted two committees of paramount interest to pet food consumers: the Ingredient Definitions Committee and the Pet Food Committee. Both sessions were scheduled for Friday, August 11, and promised discussions with significant implications for product transparency and safety.

The Ingredient Definitions Committee: Unpacking "High Profile Ingredients"

The Ingredient Definitions Committee meeting, slated for Friday, August 11, from 10:00 to 11:30 AM Pacific Time, was expected to delve into several critical areas. One agenda item, "5) Discussions: a) Status on high profile ingredients," particularly piqued the interest of consumer advocates. The term "high profile ingredients" often refers to components that have either generated considerable debate regarding their source, processing, or nutritional value, or those that represent emerging trends in pet food formulation.

Historically, discussions around "high profile ingredients" have encompassed a wide range of topics. These could include the regulatory status of novel protein sources (e.g., insect proteins, cultured meat), alternative carbohydrates, or the precise definition and acceptable uses of rendered materials and by-products. For instance, the exact definitions of terms like "meat meal," "poultry by-product meal," or specific vegetable proteins directly impact how manufacturers formulate products and how consumers interpret labels. A change in an ingredient definition can lead to significant shifts in manufacturing practices, supply chains, and ultimately, the ingredients found in pet food. Consumer groups often push for greater specificity and transparency in these definitions to ensure that labels accurately reflect what is contained within the product. The outcome of such discussions can influence everything from allergen labeling to the perceived quality of a pet food product.

Access to the Ingredient Definitions Committee meeting was provided via WebEx registration (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 was made available online (aafco.org/Portals/0/SiteContent/Meetings/Annual/2017/Committee-Agendas/Ingredient_Definitions_Agenda_Annual_2017.pdf).

The Pet Food Committee: The Push for "Feed" or "Food" Disclosure

Later on Friday, August 11, from 3:00 to 5:00 PM Pacific Time, the Pet Food Committee meeting was anticipated to be another focal point for consumer interests. A central item on this committee’s agenda was the FDA’s expected announcement regarding a "feed/food labeling disclosure" requirement. This initiative aimed to integrate a clear distinction on pet food labels between products considered "feed" and those qualifying as "food," potentially influencing how consumers perceive the quality and safety standards of their pets’ diets.

Background on the "Feed" vs. "Food" Distinction

The distinction between "feed" and "food" is critical within regulatory frameworks. "Food" typically refers to items suitable for human consumption, adhering to stringent human food safety standards, including sourcing, handling, and processing. "Feed," on the other hand, encompasses ingredients and products intended for animal consumption, which may not meet human-grade standards. For pet food, many ingredients are sourced and processed as "feed-grade," meaning they are not necessarily unfit for consumption but do not undergo the same rigorous oversight as human food.

Consumer advocates, including Susan Thixton of TruthAboutPetFood.com and Mollie Morrissette, have long championed a clear "feed" or "food" disclosure on pet food labels. Their argument centers on the premise that pet owners deserve to know whether the ingredients in their pets’ food meet human-grade standards. This transparency is seen as vital for informed purchasing decisions, especially for consumers who prioritize ingredients that mirror the quality they would expect in their own food. The absence of such a disclosure can lead to consumer confusion and misperceptions about product quality and safety.

The proposed "feed/food labeling disclosure" was intended to be added to the duties of the Pet Food Label Modernization working group, of which both Thixton and Morrissette were members. The goal was for this group to draft a future model bill incorporating this critical label requirement. The FDA had expressed full support for this label requirement during a meeting with consumer advocates in June 2017, generating optimism that the agency would publicly affirm this stance at the AAFCO meeting.

To bolster their case, consumer advocates were also presenting consumer signatures to a petition supporting this disclosure. This petition, accessible via ThePetitionSite.com (thepetitionsite.com/924/546/122/tell-aafco-consumers-support-food-or-feed-disclosure/), aimed to demonstrate widespread public demand for greater transparency. The deadline for signing the petition was Tuesday, August 8, 2017, just ahead of the AAFCO meeting, underscoring the urgency and strategic timing of the advocacy efforts. The full request submitted to the FDA by consumer advocates on this labeling requirement was available for public review (regulations.gov/document?D=FDA-2016-P-3578-0004).

The Pet Food Committee meeting, like the Ingredient Definitions Committee, was accessible via WebEx (fass.webex.com) and a conference call line (US TOLL 1-650-479-3207, Access code: 666 808 790 #). The agenda for this session was also publicly available (aafco.org/Portals/0/SiteContent/Meetings/Annual/2017/Committee-Agendas/Pet_Food_Agenda_Annual_2017.pdf).

The Broader Impact and Implications of Label Modernization

The discussions at the August 2017 AAFCO meeting, particularly those concerning pet food label modernization, carried significant implications for the entire pet food ecosystem. The global pet food market, valued at approximately $80 billion in 2017 and growing steadily, is driven by increasingly discerning consumers who view their pets as family members. This trend has fueled a demand for higher quality, more transparent, and often "human-grade" pet food options.

For Consumers: A clear "feed" or "food" disclosure would empower pet owners with unprecedented transparency, allowing them to make more informed choices aligned with their values and their pets’ dietary needs. It could alleviate confusion surrounding ingredient sourcing and processing standards, potentially leading to increased trust in pet food manufacturers who embrace higher quality standards. This transparency could also foster a more competitive market, as brands differentiate themselves based on ingredient quality and sourcing.

For Pet Food Manufacturers: The implementation of new labeling requirements, while potentially challenging in the short term, could ultimately benefit manufacturers. Brands that already use human-grade ingredients could leverage the "food" designation as a clear marketing advantage, validating their premium pricing. Conversely, manufacturers relying on feed-grade ingredients would need to clearly label their products as such, potentially necessitating adjustments in their marketing strategies or even ingredient sourcing to meet evolving consumer expectations. The Pet Food Label Modernization working group’s mandate to write the future label requirement law (model bill) signifies a long-term commitment to reshaping how pet food products are presented to the public.

For the Regulatory Landscape: The FDA’s vocal support for the "feed/food labeling disclosure" underscores a growing recognition within federal agencies of the need for enhanced transparency in the pet food sector. This aligns with broader trends in food safety and consumer protection. AAFCO’s role in translating these aspirations into practical, enforceable model regulations is crucial for ensuring uniform application across states and for providing a clear framework for industry compliance.

The Ongoing Pursuit of Transparency and Safety

The August 2017 AAFCO meeting represented a crucial juncture in the ongoing dialogue surrounding pet food quality and regulation. The efforts of consumer advocates like Susan Thixton and Mollie Morrissette, combined with the willingness of the FDA to support initiatives like the "feed/food labeling disclosure," highlight a collective movement towards greater transparency and accountability within the industry. While the outcomes of such meetings often unfold over time, influencing future legislation and industry practices, their immediate impact lies in setting the agenda for reform and empowering stakeholders with the knowledge to advocate for change. The promise of a full report following the meeting ensured that even those unable to participate directly would be informed of its conclusions, fostering continued engagement and advocacy in the critical domain of pet food safety.