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Association for Truth in

This publication is provided by Associ- ation for Truth in , as education for pet food con- sumers.

WHAT YOU NEED TO KNOW

The information provided in this booklet is intended as education for pet food consumers. AssociationforTruthinPetFood.com

What to know before you shop for pet food.

food or food – but most do COMPLETE AND not abide by food laws; most pet BALANCED Unless the product is noted ‘for sup- ‘’ are not food. plemental feeding’, all types of com- Most pet foods are sold as ‘Complete and Balanced’ . The claim is mercial pet food are considered extremely misleading. ‘complete and balanced’. This state- ment means the pet food is required and are termed To be labeled as Complete and Bal- to provide your pet with various nutri- ‘food’, but most are not food as con- anced, one of two requirements must be met. 1. The pet food must meet the ents as outlined by the Association of sumers understand the term (food). AAFCO nutritional profiles (for or American Feed Control Officials (AAF- Through a series of confusing laws ); or 2. The pet food passed an CO) specific to species (cats or dogs). and conflicting FDA Policies, most pet AAFCO certified feeding trial. More information on Complete and foods are regulated as feed Most Complete and Balanced pet Balanced on the left of this page. (such as cattle feed, chicken feed). foods follow option one above. does not follow food safe- Only basic nutritional information is ty law; feed is allowed to include any- The AAFCO profiles include minimum requirements, with only a provided on the pet food label, stated thing from wholesome food few maximums, as needed by cats as ‘Crude’ (Crude , Crude ingredients to illegal material allowed and dogs. As example, for cat and and Crude Fiber). The term ‘crude’ de- by FDA to be disposed of in animal dog foods there is a minimum require- fines the basic method of testing used ment of fat, however there is no es- food/pet food. tablished maximum for fat. Pet foods (crude or basic testing) to determine with 5% fat and pet foods with 50% fat protein, fat, and fiber levels. One of the most dangerous, illegal are both considered ‘balanced’ nutri- feed/animal food ingredients - allowed tion. The same holds true for many other including and by FDA into pet foods - is material minerals. Again, the Complete and sourced from diseased or dead/non- Balanced claim is misleading to con- Pet food (in the U.S.) is primarily regu- slaughtered . Source: FDA sumers. lated by the Food and Drug Adminis- Compliance Policy 690.300, and FDA AAFCO certified feeding trails are tration (FDA); specifically the division Compliance Policy 675.400. most commonly performed on cats Center for Veterinary Medicine (CVM). and dogs in kennel laboratory set- Each State Department of Agriculture Pet foods that meet the requirements tings; not on in real life situations. In recent years, some pet food manu- has authority over pet food (state law) of food are classified as grade facturers are changing tradition per- but all states follow FDA’s authority. pet foods. Human grade pet foods are forming feeding trials on real pets in manufactured in a certified human homes. The laws that govern pet food are the food facility, include 100% human Federal Food, Drug, and Cosmetic food quality ingredients (USDA in- Act, and to a lesser extent state laws spected and approved human edible), written by the Association of Ameri- and include 100% human quality sup- can Feed Control Officials (AAFCO). plements. Human grade pet foods are However, many applicable laws are food, exactly how pet owners are fa- not enforced. miliar with the term food. ‘Human grade’ will be stated on the pet food One of the most important things for label if the product meets the legal consumers to know is that pet food requirements. regulated as food. It is called food Other than human grade pet foods, all AssociationforTruthinPetFood.com

What to know before you shop for pet food.

pet foods can include inferior/illegal QUESTIONS TO ASK ingredients; emphasis . PET FOOD Some, but not all, pet foods utilize For pet foods or treats to make the inferior/illegal ingredients. ‘Made in the USA’ claim, the require- Are meat, vegetable, grain, and fruit ingredients human edible? ment is the product is manufactured As all pet food labels are required by in the U.S., and all ingredients are Are supplements human grade or regulation to look similar, the chal- sourced from the U.S. However, this feed grade? lenge for pet food consumers is learn- requirement is not enforced; another What is the country of origin of all in- ing which pet foods include misleading marketing trick ignored by gredients, including all supplements? inferior/illegal ingredients. Questions regulatory authorities. found on the left side of this page will Who manufactures the pet food? help consumers determine the quality of the pet food (ingredients) they are purchasing. Always ask questions of Some pet food companies manufac- the manufacturer before you pur- ture their own brands, some do not. A chase. co-packer is the term used for a manu- facturer that makes pet food for anoth- The following list of pet food ingredi- er brand. Ask who manufactures the ents are allowed through legal defini- pet food, ask about the recall history tion to be sourced from diseased of the co-packer. animals or dead/non-slaughtered ani- mals (inferior sources):

Chicken by-products Meat meals are ingredients unique to Chicken by-product meal pet food/animal feed (not used in hu- Poultry by-products man food). The term ‘meal’ means the Poultry by-product meal ingredient has been cooked prior to Meat and meal the process of the pet food. Beef and bone meal Meat, and commonly bone and inter- Animal fat nal organs are ground fine and cooked Animal digest to become a powder-like substance Meat meal (the meat meal). Beef meal Lamb meal Some believe meat meals provide Venison meal more nutrition as the moisture is re- moved from the meat (meat contains If a pet food contains one of the above high levels of moisture). Others be- ingredients, ask the manufacturer for lieve the high level of processing de- a guarantee in writing to quality of in- creases the nutritional value (cooked gredients. Ask: Are meat ingredients once in the processing of the meat sourced from USDA inspected and meal, cooked twice in the processing approved human edible sources? of the pet food).

Meat meals are most commonly used AssociationforTruthinPetFood.com

What to know before you shop for pet food.

in kibble pet foods. and finally sprayed with flavoring (in most cases) to enhance the taste. PET FOOD NAMES Cooking times vary with each manu- facturer. Just as with pet food ingredients, the Regulatory authorities ignore labeling names of pet foods can be confusing. laws allowing pet foods to display im- The closest comparison of kibble pet Below are explanations to various regulations of pet food product ages of food (grilled steak, roasted food to human food – in manufactur- names. chicken) when nothing in the pet food ing process only - is a fortified break- looks similar to the images displayed. fast cereal (fortified meaning with Named Meat If a pet food name is (example) Beef Misleading images on pet food labels added vitamins and minerals; as ex- Dog Food or Cat Food, regula- are a direct violation of federal law ample Total cereal). Cereal is made tions require the pet food to contain a and many state laws, but currently no through a similar extrusion process. minimum of 70% of the named meat authority enforces those laws. Images (moisture removed). of food on pet food labels are in most Currently, there are no human grade If the pet food name includes two cases only marketing. Do not allow kibble pet foods. The manufacturing meats (example: Beef and Tuna Pet them to influence your purchase deci- process could become human grade, Food), the pet food is required to con- tain a minimum of 70% of the two sions. but thus far no manufacturer has cer- named meats (moisture removed). tified their facility.

Dinner, Entree, Formula Kibble pet foods, on average, contain If a pet food name includes the words Dinner, Entree, or Formula (example: Pet foods that include the word ‘Fla- high amounts of starchy carbohy- Beef Dinner for Dogs or Chicken En- vor’ in the name – such as T-bone drates. This is required due to the tree Cat Food) regulations require the Steak Flavor – are not required to in- manufacturing process; needed to pet food to contain a minimum of 10% of the named meat (excluding mois- clude the named meat. The only re- hold the kibble shape. ture). If the pet food name includes quirement is the pet food to be two meats (Chicken and Din- ‘flavored’ with the named meat; such It is best to store kibble in its original ner), the two meats combined are re- as T-bone steak flavor. (See more pet packaging, bag placed inside an air- quired to be a minimum of 10% of the food (excluding moisture). food name regulations left side of this tight container. Original packaging is page.) required if a pet becomes sick from With the food. If a pet food name includes the word With (example: XYZ Pet Food With Beef), regulations require the pet food Most kibble pet foods have a shelf life to contain a minimum of 3% of the between 6 months and 2 years (prod- named meat. Kibble pet foods are probably the uct is required to stay fresh and pro- most popular style of pet food, not be- vide required nutrition for the duration cause it is superior in nutrition; all of the shelf life). commercial pet foods are required to provide the same nutrition. Kibble pet foods are the most popular simply be- cause of convenience. Most kibble pet Canned pet food is similar to human foods are made via extrusion, a pro- canned food, again – only through the cess where ingredients are cooked manufacturing process. The pet food through pressure and steam. Kibble is is cooked in the can, not prior to can- cooked again in the drying process ning. Varieties of canned pet foods AssociationforTruthinPetFood.com

What to know before you shop for pet food.

include those in loaf style and those packaging. These products are most PET FOOD as a stew or with gravy. often cooked prior to packaging. INGREDIENT QUALITY Some canned pet foods include piec- Shelf life varies with style, but com- Pet food uses a different language es of actual meat; others contain monly these products have a shelf life than human food. As example, ‘chick- chunks of fabricated meat. Fabricated between 6 months and 1 year. en’ in human food means USDA hu- man edible chicken meat. In pet food meat is an extruded meat product ‘chicken’ can be USDA human edible made from meat slurry with added Some of these types of products are chicken meat, USDA condemned vegetable starches to help hold the human grade, others are not. The chicken meat, or chicken and (no meat). desired shape. There is no disclosure packaging will state ‘Human Grade’ if on the pet food label to use of fabricat- the pet food meets the legal require- To make matters a little more chal- ed meat. Consumers can learn some ments. lenging for consumers, pet food ingre- information from the ingredient listing dient definitions are not public information. The AAFCO organization to determine if the pet food contains holds control over all pet food ingredi- actual meat or fabricated meat. Look ent definitions, charging $100 for ac- for multiple gums (carrageenan, cas- Commercial raw pet food is relatively cess. For consumers to understand the ingredients in pet food, they must sia gum) and or multiple starches new to the market as compared to kib- pay the $100 fee or trust the manufac- (, flour, or vegetable ). ble and can, but actually this style of turer. pet food is the oldest form of cat and Cooking/canning times vary with each dog food. Long before commercial pet Consumers should not assume that pet food chicken, or any pet food in- manufacturer. food, both cats and dogs consumed gredient is similar to the same ingredi- raw prey – such as birds, mice and ent in human food. Ask the pet food Most canned pet foods have a shelf rabbits. manufacturer for a detailed explana- tion to what type of chicken (or any life between 2 and 5 years. ingredient) is used in the pet food. Is Raw pet food is highly scrutinized by the meat human edible meat? Currently there are no human grade FDA; the only style of pet food FDA canned pet foods. There are moist pet has issued a consumer warning foods that are human grade, sold fro- about. FDA's concern is the spread of zen in tubs. Because canned foods are ; “raw pet food is more likely so popular in human food, canned pet to be contaminated with disease-caus- food could easily become human ing bacteria, such as and grade if the manufacturer followed all food regulation (human grade ingredi- ents and supplements). But to our This FDA warning is incorrect and ex- knowledge there are no human grade tremely misleading. FDA pet food re- canned pet foods currently. call history details many more recalls for dangerous bacteria with kibble foods than raw (millions of pounds of kibble recalled as compared to only thousands of pounds of raw pet food While not as popular as canned pet recalled). food, another style of moist pet food is sold frozen or sold in shelf stable Shelf life varies between 6 months and 1 year frozen. AssociationforTruthinPetFood.com

What to know before you shop for pet food.

Some raw pet foods are human grade, however achieving the official human LAWS grade status is challenging for raw pet Should your pet become sick or die food. FDA and the AAFCO require hu- and you believe the illness or death is The Federal Food Drug and Cosmetic man grade pet foods to be manufac- linked to a pet food, the incident Act defines food as: tured in a human food facility, but should be reported to proper authori- “The term "food" means (1) articles both organizations neglect to recog- ties. Pet owners can report to FDA on- used for food or drink for man or other nize the Department of line or phone, for information Click animals, (2) chewing gum, and (3) Agriculture’s (USDA) role in human Here. Or report to state authorities. To articles used for components of any such article.” food. USDA oversees the production find your state’s representatives Click of meat. Some raw pet foods are man- Here. Your should report The Federal Food Drug and Cosmetic ufactured under constant inspection the food incident too. Act defines an adulterated (illegal) (same as human food) by USDA. Con- food as (in part): sumers can ask the manufacturer: return the food for a refund, “(3) if it consists in whole or in part of was the pet food made under constant packaging information will be needed any filthy, putrid, or decomposed sub- USDA inspection and are supple- for investigation by authorities. All vet- stance, or if it is otherwise unfit for food; or” ments human grade? If yes, the pet erinary records relating to your pet’s food can be considered human grade. illness should be provided to authori- “(5) if it is, in whole or in part, the ties; should the worst happen, a product of a diseased animal or of an necropsy will benefit investigators. animal which has died otherwise than by slaughter;” Both of these styles of pet food are a However, the FDA openly tells the pet method used to preserve the food by food industry law will not be enforced: removing the moisture. Both styles of “Pet food consisting of material from pet food require the consumer to add diseased animals or animals which moisture back to the food before feed- have died otherwise than by ing. slaughter…will be considered fit for animal consumption.” There are human grade options in this Do not assume your choice of pet category. food contains safe ingredients. Al- ways ask questions; Does this pet food abide by all food laws?

Treats for cats and dogs are intended as supplemental feeding, never as the sole source of food. The same lack of enforcement of law and inferior quali- ty of ingredients apply to treats. Ask the same questions to a treat manu- facturer you would a food manufactur- er. AssociationforTruthinPetFood.com

What to know before you shop for pet food.

http://www.fda.gov/ICECI/Compliance WHERE TO PURCHASE Manuals/CompliancePolicyGuidanceM YOUR PET FOOD Association for Truth in Pet Food (AT- anual/ucm074717.htm PF) is a consumer association; a pet Locally owned, independent pet food food consumer stakeholder group. Report a sick pet to FDA stores are often the only source to Founder Susan Thixton represents pet http://www.fda.gov/AnimalVeterinary/S purchase human grade pet foods. food consumer members at AAFCO afetyHealth/ReportaProblem/ucm1824 Many independent stores highly scru- 03.htm tinize the products they carry and pet food regulatory meetings and with most often are well informed about FDA. the brands they carry. Report a sick pet to State http://www.aafco.org/Regulatory One of the efforts ATPF has estab- lished is a voluntary pet food transpar- Association for Truth in Pet Food ency program titled Pledge to Quality http://associationfortruthinpetfood.com/ and Origin. To learn more and view Pledges received Click Here. Susan Thixton http://truthaboutpetfood.com/ ATPF members and consumer non- members also performed the largest consumer funded testing of pet food. To view those results Click Here.

Choosing a pet food is one of the most important decisions a consumer must make. Association for Truth in Pet Food provides this pet food education- al document to assist consumers in that decision. This pet food booklet is not all inclusive;

For print versions of this document, below are links provided within.

FDA Compliance Policies http://www.fda.gov/ICECI/Compliance Manuals/CompliancePolicyGuidanceM anual/ucm074710.htm