The Industry "Enigma": PhD Required ...
Labels, and any claims made on them, are regulated both on a federal and a state level in the United States. In Europe, The European Pet Food Industry Federation (F.E.D.I.A.F) is responsible for these guidelines. In South Africa, this responsibility is carried by the National Department of Agriculture (DOA). In the United States, the federal regulations are published in the Code of Federal Regulations (CFR), Title 21CFR [ref].
Every label is required by law to have eight pieces of information based on the US legislation. Three things must be on the front of the package in plain view. In South Africa, the labelling requirements are covered under the Pet Food Advertising Regulations (ASASA) , and in essence, a summary of the US regulations. All pet-food products must be registered in terms of the Fertilizers, Farm Feeds, Agricultural Remedies and Stock Remedies Act 36 of 1947 ("the Act") in South Africa . The National Department of Agriculture decided to adopt the Association of American Feed Control (AAFCO) guidelines in Act 36 of 1947 (as amended), so we will continue to use the US guidelines and regulations as guidelines (US Food and Drug Administration (DFA) Pet Food Labels ).
- Brand and Product Name: The name of the food will actually indicate the percentage of protein in the food. More information below;
- Species: The species the food is formulated for;
- Quantity: The weight of food in the bag, can, roll, container, etc;
The other five items may be included on the front label or elsewhere on the package, such as on a back or side label, called the “information panel”.
- Guaranteed Analysis: Typically, the minimum percentages of crude protein and crude fat, and the maximum percentages of crude fibre and moisture (crude refers to testing not the food);
- Ingredient Statement: All ingredients are listed in order of predominance by weight, including their inherent water content;
- Nutritional Adequacy Statement: A substantiated claim of the food’s nutritional adequacy (e.g., complete and balanced) as well as which life stage(s) it is for (e.g., for growth, for maintenance, for all…);
- Feeding Directions: Recommended quantity based on weight and / or age of pet;
- Contact Information: Name and address of manufacturer or distributor;
Quite a bit of information for you to assimilate, as it turns out. The name of a pet food indicates the percentage of protein it has in it. For example, if a pet food name includes:
- The Name of the Protein: It must contain at least 95% of the said ingredient;
- Dinner, Entrée, Platter, etc.: It must contain at least 25% of the said protein;
- A modifier such as “with” chicken: It must contain at least 3% of the said protein;
- The word “flavour”: There are no requirements on the amount of protein it contains;
Commercial diets and treats are legally required to include proper listing of all the ingredients in the product in order from most to least, based on weight.
“Ingredients must be listed in order of predominance by weight, on an ‘as formulated’ basis”, according to the Association of American Feed Control (AAFCO). The ingredient that makes up the highest percentage of the total weight as it goes into the product is listed first. Each ingredient must be listed by its appropriate name.
There are hundreds of meaningless marketing terms on dog food labels and we’ve listed a few here. These words are just words, they have no legal definition (which is why you’ll see a lot of them) and there are no legal requirements for including them on packaging. When you see them, take the info with a grain of salt.
- Natural: Arsenic is also natural. So is water, chicken, and the highest grade of protein. The U.S. FDA states, “The term ‘natural’ is often used on pet food labels, although that term does not have an official definition.” While the FDA does not have an official meaning, AAFCO does. It states, “For the most part, ‘natural’ can be construed as equivalent to a lack of artificial flavours, artificial colours, or artificial preservatives in the product.” Under the ASASA guidelines (South Africa), natural is defined as: "a feed or ingredient derived solely from plant, animal or mined sources, either in its unprocessed state or having been subject to physical processing, heat processing, rendering, purification, extraction, hydrolysis, enzymolysis, or fermentation, but not having been produced by or subject to a chemical synthetic process and not containing any additives or processing aids that are chemically synthetic except in amounts as might occur unavoidably in good manufacturing practices;"
- Holistic: The actual meaning of holistic is “characterized by comprehension of the parts of something as intimately interconnected and explicable only by reference to the whole”. It means nothing in terms of the ingredients, nutrition or quality of the food. No definition under South African legislation.
- Premium: FDA labelling guidelines state that, “Products labelled as premium or gourmet are not required to contain any different or higher quality ingredients, nor are they held up to any higher nutritional standards than are any other complete and balanced products.” No equivalent definition under South African legislation.
Although AAFCO’s labelling requirements appear modest, the complexities of the rules, such as the different “percent” rules, often result in confusion over the product’s ingredients. Consider the “95 percent” rule and the “3 percent” rule. The “95 percent” rule applies to products that primarily consist of meat, poultry or fish. The rule requires that if an ingredient is to be used in the name of the product, such as “Beef for Dogs” then the named ingredient must constitute at least 95% of the product. Seems simple enough. Compare the “3 percent” rule; originally the 3 percent rule applied only to ingredients highlighted on the food container, but not included in the name of the product. Under the “3 percent” rule if the manufacturer wished to include a side statement of “with cheese” then at least 3% of the product must contain cheese. However, recent amendments to AAFCO regulations now permit manufacturers to use “with” as part of the product name. The result? It is now perfectly legal for a manufacturer to name a product “Cat Food with Tuna” even if the product only contains 3% tuna. Even more confounding, this product sits on the grocery shelf next to a product named “Tuna Cat Food” which consists of 95% tuna.
After navigating the 95% rule and the 3% rules, pet parents and guardians then faces the perplexing 25% rule, or the “dinner” rule. A manufacturer wishing to include an ingredient name in its product name (i.e. “Chicken Formula Cat Food”) must comply with the 25% rule, which requires that the ingredient constitute at least 25% of the product (excluding water for processing) and that the label include a qualifying descriptive term such as “dinner” or “formula”. The purpose of the descriptive term is to imply to the pet parent or guardian that the product contains other ingredients. Confusion arises due to the fact that the “named” ingredient on the label can constitute as little as one quarter (1/3) of the ingredients. Moreover, such a rule permitting the product name to include something other than the primary ingredient results in a confusing ingredient list. It is perfectly plausible that a pet parent or guardian will find that “Beef Dinner for Dogs” lists beef as the third or fourth ingredient on the list, after corn, grain, and rice. The results are even more perplexing when one considers the fact that “Chicken Formula Cat Food” could contain salmon or beef or liver as its primary ingredient. Since many pet parents or guardians do not take the time to understand pet food labels, this 25 percent rule can have damaging results if a pet has an allergy to any of these ingredients. For example, the owner of a cat with a lamb allergy could feasibly purchase Chicken Formula under the logical assumption that the product contained only chicken. But under AAFCO’s rules, it is permissible for a product labelled "Chicken Formula" to contain 25% chicken, and 50% lamb or beef or fish. You can read the AAFCO requirements here [ref].
In terms of South African legislation [ref], this means that:
9. Claims as to the content of particular ingredients shall be subject to the following rules, which are based on finished products, and for which credible rehydration or dehydration factors respectively shall be used when applying them to products containing a combination of dry and wet ingredients-
- "with X flavour" shall mean either that there are traces of the flavour substance, essence or extract present in the product, or that there is up to or including 4% of X itself in the product;
- "with X" shall mean that there is at least 4% of X present;
- "high in X", "rich in X", or "with extra X" shall mean that there is at least 14% of X present;
- "X dinner", "X recipe" or "X menu" shall mean that there is at least 26% of X present;
- "all X" shall mean that at least 65% of X is present.
- When the ingredient or material is described as a form following the name of the material, the inclusion level must be at least 26%, e.g. beef cubes, then the beef inclusion must be at least 26%.
- When the form of the ingredient or material precedes the name of the material, the inclusion level must be at least 65%, eg Cubes Beef, then the beef inclusion must be at least 65%.
However, we tend to follow the US regulations in South Africa instead. The infographic designed by Sniff Design Studio for PupCulture Magazine below summarize above neatly.
Credit & Source (http://sniffdesign.com/how-to-read-a-dog-food-label-infographic/)
Past the product name, pet parents and guardians must then decipher the nutritional adequacy statements found on labels indicating for which life stages the product is suitable. Examples include “for maintenance”, “for growth”, and “for all life stages”. While the “for maintenance” and “for growth” claims must meet strict nutritional AAFCO standards, the labels claiming that a product is intended for “senior” animals or specific breeds of dogs have no such requirements. The result is that a pet parent or guardian buying a dog food “for seniors” could be buying something that is either exactly the same formula as the “for maintenance” product at a higher price, or even worse, something that is of a lesser quality and actually accelerates the onset of related maladies such as arthritis and hip dysplasia.
Now, let’s apply what we have learned. Below is one of the commercial brands available in South Africa, focused specifically at addressing the “grain-free” requirements of the market. Please note that we are using this as part of the educational element of this site, and not intended as “vendor bashing”.
Ingredients: (1) Chicken, (2) Brown Rice, Whole Grain Oats, Whole Grain Barley, Brewers Rice, (3) Chicken Fat, (4) Chicken Meal, (2) Pea Protein Concentrate, Dried Beet Pulp, (5) Flaxseed, (6) Chicken Liver Flavour, (7) Lactic Acid, Vegetable & fruit blend (Green Peas, Apples, Cranberries, Carrots, Broccoli), (8) Potassium Chloride, Iodized Salt, Choline Chloride, Vitamins (Vitamin E Supplement, L-Ascorbyl-2-Polyphosphate (source of vitamin C), Niacin Supplement, Thiamine Mononitrate, Vitamin A Supplement, Calcium Pantothenate, Biotin, Vitamin B12 Supplement, Pyridoxine Hydrochloride, Riboflavin Supplement, Folic Acid, Vitamin D3 Supplement), Minerals (Ferrous Sulfate, Zinc Oxide, Copper Sulfate, Manganous Oxide, Calcium Iodate, Sodium Selenite), Taurine, Mixed Tocopherols for freshness, Phosphoric Acid, Beta-Carotene, Natural Flavours.
Since ingredients on dog food labels are listed by pre-cooked weight, ingredient splitting allows the companies to list the meat higher up and most of the grains lower in the list than is, making the food look like it’s higher in meat than it is.
So if we “un-split” the above, it would essentially read: (1) Cereals & Grains (Brown Rice, Whole Grain Oats, Whole Grain Barley, Brewers Rice, Pea Protein Concentrate, Dried Beet Pulp), (2) Chicken, Chicken Fat, Chicken Meal, (3) Vitamins & Minerals, (4) Chemical additives.
Ingredient splitting might be one of the pet food industry’s most controversial practices. Pet food companies deny any intentional wrongdoing. They claim they’re only reporting a product’s contents — and simply following government guidelines. Consumer advocates obviously have a disparate opinion - they insist ingredient splitting is nothing less than a deliberate attempt to mislead consumers — a common trick used by less ethical dog food companies to make an ingredients list look more attractive to buyers than it really is. As Susan Thixon (founder of The Truth About Dog Food website [ref] and Author at Dogs Naturally Magazine [ref]) puts it: “The ingredients are listed by the actual ingredient name – so officially they aren’t doing anything wrong (such as ground yellow corn is a different ingredient / has a different definition than corn gluten meal). But for consumers, they don’t realize that an estimated half of this food is grains.”
Essentially, ingredient splitting is the deceptive practice of subdividing a more abundant — yet inferior quality — ingredient into smaller portions. This dubious tactic can be used to artificially raise a meat item to a higher position on an ingredients list — and lower an inferior one. Say you have a dog food in which oats (or rice) is the dominant ingredient. Since cereals are less nutritious to a dog than meat, it’s considered a lower quality item. Remember, pet food manufacturers are required to arrange each item on every ingredient list in order of its precooking weight.
Let’s take a look at the “Before Splitting” side of the table below (using example content percentages to illustrate the point around splitting).
|Before Splitting||After Splitting|
|5||Ingredient B||?||5||Brewers Rice||10%|
|6||Ingredient C||?||6||Ingredient A||?|
|7||Ingredient D||?||7||Ingredient B||?|
|8||Ingredient E||?||8||Ingredient C||?|
Notice how cereals (oats), with its 30% pre-cooked weight, gets a first place position. Second-ranked rice makes up the next 20%, thus leaving chicken meal (Chicken, Chicken Fat, Chicken Meal) (a quality item) to occupy the list’s #3 spot. Common fillers found in pet food include corn bran, rice bran, oat hulls, cereal by-products, feathers, soybean hulls, cottonseed hulls, peanut hulls, rice hulls, wheat mill run, citrus pulp, modified corn starch, weeds, and straw.
Of course, dog food companies want their products to “look” like they’re meat-based, we just need to remind ourselves about the picture above. So, they’re well aware an ingredients list like this isn’t likely to impress a label-reading shopper.
Now, what would happen to that same list if you divide a few of the more abundant ingredients into smaller portions? Please look at the right side of the table labelled “After Splitting”.
Instead of using 30% cereals, a pet food designer could simply split the grains or cereals into Brown Rice, Whole Grain Oats, Whole Grain Barley — at just 12% each. And replace a large portion of the original rice with other rice ingredients, for example, Brewers Rice. That would move the cereals and rice components further down the list. The net result is that even though the amount of chicken (meal) remains unchanged, it’s now magically the first-ranked ingredient.
Let’s review the ingredients in more depth (and don’t forget the statement on “NO artificial colours, flavours or preservatives”):
- Chicken – most expensive part of the meal, but in most cases, only a tiny amount of this component actually makes it into the meal. Check out this video by Rodney Habib [ref].
- Brown Rice - Brown rice is a little higher in protein and a little lower in fat when compared to white rice. Added to boost fibre, also used as filler;
- Whole Grain Oats - Oats, in particular, are a good choice of grain for pets, according to Dr. Richard Pitcairn, DVM, PhD [ref], also used as filler;
- Whole Grain Barley - one of the more acceptable cereal grains that is used in dog food, also used as filler;
- Brewers Rice - Brewers' rice [ref] and second heads are one of the many by-products that rice milling creates. Second heads are milled rice kernels that are one half to three quarters of the original kernel. Used as filler.
- Chicken Fat - Chicken fat [ref] is obtained (usually as a by-product) from chicken rendering and processing. Typically added to improve palatability;
- Chicken Meal - Chicken meal [ref], according to the Association of American Feed Control Officials (AAFCO), is the dry rendered product from a combination of clean chicken flesh and skin with or without accompanying bone, derived from whole carcasses of chicken, exclusive of feathers, heads, feet and entrails.
- Pea Protein Concentrate - Pea protein concentrates are made by separating the protein fraction of pea seeds from the fibre and starch fractions. Several processes exist to do this, yielding products containing from 50 % to 90 % protein. Used to boost protein content of recipe;
- Dried Beet Pulp - Beet pulp [ref] is a by-product from the processing of sugar beet which is used as fodder for horses and other livestock. Beet pulp is the fibrous material left over after the sugar is extracted from sugar beets. Added to boost fibre and as filler;
- Flaxseed – Omega additives, best processed in whole format;
- Chicken Liver Flavour – typically derived from fermented organs in stock format;
- Lactic Acid [ref];
- Vegetable & fruit blend (Green Peas, Apples, Cranberries, Carrots, Broccoli);
- Potassium Chloride [ref]
- Iodized Salt [ref]
- Choline Chloride [ref]
- Vitamins (Vitamin E Supplement, L-Ascorbyl-2-Polyphosphate (source of vitamin C), Niacin Supplement [ref], Thiamine Mononitrate [ref], Vitamin A Supplement, Calcium Pantothenate [ref], Biotin [ref], Vitamin B12 Supplement, Pyridoxine Hydrochloride [ref], Riboflavin Supplement [ref], Folic Acid, Vitamin D3 Supplement)
- Minerals (Ferrous Sulfate, Zinc Oxide, Copper Sulfate, Manganous Oxide, Calcium Iodate, Sodium Selenite)
- Taurine [ref];
- Mixed Tocopherols [ref] for freshness (Vitamin E-based preservative);
- Phosphoric Acid [ref];
- Beta-Carotene (synthesized) [ref];
- Natural Flavours;
Right, so that takes us to natural and artificial flavours, which are terms the FDA does define and regulate. First, it helps to understand what the FDA defines as a "flavour". According to section 101.22 [ref] of the Code of Federal Regulations Title 21 (21CFR) , an annually updated codification of the FDA's rules, a flavour is any ingredient "whose significant function in food is flavouring rather than nutritional". So while beef itself has lots of flavour, its nutritional contribution to food is significant enough that it wouldn't qualify as a flavouring. But an extract of beef that's added in minute quantities for flavour alone, and with little or no nutritional value, would qualify as a flavouring.
As for natural versus artificial, the FDA says that a natural flavour is one that's derived from a "spice, fruit or fruit juice, vegetable or vegetable juice, edible yeast, herb, bark, bud, root, leaf or similar plant material, meat, seafood, poultry, eggs, dairy products, or fermentation products thereof". Basically, a natural flavour is one that's derived from a plant or animal. An artificial flavour, on the other hand, does not come from a plant or animal source, and instead is generated from scratch.
The question is then: is natural better than artificial? On the surface, a food flavouring that comes from a plant or animal might seem to be more desirable than an artificial one. But believing so requires making assumptions that don't always hold up under scrutiny.
The first problem is that not everything that comes from a natural source is guaranteed to be good. Cyanide, for instance, can be extracted from bitter almonds, but we wouldn't recommend eating it. Of course, no one is allowed to use cyanide as a food additive, but the basic idea still holds that extracts from plant or animal sources shouldn't automatically be considered to be safer or more desirable.
Artificial flavours, meanwhile, aren't intrinsically bad. On a scientific level, an artificially-made flavour compound is absolutely indistinguishable from the same compound derived from a natural source. As Gertrude Stein [ref] might have said, "Vanilla is vanilla is vanilla".
But there are other reasons why we shouldn't put too much stock in "natural" flavours. For a really fun example, let's look at castoreum [ref], a secretion that comes from the two castor sacs located under a beaver's tail, right next to a pair of anal glands. It's classified as a natural food additive - because it comes from an animal source, after all - but, as you've probably guessed, it isn't valued for the beaver-butt flavour it adds to foods. Nope, castoreum tastes and smells like vanilla, which makes it an option for baked goods, frozen dairy treats, and puddings. Yum! Just like mom used to make!
Granted, castoreum is a very rare food additive, but it's still a pretty good example - whether a flavouring's source is natural or artificial ultimately doesn't shed much light on what it is or whether it's something you want in your food.
Additional Articles and Videos
Good reference articles and further reading available at:
- Dogs Naturally Magazine - Looking For A High Protein Dog Food? These 5 Label Rules Will Help (Dogs Naturally Magazine)
- Pet food labels - what you don't see is important! Requires Adobe (Natural Pet Products)
- Think you know how to read a pet food label? Video post by our favourite Pet Nutrition Blogger, Rodney Habib (Facebook)
- Reading Pet Food Labels by Dr Judy Morgan (YouTube)