The "100%" and "Complete" Fallacy ...
The Association of American Feed Control Officials (AAFCO) permits a pet food manufacturer to claim that its product is “100% complete” provided that the manufacturer has complied with AAFCO’s feeding trial protocols or nutrient profiles (you can read the AAFCO Methods for Substantiating Nutritional Adequacy of Dog and Cat Foods here [ref] (requires Adobe PDF Reader). The U.S. Food and Drug Administration notes on "Complete and Balanced" Pet Food can be found here [ref].
If you think about it, this is quite an incredible statement. Claiming that anything is 100% is like claiming perfection, total knowledge, and absolute truth. Has pet nutrition really advanced that far? Does a chemist make such a claim? A physicist? Doctor? Professor? Did Einstein, Bohr, Pasteur, Aristotle, Plato, or any of the greatest minds in human history make such claims? No. Has the science of pet nutrition advanced to the point where it can be claimed that everything is known about the physiology, digestion and biochemistry of animals, as well as knowing everything there is to know about food? Surely, a BIG No.
AAFCO’s feeding trials typically only need to last 26 weeks and are conducted, at a minimum, on a group of 8 animals. Yet, AAFCO holds this isolated and short-lived study sufficient proof that the tested product can sustain all similar-species for the duration of the animal’s life. In other words, a food tested on 8 poodles for 6 months is considered 100% complete for all dogs. According to AAFCO, this same dog food can sustain Beagles, Bull Mastiffs and Boxers for their entire lives. That’s quite a fluid dog food. As Dr. Wysong (22 Pet Food Fallacies) [ref] points out, this “food could cause disease and destroy long term health, yet not be harmful and be 100% complete” because it managed to sustain a dog for 26 weeks. Shouldn’t the sustainability goal of the pet food industry be much longer than 6 months? Shouldn’t the foods be tested on various breeds taking into consideration each breed’s varied nutritional requirements?
"Science does not have 100% knowledge of anything, much less nutrition. A 100% complete and balanced diet implies 100% complete knowledge – and since that is not true, the 100% complete and balanced manufactured diet is a myth."
~ Dr. Wysong
It is impossible for any pet food to be truly complete and balanced or 100% complete. To illustrate, consider the following example. For the sake of simplicity, assume an animal needs only four ingredients to have a “complete and balanced diet”. If half of ingredient 1 is eliminated, the diet is still technically complete but is no longer balanced. If the animal is no longer getting enough of ingredient 1 in its diet, the animal’s instinct is to eat more (of whatever food is available) to make up for the perceived deficiency. Thus, the probability of the imbalance of nutrients in pet foods can lead to obesity.
The proof that commercial pet food is not necessarily balanced is found on the packaging: consider the high level of carbohydrates and the “wild card” of the rendering process. Plus, each time U.S. regulatory agencies meet, they debate all over again how much of which nutrients will constitute 100% complete. If this is so, then how could the previous balance of nutrients have been 100% complete? The most honest solution would be to cease the “complete and balanced” claims and start to educate the pet parents and guardians about nutrition and their pets’ specific needs. But this would not sell pet food; the public at large is addicted to the convenience of commercial pet foods and judging by the reluctance to eliminate fast food from our own diet, our pets will likely fare far worse.
Today, one simple word can strike fear in the heart of the pet food manufacturer claiming that its product is “100% complete”: taurine. Taurine [ref] is an essential amino acid found in most animal protein sources. Taurine regulates the amount of calcium entering the heart tissue. The calcium then triggers each heart beat. Thus, taurine deficiency can cause heart failure [Thomas H. Maugh, Thousands of Cat Deaths Traced to Pet Food Deficiency , LA Times, August 14, 1987 [ref]]. Few mammals are unable to produce taurine, but cats and humans are among them. While the National Research Council (NRC) did not issue a guideline regarding the minimal amount of taurine to be included in cat food until 1981, taurine was considered an essential nutrient as early as 1976. In August of 1987, researchers at the University of California at Davis, reported in Science Magazine that a taurine deficiency in commercial cat foods had resulted in the deaths of thousands of cats before manufacturers began supplementing their products with taurine.
The discovery of the link between taurine deficiency and heart disease in cats was discovered by Dr. Paul D. Pion DVM, DipACVIM (Cardiology) [ref] while researching blood clots in cats. One cat referred to Pion by a local veterinarian had dilated cardiomyopathy (DCM), a degenerative heart disease. The cat also had eye disease and had been diagnosed as “taurine deficient” (taurine deficiency also causes degeneration of the retina). By “pure coincidence” Dr. Pion had been reading about taurine and began examining the eyes of the other cats and analysing their taurine levels. Upon discovering that every cat with DCM also had low levels of taurine, Dr. Pion began treating them with taurine supplements. Soon the cats began making “miraculous recoveries”.
Upon the discovery of the link between the dying cats and their taurine deficiencies, pet food companies, began reformulating their products to include additional taurine. While no one will ever know exactly how many cats died as a result of eating nutritionally-inadequate pet food, there is little doubt that at least one (if not all) of the taurine-deficient brands bore the label “100% complete”.
The upsetting death of thousands of cats serves as proof of the pet food industry’s ignorance regarding what constitutes a 100% complete diet. The commercial pet food industry has been around since the early 1900s. Yet an apparently essential nutrient went undiscovered until 1976, and even then, only accidentally by an academic outside the industry.
So why had cats not been dying of taurine deficiency in such large numbers prior to this discovery in the early 1980s? The answer lies in the industry’s shift from animal protein sources to an increased reliance on carbohydrates in their formulas. In other words, as long as the pet food industry included a significant amount of animal protein in their pet foods, the pets ingesting these products had no risk of developing a taurine deficiency.
Not all animals suffer fatal disease from malnutrition – that much is obvious from the evidence of pets surviving for years on just one pet food product. But this doesn’t mean that these other pets suffer no effects. On the contrary, such pets often suffer from allergies, obesity, or a host of other ailments, not to mention anything invisible to the pet parent's eye.
(Source: The AVMA Journal titled "Nutritional adequacy of diets formulated for companion animals"AVMA (requires Adobe PDF Reader))
Our most rabid opponents will tell you that raw diets do not meet the established standards for pet nutrition as per the AAFCO standards. AAFCO approval is the "Golden Seal" of quality when it comes to pet foods, and because raw diets do not have this seal of approval, many imply that they are inferior to commercial foods. But what are the AAFCO standards? How did AAFCO come up with these standards? Should they be viewed as the "Golden Seal of Approval"? Is it a valid argument to compare commercial, processed foods and raw foods using these standards? Most disturbing is that these trials are usually performed by the manufacturer and thus you, the consumer, guardian and pet parent, will not see results that are less than complimentary.
AAFCO standards and nutrient profiles were established through collaboration between scientific experts in the industry, in academia (such as universities), and in the regulatory commission (National Research Commission, or NRC). These experts looked at the peer-reviewed literature and documented data available to them and then formulated nutrient profiles after collaboration. These nutrient profiles have been updated once and are scheduled to be updated again. At this point you should note that nature's nutritional standards for dogs and cats has not changed within the past several thousand years since the species' existence (hundred thousand and even million years if you include their ancestors).
Some argue that AAFCO profiles are the best there is, but others argue that AAFCO profiles are simply "better than nothing". Indeed, the standards can lull people into a false sense of security about the food they feed their pets, just think of the big chicken egg debacle in the late 70's, and more recently, butter vs margarine. They think it is nutritionally complete, when in reality it may not be truly complete, or be completely incomplete. Additionally, AAFCO profiles have not been tested or reproduced (and one of the biggest principles of science is that the method must be reproducible and the results verifiable). There are no studies that prove "their adequacies or inadequacies" [Quinton Rogers, DVM, PhD, as quoted in "Alternative Feeding Practices" by Susan Wynn. To see the full article, click here [ref]. It is, at best, an educated guess as to what our animals really need, and is based on less-than-scientific principles.
There are several other things wrong with these standards that AAFCO uses to ensure foods are 100% "complete and balanced". The standards were developed based on the belief that dogs are omnivores and can be properly maintained on a grain-based diet. They are therefore irrelevant to raw natural diets. Why? First, to gain nutritional analysis, the food must be chemically denatured, cooked, purified, and otherwise manipulated, meaning that any reading is an inaccurate representation of the raw, natural and whole item. This also means that the interactions between nutrients are overlooked as each nutrient is studied separately rather than in conjunction (as the whole) with the others.
Second, the NRC profiles (which AAFCO used to develop its own profiles) assume 100% bioavailability. However, if a dog is fed as an omnivore, there are good amounts of nutrients unavailable to it that are contained in the indigestible plant matter. Phytates [ref] in particular (contained in abundance in grains and soy products - which kibbles often contain in substantial amounts) are well-known for interfering with valuable nutrients like iron, zinc, and calcium. Hence, you have to feed more of these nutrients in order for the dog to get the amount it needs; what the dog actually needs and uses is NOT the same amount of nutrient initially added. This results in skewed and biased standards, as they list the initial nutrient amount added, not the amount absorbed. Thus, this leads us to conclude that bioavailability is less than 100%, and the nutrients in the standards are therefore inaccurate representations of what the dog really needs.
There is a third reason why AAFCO standards are not appropriate for raw foods. This deals with the reason the food is raw and not cooked. AAFCO standards are based on cooked or processed foods (processed in order to be evaluated), foods which already have a decreased nutritional value because of being cooked or processed. Cooking denatures proteins and collagen, destroys important nutrients, and generally makes the food less digestible and less bioavailable (the exception being grains and vegetables, which we have already determined should not be given to dogs anyway). This means essential vitamins and minerals must be added back in. But how much? In what amounts? Research has shown that synthetic vitamins do not work with the same efficiency as those found in their natural state (i.e. in raw natural foods). Additionally, many vitamins and minerals interact with each other both negatively and positively. For example, vitamin C increases the uptake of iron, whereas Vitamin E inhibits the uptake of iron. Vitamin C also lowers zinc and manganese uptake, whereas Vitamin E helps increase zinc and manganese absorption [you can read the following two articles on human supplements to help contextualise this - How to Improve the Body's Absorption of Vitamins by Tracey Roizman, D.C.[ref], Demand Media and Nutrient-Nutrient Interaction in MultiVitamin Supplements by Pasha Gurevich [ref], or do your own online research on the topic]. Commercial pet foods should contain all of these nutrients, but are they contained in the proper amounts? And just what is a "proper amount"? The difficulties for establishing proper amounts have already been discussed. Do they have methods for monitoring the complex interactions of all these nutrients? Since feeding trials simply look at palatability, survival, and the appearance of health, these complex interactions are ignored. Cooking and processing food also kills enzymes that may help with the digestion of the food and the processing of nutrients, so the bioavailability of vitamins and minerals in cooked foods is further reduced [Lonsdale, T. 2001. Raw Meaty Bones. Chapter 4 (Amazon)].
Let us evaluate the actual AAFCO feeding trials themselves. Are these really the "Golden Seal of Approval" that pet food manufacturers make them out to be? As stated above, AAFCO feeding trials consist of at least eight dogs being fed the same diet for a mere 26 weeks (approximately six months). During this time, 25% of the dogs (so, two animals) can be removed from the test and the dogs eating the food can lose up to 15% of their weight and condition; the food will still pass the test and be labelled "complete and balanced". But extrapolate these figures to the number of animals eating this food for much longer than 26 weeks and you will have much more of a problem! If a food caused dogs to start losing condition over the 26 week period yet still passed, imagine how many animals would fail to thrive in real life while being fed this food for years?
As long as the remaining dogs in the trial appear healthy and have acceptable weights and certain blood values, the food passes and is considered "complete and balanced" nutrition for whatever life stage for which it was tested (puppy, adult maintenance, geriatric, etc.). So it can now be fed to your pet for a period much longer than the six-month test period. However, AAFCO feeding trials were NOT designed to measure the long-term effects of commercial diets. It says so right in their mission statement [Lonsdale, T. 2001. Raw Meaty Bones. pg 216]. AAFCO trials were designed to ensure that pet foods were not "harmful to the animal and would support the proposed life stage" [pg 216, Raw Meaty Bones] for a period of 26 weeks. The AAFCO protocols were NOT designed to "examine nutritional relationships to long-term health or disease prevention" [pg 216]. If a dog lives for six months with no noticeable ill effects on a kibble, then the food is considered 100% complete and balanced nutrition, even though long-term nutritional deficiencies may occur several years down the road.
These "complete and balanced" and "not harmful" pet foods can destroy long-term health and cause disease and yet still be marketed as a healthy food for your pet. An example would be the lamb and rice commercial diets that had met or exceeded the nutrient profiles of AAFCO, and that had passed the AAFCO feeding protocol yet created a taurine deficiency in the dogs that ate them [Torres, C.L.; Backus, R.C.; Fascetti, A.J.; and Rogers, Q.R. Taurine status in normal dogs fed a commercial diet associated with taurine deficiency and dilated cardiomyopathy. Journal of Animal Physiology and Animal Nutrition. 87 (2003). 359-372.[ref]] The dogs suffered from dilated cardiomyopathy; what is particularly distressing is that dogs can synthesize taurine from the readily-available (at least, in raw food) amino acids methionine and cysteine (whereas cats cannot), yet they still developed cardiomyopathy from this AAFCO approved food! What other "unknown oversights" are waiting to be discovered through more pain and anguish inflicted upon our pets? Other examples of "oversights" would include supplementing cat foods with taurine after cats were going blind and suffering heart problems (as described above), or the constant adjustment of calcium:phosphorus ratios in puppy foods to prevent bone malformations and improper growth patterns, which still occur despite all the supplement adjustments. Interestingly, natural calcium in raw bones does not cause these malformations to the same degree artificial calcium does. One has to feed a LOT more natural calcium via bones to get the same degree of skeletal malformations found in commercial fed pets.
When making their commercial processed foods, the pet food companies must often over-supplement their foods with the various vitamins and minerals to fall within the range of accepted nutrient values - the effects of which are NOT monitored past the six months of the AAFCO feeding trials. It should also be noted that pet food companies are not required to divulge the specific results of AAFCO testing of their products; that information is only made public if the company chooses to do so! Additionally, not all foods are required to enter feeding trials. A food can undergo laboratory analysis to determine if it meets the nutrient requirements for dogs and cats. However, those nutrient requirements - expressed as minimum and maximum values - can vary widely! The minimum iron requirement for dogs, for example, is 80 mg/kg. The maximum iron requirement is 3,000 mg/kg! This is an incredible difference, and yet one food on the low end can be just as "complete and balanced" as another food with the maximum amount for iron! How will this affect the dogs over long term? Will one animal show a deficiency while the other shows an excess? The industry does not know, because they have never been required to test this beyond the 26-week mark! Foods can also obtain "complete and balanced" status by being "grandfathered in". If a company can show that one of its new foods bears "nutritional similarity" to one of their own existing products that underwent feeding trials (which allow for the removal of 25% of the dogs and loss of condition up to 15% over the course of 26 weeks), then that food can carry the same claim of "complete and balanced". Yet the actual ingredient combination was never tested! How can this similar yet different food be "complete and balanced" for the *lifetime* of the animal if it was never adequately examined or tested? The entire process is faulty, but it is the best the pet food industry has. If this is the pet food industry's best, then what does that say about their "complete and balanced" commercial foods? Hopefully one can now see why the AAFCO standards are useless for evaluating raw food diets and why they are incomplete in determining the actual "nutrient standards" needed and utilized by our pets.
To paraphrase Dr Amy Nesselrodt, DVM, "Like most vets, I was taught that “complete and balanced” was the standard to look for in pet foods, but I’ve come to realize that nutrition is much more complicated than that. Raw is different; raw is real food."
Some of this work was adapted from the works published by Carissa Kuehn, Myths of Raw Feed, http://rawfed.com/myths/.
Additional Articles and Videos
Good reference articles & videos further reading available at:
- Raw Pet Food And AAFCO by Dr. Amy Nesselrodt (Dogs Naturally Magazine);
- Pet Food Regulations Don’t Protect Dogs By Dogs Naturally Magazine (Dogs Naturally Magazine);
- Why AAFCO Guidelines Are Useless For Raw Dog Food by Dogs Naturally Magazine (Dogs Naturally Magazine);
- Are Raw Diets Complete and Balanced (and does it matter)?, by Julia Henriques from Dogs Naturally Magazine (Raw Love Pets)
- Pet food formulations by Dr Judy Morgan (YouTube)