The Label Claim FDA Admits Is Not True – Truth about Pet Food

June 10, 2023 Kar-Bay-Inc

When you look at a pet food label, is there ANYTHING on that label that would cause you to question if it provided complete and balanced nutrition for your pet?

It says – in bold type – Complete & Balanced. That is a label claim, an assurance to pet owners – right?

Wrong.

Dr. Timothy Schell, Director of the Office of Surveillance and Compliance, FDA Center for Veterinary Medicine told TruthaboutPetFood.com:

“there are many breeds and sizes of pets as well as other factors that affect dietary intake and nutrient utilization. Therefore, there is no way of ‘assuring’ animals consume a complete and balanced diet.”

Your pet food label is misleading you with full FDA knowledge. And the agency is refusing to correct the problem.

The problem: Complete and Balanced pet foods are required by regulation to meet AAFCO Nutrient Profiles (developed by FDA and AAFCO). AAFCO Nutrient Profiles are ONLY for “active” pets. The National Research Council (NRC) defined the high calorie requirement AAFCO’s Nutrient Profiles are based on as: “Dogs kept in a domestic environment with strong stimulus and ample opportunity to exercise, such as dog households in the country or in a house with a large yard.” (The same active pet/high calorie requirements apply for cat foods.)

If a pet’s calorie needs meet the ‘active’ level, the pet food should meet all of your pet’s nutritional needs.

But, if you have a senior pet or an overweight pet or live in an apartment or condo…if your pet does NOT have ‘strong stimulus and ample opportunity to exercise’…if your cat or dog cannot possibly consume the calories that AAFCO Nutrient Profiles for Complete and Balanced require – your pet could be experiencing nutrient deficiencies directly linked to your pet food whose label specifically told you was complete and balanced.

Or what if you have an athlete pet, who’s activity level requires them to eat many more calories than AAFCO Nutrient Profiles allow for? Your pet could be experiencing nutrient excesses directly linked to your Complete and Balanced pet food whose label never alerted you to any possible nutrient excess concerns.

It is NOT the manufacturer’s fault.

Unlike other pet food issues – such as when manufacturers choose to source ingredients sourced from (FDA allowed) diseased animals and animals that have died other than by slaughter or when other manufacturers choose to source USDA inspected and passed meats – in this instance manufacturers do not get to choose. ALL pet food manufacturers are required by regulation to formulate their pet foods to active pet AAFCO Nutrient Profiles. Regulations do not give manufacturers any other options – manufacturers are not given any other Nutrient Profiles for inactive pets or athlete pets.

As well…pet food regulations also require manufacturers to make the “Complete and Balanced” or “100% Complete Nutrition” label claim.

If a pet food manufacturer wanted their label to alert a pet owner that their food is complete and balanced ONLY IF a large quantity is consumed daily, existing regulations would NOT BE ALLOW THEM TO.

Don’t blame your pet food manufacturer for this problem.

The “Complete and Balanced” label claim that is currently misleading millions of US pet owners, is a “nutritional adequacy statement“. AAFCO regulations – written with full FDA participation – require all pet food labels to include “A statement of nutritional adequacy or purpose“.

These two organizations – one a private organization, the other a government organization – are the sole responsible parties for this entire mess.

This can be corrected.

This could be relatively easy to correct if FDA and AAFCO would develop and adopt multiple Nutrient Profiles for pet food manufacturers to use. There is NO NEED to reinvent the wheel, Europe already has multiple nutrient profiles available for pet food manufacturers to choose from.

But after multiple attempts by consumer advocates (veterinarian Dr. Karen Becker, pet food formulator Steve Brown, and myself) – the FDA and AAFCO refuse to fix these serious pet food nutritional problems.

What can you do?

The ONLY advice FDA gave for pet owners is for them to “work with a veterinarian to seek specifics on nutritional intake” for your pet. That is VERY poor advice.

Most veterinarians do not have a copy of the AAFCO Nutrient Profiles and/or the National Research Council’s Nutrient Requirements for Cats and Dogs. Thus they probably don’t know how much required nutrients should be in a pet food.
Even if a veterinarian happened to have a copy of the AAFCO Nutrient Profiles or the NRC book, they would also have to have a complete nutritional analysis of the pet food a pet owner was questioning. And…most pet foods do not provide this information. Without knowing the nutrient levels of a pet food, per 1,000 kcals, the veterinarian cannot give nutritional advice to the pet owner.
And most veterinarians are unaware that Complete and Balanced pet foods are formulated ONLY for active pets. Most veterinarians tell pet owners to feed less pet food if the pet was senior or overweight – or more pet food if the pet was underweight, never knowing they just gave advice that could (will in MANY instances) cause nutritional deficiencies or excesses in their patient.

The ONLY thing we can do – is ask FDA and AAFCO.

If your cat or dog cannot possibly consume the calories that AAFCO Nutrient Profiles for Complete and Balanced require, send FDA and AAFCO an email asking them what you should do now. If you have an athlete pet and you are concerned about nutrient excesses, send FDA and AAFCO an email asking them how can you feed your pet the calories they need without nutrient excesses.

Tell them your vet does not have the AAFCO Official Publication or the NRC Nutrition book for cats and dogs or have a full nutritional analysis of your pet food or have an understanding that AAFCO Nutrient Profiles are based on the caloric needs of ONLY active pets.

Tell them you have a pet that cannot possibly eat the daily calories required for a complete and balanced diet per AAFCO. Ask them – because they created this mess – what you should do.

FDA Center for Veterinary Medicine email: AskCVM@fda.hhs.gov
AAFCO email: aafco@aafco.org

If they don’t provide you with the responses you need to properly and safely feed your pet, you might want to consult with your attorney.

FDA and AAFCO caused this problem, they refuse to fix the problem, and they even tried to ‘pass the buck’ on to veterinarians. No more.

FDA and AAFCO need to face all of you who are worried about nutrient deficiencies or excesses caused by their lack of action.

Email them. Again and again and again.

Wishing you and your pet(s) the best,

Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
TruthaboutPetFood.com
Association for Truth in Pet Food

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