FDA is trying to pull a fast one… – Truth about Pet Food

January 6, 2023 Kar-Bay-Inc

The FDA is actively trying to end the use of the term ‘feed’. Shielding industry – seemingly specifically the pet feed industry – at the expense of transparency for pet owners.

In the Federal Register on November 3, 2022 – the FDA posted a notice requesting comments regarding the “Federal-State Food Regulatory Standards”. These ‘standards’ are an effort between FDA and some US States. This federally funded program is an effort to have uniform regulations and uniform enforcement of law. The animal feed/pet food portion of these Regulatory Standards is currently termed “Animal Feed Regulatory Program Standards” (AFRPS) – BUT…FDA is proposing to change the name and legal definitions within the Standard to “Animal Food” instead of “Animal Feed”.

The FDA claims the change from Animal Feed to Animal Food will “improve program effectiveness, understanding and clarity.” However, the FDA did not provide any evidence to support their claim that changing feed to food will improve program effectiveness, understanding or clarity.

Would changing the name of the program (from feed to food) really improve effectiveness, understanding and clarity?

No, it won’t. In fact, the name change does nothing to improve effectiveness, would add to the confusion, destroys clarity and puts an end to transparency efforts for pet food consumers.

As example, AAFCO – the Association of American Feed Control Officials – is a partner organization of the Animal Feed Regulatory Program Standards (AFRPS). In order to achieve ‘clarity’ AAFCO would need to change their name to AAAFCO – the Association of American Animal Food Control Officials.

The 25 member states of AFRPS would need to change wording of their state laws. As example, North Carolina laws are titled “Commercial Feed Law”, pet food is legally defined as “any commercial feed prepared and distributed for consumption by pets.” In the North Carolina laws, the term ‘feed’ is referenced 152 times. To achieve the ‘clarity’ that FDA claims occurs with the name change, the state of North Carolina would need to change 152 different words within their state laws. And this same reference to feed in each of the other 24 member states would need to be legally changed as well.

Even the job titles of employees who enforce the regulations are called “Feed Officials” – not ‘Animal Food Officials’.

Who is going to pay for these hundreds – if not thousands – of different changes to state laws? Changes to law is not a simple process, and it is not accomplished for free.

Unless everyone makes the feed to food changes to their laws, organization names, and employee titles – there is NO improvement to effectiveness, understanding and clarity as FDA claims this proposed name change will achieve. Unless everyone makes the legal feed-to-food change, FDA’s proposal significantly adds to confusion.

But…the feed-to-food name change DOES provide some protection to pet feed producers.

In the past ten years, the consumer awareness of the differences between feed and food has grown significantly. Evidence of this is the growth of human grade ingredient pet foods and financial interest of traditional pet feed brands in pet ‘foods’. Such as General Mills’ – the owner of Blue Buffalo – 2020 investment in Pet Plate and Mars Petcare’s 2022 purchase of Nom Nom.

It benefits industry to make all pet ‘foods’ appear to be similar, no separation between feed and food. It benefits feed grade pet food manufacturers to be classified as animal food grade manufacturers. But it certainly does not benefit pet owners.

Unfortunately, the date to post a comment on this issue has passed (comment period closed January 3, 2023) on the Regulations.gov website. Our consumer association posted a lengthy and a second brief comment before the deadline closed. But pet owners can (and please do) send a comment regarding the proposed feed-to-food name change directly to FDA Center for Veterinary Medicine. Email FDA CVM at: AskCVM@fda.hhs.gov.

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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