The Most Sweeping Change in Pet Food Label Transparency – Truth about Pet Food

Have you ever wondered why AAFCO has to define pet food ingredients? As example, chicken is already legally defined through the Poultry Products Inspection Act. So why would the chicken used in pet food require another definition?

The answer: because pet food chicken is held to a completely different standard than the chicken consumers are familiar with. The commonly known chicken is required to meet the legal standards of the Poultry Products Inspection Act, but the chicken used in (most) pet foods is NOT required to meet the legal standards of the Poultry Products Inspection Act (the exception would be human grade pet foods). To the confusion of millions of pet food consumers, both chicken ingredients have the exact same name even though they are held to two very different standards. Legally speaking, pet food chicken is a nonstandardized food (it does not meet the ‘standard’ of food chicken).

But, federal law takes into consideration this confusion caused by two very different ingredients of the same name. In fact, federal law – specific to animal food – requires the confusion to be addressed in the ingredient name.

Title 21, Chapter I, Subpart E, Part 502 Common or Usual Names for Nonstandardized Animal Foods states (bold added for emphasis):

“General Principles (a) The common or usual name of a food, which may be a coined term, shall accurately identify or describe, in as simple and direct terms as possible, the basic nature of the food or its characterizing properties or ingredients. The name shall be uniform among all identical or similar products and may not be confusingly similar to the name of any other food that is not reasonably encompassed within the same name. Each class or subclass of food shall be given its own common or usual name that states, in clear terms, what it is in a way that distinguishes it from different foods.”

There couldn’t be much more “confusingly similar” names than nonstandardized ingredients of pet food that have the EXACT SAME name as standard ingredients of food. The pet food ingredients chicken, beef, lamb, turkey, corn, peas, and on and on have a common name that is ‘confusingly similar’ (actually it’s identical) to standardized foods.

Most pet food ingredients are feed grade, a “subclass” of food. Law clearly requires that any “subclass of food shall be given its own common or usual name…that distinguishes it from different foods.” There is no doubt about it – feed grade ingredients are a subclass of food and they are required to be given a different name.

So…(here is where we need your support)…

Based on this law (and a few others) we have submitted an official request to the FDA to amend current pet food ingredient names. Based on the legal requirements within animal food law, we have requested FDA to require pet food label disclosure of the subclass ingredients feed grade.

The official request sent to FDA is termed a “Citizen Petition”, a process where individuals or organizations can make requests to FDA for changes in policy. Citizen Petitions submitted to FDA are posted on the government website Regulations.gov and are open for public comment. FDA is required by law to respond within 150 days (though they commonly ignore this legal deadline).

Our Citizen Petition can be read here. We make several legal arguments, proving to FDA that law requires the label disclosure of feed grade ingredients. As required, our Citizen Petition explains what we are requesting in Section A. We included in Section A existing laws and proposed laws that would make it clear to industry the feed grade disclosure requirements. Section B of our petition includes the grounds for our request, where we quote numerous sections of law evidencing feed grade is required to be disclosed on the pet food label.

Your part…Submit a Comment!

It is significantly important for FDA to see that pet food consumers support this change. As well, it is significantly important for FDA to see that pet foods using human grade ingredients support this change. And it is simple to show your support.

Our Citizen Petition is posted on the government website Regulations.gov. Click on the blue “Comment” box. You can include your name or you can remain anonymous.

Please share the Petition with every pet owner you know and ask them to post a comment. Your comment can be as simple as ‘I support this petition’ to as detailed as you’d like to make it. Feel free to tell the FDA why you believe label disclosure of feed grade ingredients is necessary.

Everyone (but the pet feed industry) benefits.

These sweeping changes to pet food labeling will benefit millions of pet owners. After decades of pet food label deception, if FDA implements these changes as law requires, pet owners would finally know if they are purchasing pet food or pet feed.

We suspect the pet feed industry won’t be too happy about our Citizen Petition. We suspect they will be lobbying their members of Congress urging them to influence the FDA to ignore these legal requirements. To battle their lobbying efforts, we ask pet owners to share the Petition with their members of Congress too.

Send your Senate and House Representatives in Congress a message stating you are in support of Citizen Petition FDA-2022-P-1643-0001. Ask your Representative to urge the FDA to amend the common names of pet food ingredients disclosing the subclass feed grade as animal food law requires.

Wishing you and your pet the best –

Susan Thixton
Pet Food Safety Advocate
TruthaboutPetFood.com
Association for Truth in Pet Food

Become a member of our pet food consumer Association. Association for Truth in Pet Food is a a stakeholder organization representing the voice of pet food consumers at AAFCO and with FDA. Your membership helps representatives attend meetings and voice consumer concerns with regulatory authorities. Click Here to learn more.

What’s in Your Pet’s Food?
Is your dog or cat eating risk ingredients?  Chinese imports? Petsumer Report tells the ‘rest of the story’ on over 5,000 cat foods, dog foods, and pet treats. 30 Day Satisfaction Guarantee. Click Here to preview Petsumer Report. www.PetsumerReport.com

Find Healthy Pet Foods in Your Area Click Here

The 2022 List
Susan’s List of trusted pet foods. Click Here to learn more.