There are NO Organic Pet Food Regulations – Truth about Pet Food

Regulations for organic pet foods are non-existent.

The AAFCO Official Publication (the pet food rule book) defines the feed term ‘organic’ as a feed or feed ingredient that meets the requirements of the USDA National Organic Program – explained in federal law within Title 7 Code of Federal Regulations Part 205 (7 CFR Part 205). But…those regulations are for human food and livestock feed, not pet food.

Within 7 CFR Part 205 the word ‘livestock’ is mentioned 95 times, and the word ‘feed’ is included 88 times. (And unlike ‘feed’ laws across almost all US states which define pet food as a feed, the USDA National Organic Program defines feed as: “Edible materials which are consumed by livestock for their nutritional value.”) But the words ‘pet’ or ‘pet food’ are not mentioned, not once.

The AAFCO website states (bold added): “Organic regulations specific for pet foods are currently being developed.”

“Currently“?

In 2004, the National Organic Program decided to organize a task force “to develop
labeling standards for organic pet food“. The notice about the proposed organic pet food task force – posted in the Federal Register – stated (bold added): “The National Organic Standards Board (NOSB) at its October 12- 14, 2004, meeting recommended the formation of two ad hoc task force groups to develop draft organic standards. One task force will develop proposed production, handling, and labeling standards for food and animal feed products derived from aquatic animals. The second task force will develop proposed organic labeling standards for pet food.”

In 2008, the Organic Pet Food Task Force released their recommendations to the National Organic Program. Included within their recommendations were legal definitions of pet food and some ingredients, as well as labeling requirements of organic pet food such as the requirements for “organic” or “made with organic” statements on labels.

In 2010, the AAFCO website posted an “Update on Organic Pet Foods“, but the update was not from regulatory – instead the update was from industry (the Pet Food Institute). Within this update it stated the National Organic Program shared “that rulemaking for pet food will be included in the NOP’s priority work plan for
FY 2011.”

But organic pet food regulations were not provided in 2011, or any year since. Seventeen years have passed since the National Organic Program decided to develop labeling standards for organic pet food…but we still don’t have them.

Where does this leave organic pet food today?

The Pet Food Institute’s update from 2010 stated organic pet food rulemaking “will eliminate future confusion and contradictions.” Without any organic pet food regulations, what pet owners are left with today is confusion and potential contradictions.

Without regulations, one pet food manufacturer could interpret the existing National Organic Program federal laws one way while another manufacturer could interpret them another way. The existing laws don’t mention pet food, so basically they are free to interpret them any way they want. Significantly, without specific organic pet food regulations, regulatory authorities in pet food have nothing to enforce should regulatory disagree with a manufacturer’s interpretation of law.

Why hasn’t organic pet food regulations been written? Why the seventeen year delay?

It could be all the regulatory bodies involved.

The National Organic Program is part of the federal agency USDA (United States Department of Agriculture). But, pet food is regulated by sister federal agency FDA (Food and Drug Administration). These two ‘sisters’ don’t typically work together – each regulates within their jurisdiction careful not cross the line into the other’s jurisdiction. And then pet food also has AAFCO (Association of American Feed Control Officials) regulations which are openly accepted by FDA but not accepted by USDA.

We know the USDA believes that all meat ingredients in pet food should be inspected and passed, but FDA believes condemned meats are suitable for use in pet food. The seventeen year delay in organic pet food regulations could be directly linked to the two VERY different perspectives of pet food from two federal agencies.

Questions were sent to the USDA National Organic Program regarding regulations for organic pet foods, but they have not responded. Should they provide us some answers, they will be shared.

Regardless to why, because regulatory authorities haven’t written organic pet food laws, pet owners are forced to become private detectives to learn exactly how organic their organic pet food is. If your pet food makes organic claims, ask for documentation from the company to validate those claims.

One more thing…organic does NOT guarantee human grade.

Condemned, diseased, or even non-slaughtered organic raised livestock would be allowed into organic pet food (by FDA). As example the pet food label could claim organic chicken and that chicken could be condemned chicken.

Organic pet foods with the words “Human Grade” on the label (ignore website claims) are manufactured in a licensed human food facility, thus not only are those pet foods guaranteed to be all human grade ingredients – the organic ingredients in those pet foods would be required to meet the human food organic regulations.

Personal opinion: Somebody (USDA or FDA) needs to promptly write and implement organic pet food regulations. Further, pet food consumer opinions must be considered when these laws are developed. The 2008 Organic Pet Food Task Force did not include one consumer representative. A new task force needs to be organized that includes consumer representatives, USDA, FDA, AAFCO and industry. It’s time EVERYONE come to the table and gets this done. Pet owners have waited long enough.

Wishing you and your pet(s) the best,

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