When Is “Human Grade” False and Misleading? – Truth about Pet Food

In a recent press release, Mars Petcare announced a new pet food that included a “Human Grade” claim on the label.

The new “Fresh Chef” line of dog foods from Mars Cesar is a refrigerated pet food, available in a roll, that looks remarkably similar to Freshpet dog food.

The marketing images of the two pet foods even included the same white marble background, with food ingredients scattered around and the same cut slices of dog food. BUT…there is one big difference between the pet foods. The Mars Petcare Cesar dog food has a “Human Grade” claim on their label:

Is Mars Petcare making a human grade pet food?

The legal requirements of human grade pet food (see page 10) are very clear. All ingredients (food ingredients and supplements) are required to be human edible, and all manufacturing conditions have to meet human food standards.

Regulations on the claim include a guidance document (see page 5) to clarify the requirements for pet food manufacturers. The document states:

“In the definition, the term “human grade” is false and misleading if the product
as a whole is not human edible. “Human grade” claims may not be made for
individual ingredients in a finished product that does not fully adhere to the
manufacturing and ingredient specifications identified above.”

In other words, regulations consider it false and misleading for a pet food company to make a claim of human grade ingredients (even if it is true) – unless the pet food is also made in a licensed human food facility. Pet food companies are held to an ‘all or nothing’ standard; pet foods must meet all of the legal requirements to make a Human Grade claim, or they cannot make the claim anywhere (label or website).

So, to determine if the Mars Petcare Cesar pet food was potentially misleading pet owners, I asked the company a few questions. Below is the transcript of a chat I had with Mars Petcare Cesar (12/6/21). I gave them my real name and my real email address.

Me: “Hi Ashton – the new Cesar Fresh Chef product – is that a human grade pet food?”

Mars Petcare Cesar: “We can assure you that our animal proteins and ingredients are derived from animals intended for human consumption. For a manufactured pet food, both the individual ingredients and the final product must comply with these standards.
Pet foods have their own set of strict standards and regulations as to what makes a nutritious, balanced meal and what does not. Here at Mars Petcare, we complete over 300 of our own quality checks to ensure that we aren’t giving anything to your pets that we wouldn’t give to our own.”

Me: “Are the foods manufactured in a human food facility or pet food facility?”

Mars Petcare Cesar: “They are manufactured in USDA inspected facilities.”

Me: “A USDA inspected facility – under USDA inspection? Such as what is required of human food?”

Mars Petcare Cesar: “Happy to circle back with you! Any other questions?”

Me: “Yes – my previous question. Are the foods made under USDA inspection?”

Mars Petcare Cesar: “Sounds great. Is susan@truthaboutpetfood.com your correct email?”

Me: “Yes. Does this mean you will email the response to my question?”

Mars Petcare Cesar: “Yes, I will get back to you after connecting with our internal team to verify.”

Trouble is…Mars Petcare Cesar did not answer my question via email.

This was a potential troubling question to Mars. If by chance the pet food is not manufactured in a licensed human food facility as is required to make the label claim of Human Grade, and they admitted that to me – they would be admitting to “false and misleading” labeling.

Does the Mars Petcare Cesar dog food meet the requirements to use the term Human Grade on the label or website? Or are they using the term in a “false and misleading” manner according to the legal guidance?

Because Mars Petcare Cesar did not fully respond to my questions, we don’t know if this dog food meets the requirements to use the term Human Grade on their label and website. Because Mars Petcare Cesar didn’t respond, the label was reported to regulatory authorities for their investigation.

How to protect yourself and your pet from false and misleading Human Grade claims.

Unfortunately for pet owners, because regulatory authorities rarely enforce labeling laws more and more companies are misleading pet owners with claims of Human Grade. Which means pet owners need to be fully aware of the laws in order to determine if a brand is misleading you or abiding by law.

With the human grade claim –

1. If the words “Human Grade” (or similar) are used anywhere on the label or on the website, the pet food must use 100% human edible ingredients and supplements, and must be manufactured in a licensed human food facility.
2. The legal guidance document for Human Grade pet food clearly states the pet food as a whole has to meet all the human grade requirements, the term cannot be used to reference individual ingredients.
3. The legal guidance document states the labeling requirements for Human Grade claims include marketing and/or website claims, “brochures, point of sale materials, websites, etc.”

Here is the legal definition of Human Grade pet food:

“Every ingredient and the resulting product are stored, handled, processed, and transported in a manner that is consistent and compliant with regulations for current good manufacturing practices (cGMPs) for human edible foods as specified in 21 CFR Part 117.” Link to AAFCO document (page 10): https://truthaboutpetfood.com/wp-content/uploads/2021/12/Ingredient_Definitions_Minutes_2016_Midyear_Isle_of_Palms.pdf

Here is the link to the AAFCO guidance document for the Human Grade claim (see page 5): https://truthaboutpetfood.com/wp-content/uploads/2021/12/Pet_Food_Report_20160317_emeeting.pdf

Ask the pet food manufacturer:

• Are all ingredients human edible?
• Are all supplements human edible?
• Are the pet foods manufactured in a licensed human food facility under USDA inspection?

If you find a pet food label or website that is making Human Grade claims, but do not meet the legal requirements – report that pet food company to your State Department of Agriculture and the FDA (AskCVM@fda.hhs.gov). Maybe, with consumer complaints regulatory will begin to enforce Human Grade labeling laws.

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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