Petfood Industry - July 2018 - 38
38 | www.PetfoodIndustry.com
David A. Dzanis, DVM, PhD, DACVN
Human vs. pet food labeling:
How do they differ?
Pet food trends may
follow human food trends,
but ingredient labeling
requirements can be quite
different between the two
markets. | Photo by Andrea Gantz
There was a recent report of an
increase in human food companies
getting into the pet food business.
Many of them likely assume the
regulation of pet foods is the same if not less
stringent than what they already face. It's one
thing if it's a conglomerate buying an established
pet food company, where it can rely on the experience of the existing personnel. However, when
a human food company tries to enter the pet
food market on its own, it may find some of the
labeling regulations to be quite unexpected.
Differences in human and pet
food labeling regulations
Foods for human consumption fall under the
authority of the U.S. Food and Drug Administration (FDA), with the primary exception of
meat and poultry products regulated by the U.S.
Department of Agriculture (USDA). Labels for
products subject to USDA inspection must be
approved by the agency, but FDA does not require
premarket review of labeling. Rather it is the
burden of the manufacturer to ensure the label is
compliant. True, FDA may take action if it finds a
food on the market that is not labeled in accordance with its regulations, but oversight is spotty.
On the other hand, in addition to FDA, the
majority of states require submission of pet food
labels as a condition of registration and/or licensure
in that state. Although a state's authority stops at
its border, in practice the objections of even a single
state can have nationwide consequences, as it is
typically infeasible to have multiple labels on the
market at once. Many human food companies are
simply not ready for that.
Many aspects of labeling are the same for
human and pet foods (e.g., net weight declaration, manufacturer's or distributor's name and
address). However, as per the Nutrition Labeling
and Education Act of 1990, labels for human
foods must convey nutrient content information via a specifically formatted "Nutrition Facts
Box." The same information on a pet food label,
however, must meet the requirements of the
Association of American Feed Control Officials
(AAFCO) model regulations. This is a decidedly different format, including a "guaranteed
analysis" where nutrient content is expressed
in terms of percentages, not per serving, along
Dr. Dzanis is CEO of Regulatory Discretion Inc. and a writer and consultant on nutrition, labeling and regulation. He is also the
author of Petfood Industry magazine's monthly column, "Petfood Insights."