Petfood Industry - July 2018 - 39
www.PetfoodIndustry.com | 39
with a separate and distinct calorie content statement. Other
aspects of pet food labeling as dictated by AAFCO, including
the nutritional adequacy statement, have no equivalent
counterpart in human food labeling.
AAFCO is exploring means to "modernize" pet food
labeling and make it appear more like consumers may be
used to when shopping for their own food. However, despite
efforts to make the "Pet Nutrition Fact Box" outwardly appear
similar, there will still be significant distinctions. Many of the
remnants of current AAFCO labeling will remain, and human
food companies would have to adjust accordingly.
Ingredient declarations and definitions
FDA regulations (for human and pet food) only stipulate
that ingredients be declared by their "common or usual"
names. However, distinct to pet foods, AAFCO has defined
many animal feed ingredients which, when applicable, must
be declared by that exact name. Even when a food ingredient
is subject to an FDA Standard of Identity where the components of that ingredient must be declared parenthetically, the
terminology may be different. The ingredients that comprise
yogurt, for example, may have to be declared by other names
when converted to "AAFCO-speak."
Under the Dietary Supplement Health and Education
Act of 1994 (DSHEA), ingredients do not necessarily have
to be GRAS (generally recognized as safe) substances or
approved food additives if they meet the statutory definition
of "dietary supplement" as intended for human consump-
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Industry July 2018
M a de
tion. While dietary supplements are still "foods," this law
has allowed for a dramatic increase in the use of substances
such as herbs and metabolites that normally wouldn't be
allowed in a food in conventional form. Also, claims relating
to effect on the structure or function of the body distinct
from its nutritive value are generally tolerated on these
For more insights by Dr. Dzanis
labels. Regardless, DSHEA does not apply to animal products. Hence, the pre-DSHEA regulatory rubric remains for
pet foods, and many human food manufacturers, especially
dietary supplement manufacturers, find that the ingredients
and claims they are used to making simply are not acceptable when it comes to a pet food.
The National Animal Supplement Council (NASC) has
developed a means to label some pet products in a manner
that effectively escapes scrutiny as an animal feed by most
states. Labeled similarly to human supplements, they may
contain ingredients or bear claims not normally allowed.
However, there is a price, in that they cannot be represented
as foods or to be of nutritional benefit and may be subject
to regulation as "unapproved drugs of low regulatory
priority." Hybrid products, i.e., those that contain nutritional
and non-nutritional components, are particularly problematic in terms of label compliance. ■