list and confuse rather than inform name or standard of identity is not form in the finalproduct, and the name
the consumer. However, it’s often used. In fact, although not allowed by of the ingredient accurately and in a
prudent, if not necessary, to use strict interpretation of the human food non-misleading manner describes its
these on occasion to help support labeling regulations either, the practice basic nature, characterizing property,
claims elsewhere on the label. True, has been informally sanctioned in other or discernible form.
depending on the situation, they can FDAdocuments. Asaresult, themarket My suggestion regarding “source
be misleading, such as when a trivial is replete with examples of this practice, of…” pa r ent het ic als is to req u i re
source is identified by a parenthetical and as far as I can see, they don’t deceive the identif ied sou rce of the named
while a much more prominent source or confuse the consumer. nutrient or substance to be the primary
of that same nutrient or substance is If I wasn’tclearinthe Petfood Forum source, unless the primary source is
not identified as a source. However, 2006 Proceedings, I don’t challenge also identified. In general, extensive
since a given petfood may contain a or disagree with the interpretation of use of these parentheticals should be
large number of ingredients that may the regulations by FDA or AAFCO, discouraged, but at the same time
contain trace amounts of the named nor do I question their motives in judicious use should be recognized as
nutrient or substance, requiring all making their determination. In fact, I helpful in cases where the ingredient’s
potential sources to be identified only wholeheartedly agree with the goal of purpose as a source is not evident from
encourages more elaborate, and hence the regulators to ensure truthful, non- the ingredient name itself. ●
more confusing, ingredient lists. misleading ingredient label declarations.
However, in consideration of practical Dr. Dzanis is a writer and independent
My suggestions applications, I respectfully ask for some consultant for the petfood and animal
There appears to be little, if any, laxityonthispoint. Myrecommendation feed industries on matters related
concern with use of parentheticals to is to allow parentheticals to describe to veterinary nutrition, labeling and
describe multi-component ingredients multi-component ingredients when regulation. He can be reached at Tel:
on human food labeling, even in cases the ingredient is added as a single +1.661.251.3543, Fax: +1.661.251.3203,
where an established common or usual ingredient and/or it retains a discernible E-mail: dzanis@aol.com.
