USA Pet Food Labels

Introduction

Pet foods distributed in more than one state of the USA are subject to a host of labelling requirements covering aspects such as product names, ingredient lists, nutrient content guarantees, and nutritional adequacy statements. In addition to meeting the federal labelling requirements, animal feed products are also subject to individual state laws. In the United States, the majority of states have adopted and enforce the AAFCO Model Regulations for Pet Food and Specialty Pet Food. AAFCO (The Association of American Feed Control Officials) is the official source of information on pet food labelling, ingredient definitions, official terms and standardized feed testing methodology.

The approach to labelling in Canada is similar to the USA. However, Canada does not regulate pet food labels, except under the broader Consumer Packaging and Labelling Act of the Competition Bureau which covers all retail packages, including requirements for dual language (English/French) declarations. There is a “Guide for the Labelling and Advertising of Pet Foods” which generally follows the AAFCO, although it has no legal force. Most manufacturers in Canada voluntarily choose to follow the AAFCO.

Label Design

Similar to Europe, a pet food label is divided into two main parts:

1. the principal display panel and
2. the information panel.

Table 1. Elements legally required on pet food labels in the United States of America and Canada.
Principal Display Panel	Information Panel
• Product name • Purpose statement (intended species) • Net weight	• Ingredient statement • Guaranteed analysis • Nutritional adequacy statement • Directions for use (feeding guidelines) • Statement of calorie content • Manufacturer or distributor

Optional declarations on the – principal display panel (PDP) are the brand name, the manufacturer’s name, and claims in words, pictures or graphics (such as the product vignette, bursts and flags).

Principal Display Panel

The principal display panel is the part of a label that is most likely to be displayed to customers at retail facilities. It is a primary means of attracting the consumer’s attention to a product and is usually used to communicate important information about the product.

Product Identity

Beside the product name, which is legally required, the product identity can also include the manufacturer’s name, a brand name or both. It is not mandatory to include the manufacturer’s name as part of the product identity on the principal display panel, but the name and address of the manufacturer (or distributor, when the product is manufactured for another party) must appear somewhere on the label. The product name often contains some description of the food and is subject to AAFCO regulations about composition of ingredients such as the percentage rules.

Percentage Rules

The percentage rules determine the terminology that can be used to describe a product depending on the inclusion level of an ingredient. For instance, the terms “lamb dinner”, “lamb recipe” or a similar designation requires that lamb (not including by-products or derivatives such as lamb meal or lamb liver) make up at least 25 % of total weight of all ingredients. For wet foods the water added during processing may be excluded from the percentage calculation, but never be less than 10% of the total product (AAFCO). An ingredient less than 25% but that comprises at least 3% of the formulation (exclusive of water for processing) may be indicated in the name or elsewhere on the label only in conjunction with words such as "with" or "contains," and must fall below maximum type size requirements to avoid overemphasis of minor ingredients.

Intended Species

The words “dog food” or “cat food” or similar terms must appear conspicuously on the principal display panel of pet foods. It must identify the animal for which the product is intended, so that it is clear that the product is not intended for humans.

Net Weight

The declaration of the net weight (or volume, in the case of liquid products) on the principal display panel is mandatory under FDA regulations. Net content declarations must be displayed in conspicuous and easily legible print, within the bottom 30% of the principal display panel in lines generally parallel to the base of the package. There are type size requirements for the net weight statement based on size of the Principal Display Panel.

Information Panel

Ingredient Statement

Unlike the EU, each ingredient in the pet food must be listed in descending order by weight (i.e., ingredient categories are not allowed). AAFCO has established the name and definition of a wide variety of ingredients. The ingredient names on the label must conform to the AAFCO name (e.g., poultry by-product meal, corn gluten meal, powdered cellulose), or when an applicable AAFCO name is lacking, be declared by their common or usual names, such as beef or chicken. Collective terms, such as animal protein products or ingredient brand names are not allowed on pet food labels. Contrary to the EU, in the USA trace elements and vitamins are considered ingredients and are listed in the ingredient statement. In the same way, additives such as antioxidants, preservatives, humectants, colouring agents, flavours, etc. must be listed in the ingredient statement.

Guaranteed Analysis

Table 2. Guaranteed Analysis.
Crude protein	Minimum %
Crude fat	Minimum %
Crude fibre	Maximum %
Moisture	Maximum %

Unlike pet food labels in the EU, where the typical analysis of nutrients has to be declared, in the United States minimum / maximum guarantees are declared on pet food labels (Table 2). It is important to recognise that these percentages generally indicate the “worst case” levels for these nutrients in the food. Although the guarantees do not reflect the exact or typical amounts of these nutrients, this method of declaration provides a sound means of verification and enforcement by regulators. The maximum moisture content in pet foods cannot exceed 78%, except in products labelled as a stew, gravy, broth, juice, milk replacer or similar terms.

In addition to the above, a maximum percentage crude fat guarantee is required on any dog or cat food label bearing a "low fat" "lean," "less fat" or similar claim. Although a maximum percentage ash* guarantee is not legally required in the United States, many pet food manufacturers include one on the labels of their foods. Guarantees for other nutrients may also be declared, the declaration of a nutrient is not mandatory unless its presence is highlighted elsewhere on the label, for example, "with taurine" would require a minimum percentage taurine guarantee. If these additional guarantees are for essential nutrients (e.g., taurine in cat foods), they must be declared following the same terms and units of measure outlined in the AAFCO Nutrient Profiles. If the nutrients are not essential (e.g., taurine in dog foods), a disclaimer stating so must be asterisked to each nonessential nutrient.

• Ash is the term used to define the inorganic material left after organic material has been burnt. It is important to recognise that it does not indicate that ash was added to the food.

Feeding Guidelines

All "complete and balanced" pet foods must provide quantitative feeding directions for each life stage indicated in the nutritional adequacy statement, unless a more restricted life stage designation is more prominently indicated elsewhere. The feeding directions must at minimum state the amount of feed (e.g. cups) per given body weight dog or cat and the frequency of feeding, although especially on larger packaging, more detailed directions, often in tabular format, are typically provided.

Statement of Calorie Content

Almost all dog and cat foods must carry a calorie content statement. This requirement includes all complete and balanced foods and all snacks, treats and non-exempt chew products. The statement is separate from the guaranteed analysis and appears under the heading ‘calorie content’. The declared energy is the metabolizable energy and must be expressed as kilocalories per kilogram (kcal/kg) of product on an ‘as fed’ basis, as well as in kilocalories per familiar household measure (e.g., kcal/cup, kcal/can, per piece). Rawhides, bones, ears and other chews that are exempt from AAFCO registration and labelling requirements are not required to display a calorie content statement. The method of determination (calculated vs. feeding trials) must also be clearly identified in the statement. The method for determining calories by digestibility trials is described in protocols in the AAFCO Official Publication.

The calculation method, which is also described in the AAFCO Official Publication & AAFCO’s "Business of Pet Food" website, is based on the average analysis (not the guaranteed analysis) and uses the modified Atwater factors: kcal ME/kg = (% crude protein x 3.5 + % NFE x 3.5 + % crude fat x 8.5) x 10, where NFE (the non-structural carbohydrate fraction) is determined by subtracting the combined measured fractions (crude protein, crude fat, crude fiber, moisture and ash) from 100.

Name and Address

The name and address of the guarantor, who may be the manufacturer, importer, or distributor must be stated on the label, on the information panel. Phrases as ‘distributed by...’, ‘manufactured for...’ or ‘imported by...’may indicate that a company other than the one selling the product has manufactured the pet food. This is a common practice with private label pet foods. Products that are imported must indicate the country of manufacture alongside the Guarantor Statement.

Complete and Balanced - Nutritional Adequacy Statement

In the USA, all pet food labels, with the exception of products clearly labelled as treats and snacks, or supplements must contain a statement of nutritional adequacy and manufacturers must indicate the method and life stage that was used to substantiate this claim (validation of nutritional adequacy). AAFCO regulations allow three methods to substantiate such claims:

1. Based on product formulation
2. Based on feeding trials, and
3. Based on "product family" criteria .

Based on product formulation

In 1990 and 1991, AAFCO convened the Canine Nutrition Expert (CNE) and Feline Nutrition Expert (FNE) subcommittees to establish practical nutrient profiles (minimums and maximums) for cat and dog foods based on commonly used ingredients. The profiles were last updated in 2016. The reports of the CNE and FNE subcommittees (and subsequent revisions) form the basis for the nutrient profiles that are published in the annual edition of the AAFCO Official Publication. The formulation method allows a manufacturer to claim ‘complete and balanced’ for a given life stage or life stages when the product is formulated to meet the AAFCO Dog or Cat Food Nutrient Profiles for that life stage(s). These nutrient profiles cover two categories:

1. Growth and reproduction and
2. Adult maintenance (AAFCO 2015).

For example, a pet food meeting the AAFCO nutritional profile of adult dogs can bear the following statement: ‘(Name of product) is ‘formulated to meet the nutritional levels established by the AAFCO Dog Food Nutrient Profiles for maintenance of adult dogs.’ The most recent revision of the AAFCO Dog Food Nutrient Profiles include a lower maximum calcium level in foods that MAY be fed to large-breed puppies. All products indicated "for growth" or "for all life stages" and that contain no more than 1.8% Ca on a dry matter basis must include the clause "including growth of large size dogs (70 lbs or more as an adult)." Dog foods exceeding that amount (but still in conformance with the maximum calcium allowance for all dog foods) must state "except for growth of...).

Based on feeding trials

The second method requires that the manufacturer performs an AAFCO-protocol feeding trial using the food as the sole source of nutrition. The feeding trial method can result in a nutritional adequacy claim for one or more of the following categories:

1. Gestation and lactation,
2. Growth,
3. Adult maintenance and
4. Complete for all life stages.

AAFCO has published minimum testing protocols for adult maintenance, growth and gestation/lactation. A food that successfully completes a gestation/lactation trial, followed by a growth trial using the puppies/kittens from the gestation/lactation trial, can also make a claim for all life stages. The required terminology for labels of pet foods that have passed these tests is: ‘Animal feeding tests using AAFCO procedures show that (brand YY) provides complete and balanced nutrition for (lifestage xx)’. The adult maintenance protocol uses a minimum of eight animals that are fed the food as the sole source of nutrition for six months, during which the animals are evaluated for any change in body weight and other clinical signs of nutritional deficiency or excess and blood analyses are performed. Growth protocols include feeding the food for a minimum of 10 weeks during the most critical growth phase to maximize the ability to detect nutritional problems with the food. Evaluation of feeding trials to support nutritional adequacy for pregnant or nursing dogs and cats also looks at additional parameters, such as litter size and puppy/kitten weight at the end of the trial.

Based on product family criteria

The third method (product family criteria) requires the testing of a representative lead member through the appropriate feeding trials. To be designated a member of the product family, foods must be the same processing type and in the same moisture category, be intended for the same or more restrictive life stages, be similar in energy density (±7.5% kcal/kg on a dry matter basis), and meet other nutritional criteria compared to the lead product. Provided that the calorie content of both products are determined by digestibility trials, product family members are allowed to bear the same "animal feed tests..." statement as found on the tested product.

Products substantiated by the latter two methods may be subject to re-substantiation upon any changes to the formulation or after 5 years on the market. The label for pet foods that fail to meet AAFCO requirements by any of the three standard methods (feeding trial, product family or formulation) and is not prominently identified as a snack, treat, or supplement must bear the statement: This product is intended for intermittent or supplemental feeding only.

Veterinary therapeutic foods, which are intended for use by or under the supervision or direction of a veterinarian, must be substantiated for nutritional adequacy by one of the above methods or its label must bear the "intermittent or supplemental" statement as required for all dog and cat foods. However, labels for these foods may bear the statement ‘use only as directed by your veterinarian’ in lieu of feeding directions. Technically, veterinary therapeutic foods are drugs as defined by FFDCA, and have not undergone the approval process as required by the law for drugs. However, FDA exercises enforcement discretion in not taking action against these products provided they meet the FDA's guidelines.

Batch Information

Information such as batch code and date of manufacture are also frequently found on pet food labels, and companies often use the ‘best before date’ or something similar to indicate the freshness date of the product. A method of traceability is also required and this information can be used to meet this need. Because of the need to continuously revise the code during production, this information is typically stamped on the label or elsewhere on the container (e.g., the bottom of the can), not necessarily in conjunction with either the principal display panel or the information panel.

References

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