How Pet Food is Regulated - Nutrition
Introduction
Pet food in developed countries is regulated at every stage, from the ingredients used, through the production process and through to marketing and sales. Much of the legislation applies to pet food in the same way as it does to other product categories like, for instance, human food. Often more specific regulations cover both farm feed and pet food with specific legal provisions that are only applicable to pet food.
Additionally, the pet food industry within a country can be self-regulated through a series of industry Codes or Guidelines that provide detailed rules for practical implementation of legislation or establish rules in fields that are not regulated by law. The objectives of legislation and self-regulation are to ensure that pet food products fulfil the nutritional need of pets, are safe for both animals and people and that the information to consumers is accurate and truthful. Wherever pet food is manufactured, it has to meet legal requirements established by the country or region in which it is sold.
The following sections describe the way pet food is regulated in the European Union and in the United States. Pet food provisions also exist in many other countries around the world.
Europe
Within the European Union (EU) there are three main legislative bodies - the EU Commission, EU Parliament and Council of the European Union. These bodies are responsible for developing and adopting all legislation concerning food and animal feed, including pet food. The EU Member States, on the other hand, are responsible for the implementation and control of correct application of the EU legislation. In EU legal texts a distinction is made between the term “food” which is reserved for food stuffs for humans and “feed” which is designated to animal feeding stuffs.
Pet Food Safety
Two laws set out the basic principles for food and feed safety: the ‘general food law’ (Regulation N° 178/2002) (LINK) and the ‘feed hygiene regulation (Regulation N° 183/2005) (LINK). Regulations N° 1069/2009 and 999/2001 (LINKs) are more specific and provide strict rules to ensure that all animal products used in animal feed and human food are safe. Regulation N° 1831/2003 (LINK) regulates the additives used in animal feed. This means that all additives have to be evaluated on their safety before being used in animal feed. All approved additives are listed in the Register published by the EU Commission.
Labelling and Claims
Regulation N° 767/2009 (LINK) provides rules for labelling, claims and other forms of marketing communication to make sure that the information provided to consumers is accurate and truthful. This regulation also provides for dietetic products [products for particular nutritional purposes (PARNUT)]. Directive 2008/38/EC (LINK) lists all approved PARNUT indications and the specific conditions for the diets that are put on the market for each those indications.
USA
Under the Federal Food, Drug and Cosmetic Act (FFDCA), the US Food and Drug Administration (FDA) has jurisdiction over all animal feeds in interstate commerce such as pet food (LINK to pet food section p. 8), supplements and ingredients, including imported products. While the U.S. Department of Agriculture regulates meat and poultry products for human consumption, materials of animal origin intended for animal consumption are under FDA jursidiction. The FFDCA requires that all animal foods be safe to eat, produced under sanitary conditions, contain no harmful substances and be truthfully labelled (LINKs to details on food & feed safety section p. 7). The Food Safety Modernization Act of 2011 (FSMA) amended FFDCA to set forth requirements for pet food manufacturers to establish preventive controls and follow Current Good Manufacturing Practices. The Center for Veterinary Medicine (CVM) within FDA ensures that additives and ingredients used in pet food are safe and have a proper function and enforces basic animal feed labeling requirements (e.g., statement of identity, net content statement, ingredient declaration, manufacturer's or distributor's name and address). Most of the individual states within the U.S. also regulate pet foods (including treats, supplements and edible chews) that are offered for sale within its jurisdiction. To facilitate uniform interpretation and enforcement of state regulations, the majority of those states follow the model laws and regulations as set forth by the Association of American Feed Control Officials (AAFCO). These models augment and complement the FDA regulations, covering many aspects of labeling not addressed at the federal level. AAFCO also sets nutrient standards for substantiation of nutritional adequacy and defines ingredients and specifies acceptable ingredient names. AAFCO is a private organization, but all AAFCO members must be state or federal government officials. Laws and regulations developed by AAFCO are not directly enforceable, because AAFCO is not a governmental institution, but AAFCO provides a forum whereby control officials, industry associations and consumer groups meet in partnership to address problems and provide guidance. AAFCO remains the recognized information source for pet food labelling, ingredient definitions, official terms and standardized feed testing methodology. This information is published annually in their Official Publication (LINK). Feed control officials within each state inspect facilities and enforce these regulations.
Pet Food Industry Associations
GAPFA (Global Alliance of Pet Food Industry Associations)
GAPFA brings together 13 national and regional pet food associations globally as well as corporate members with a focus on food for dogs and cats. GAPFA was officially established in November 2014 under Belgian law. The GAPFA mission is to support the health and wellbeing of pets and to promote the benefits of living with them, by providing a forum for global industry consensus to address key mutual issues. Its vision is to be recognized as the global voice of the pet food industry. The focus of GAPFA is to harness the collective knowledge and experience of the global pet food industry with the objective to develop science-based global nutritional and safety standards which will provide reference and will facilitate trade of pet food.
Pet Food Institute (PFI)
Pet Food Institute (PFI) is the main Trade Association of dog and cat food manufacturers in the USA. Affiliate members of PFI include the leading suppliers of equipment, ingredients, packaging and services to the United States pet food industry. The PFI was organized in 1958 as the national trade association of dog and cat food manufacturers in the United States of America. Active members of PFI produce 95% of the total dog and cat food tonnage in the United States. Affiliate members of PFI include the leading suppliers of equipment, ingredients, packaging and services to the United States pet food industry. PFI works closely with veterinarians, humane groups and local animal control officers to encourage responsible dog and cat ownership. It also represents the industry before legislative and regulatory bodies at the federal and state levels.
FEDIAF (European Pet Food Industry Federation)
Established in 1970, the Fédération Européenne de l’Industrie des Aliments pour Aminaux Familiers (FEDIAF), the European Pet Food Industry Federation, represents the pet food industry in Europe and unites the national professional organizations of 26 European countries, whether or not belonging to the EU, via 18 national or regional pet food industry associations (8). FEDIAF represents around 650 companies (8) responsible for producing more than 90% of European pet food. The national organizations represent manufacturers, packers and importers of prepared pet food, including foods for dogs, cats, birds, and other pets. FEDIAF represents the European pet food industry in all external forums. Through its national Associations, FEDIAF also collaborates with local and national authorities. As a competent partner, FEDIAF cooperates with the European authorities to implement pet food law designed to ensure the manufacture and distribution of safe, nutritionally balanced and palatable pet food products. This has led to a development of Self Regulation in a form of three industry Codes, which have been recognized by the EU authorities. The 3 self-regulating FEDIAF Codes are the “Guide to good practice for the manufacture of safe pet foods” (LINK), the “FEDIAF Code of good labelling practice for pet food” (LINK), and the “Nutrition guidelines for complete and complementary pet food for cats and dogs” (LINK). Wherever possible, FEDIAF strongly encourages responsible dog and cat ownership.
Dog and Cat Nutritional Guidelines
National Research Council (NRC) Publications
The NRC was established by the National Academy of Sciences in 1916 (9). It is not part of the United States government and is not an enforcement agency, but was expressly commissioned to provide advice to the U.S. government on scientific and technical matters. The activities of the NRC Committee on Animal Nutrition include the development of nutrient requirement standards for domestic and laboratory animals such as the Nutrient Requirements of Dogs and Cats 2006, written by the ad hoc Committee on dog and cat nutrition. The 2006 NRC publication provides a thorough review of the scientific literature and makes recommendations for both the minimum requirement and safe upper limit of intake of nutrients in healthy dogs and cats. Although the 2006 edition has added values of recommended allowances, nutrient availability and digestibility of pet foods processed with typical ingredients may still differ. While the publication is not used directly to establish regulatory standards for commercial pet foods, the recommendations contained in the NRC Nutrient Requirements of Dogs and Cats are considered by other organizations charged with that task (e.g., FEDIAF, AAFCO). It is an important source of research information on small animal nutrition, and is cited frequently in the scientific literature.
FEDIAF Nutrition Guidelines for Complete and Complementary Pet Food for Cats and Dogs
The Nutritional and Analytical Sciences Working Group of FEDIAF developed nutritional guidelines for cats and dogs, which are updated as soon as new scientific data become available. The objective is to provide practical nutrient recommendations for pet food manufacturers when formulating products for healthy dogs and cats during adulthood, growth and reproduction, and to be the reference document on pet nutrition in Europe for EU and local authorities, consumer organisations, professionals, and customers. The guidelines use NRC recommendations and studies published by internationally recognized nutritionists, veterinarians and other researchers. AAFCO official publications are also taken in consideration. The nutrient levels take into account the (lower) energy requirements of household pets and, where possible, availability data from practical pet foods. The FEDIAF Nutritional and Analytical Sciences Working Group cooperates with a Scientific Advisory Board of 10 leading nutritionists from different European universities.
Official Publication of the Association of American Feed Control Officials (AAFCO)]
In 1990 and 1991, AAFCO established the Canine Nutrition Expert (CNE) and Feline Nutrition Expert (FNE) subcommittees (18). The CNE and FNE subcommittees were charged with updating practical nutrient profiles for both dog and cat foods based on commonly used ingredients (2). The profiles are updated periodically, the last revision occurring in 2016. Under the AAFCO model regulations, meeting the AAFCO Dog and Cat Food Nutrient Profiles is one basis for substantiation of nutritional adequacy (complete and balanced) of a product for the designated life stage (2). The alternative means of ensuring nutritional adequacy of a food is either to perform feeding trials according to standardized feed testing methodology developed by AAFCO, or to formulate the product to meet the criteria as a member of a product family, i.e., a group of similar products whose lead member was demonstrated to be complete and balanced through passage of a feeding trial. All products sold as "complete and balanced" in the U.S.A. must substantiate nutritional adequacy through one of these methods, as no other nutritional authorities are recognized. Those that do not and are not prominently identified as a "snack," "treat" or "supplement" must bear the statement "This product is intended for intermittent or supplemental feeding only."