Pet food labeling is regulated at two levels. The federal regulations, enforced by the United States Food and Drug Administration (FDA), establish standards applicable for all animal feeds: proper identification of product, net quantity statement, manufacturer’s name and address, and proper listing of ingredients. Some states also enforce their own labeling regulations. Many states have adopted the model pet food regulations established by the Association of American Feed Control Officials (AAFCO). These regulations are more specific in nature, covering aspects of labeling such as the product name, the guaranteed analysis, the nutritional adequacy statement, feeding directions, and calorie statements.
The percentages of named ingredients in the total product are dictated by four AAFCO rules.
1. 95% Rule: Applies to products consisting primarily of meat, poultry or fish, and most often are canned products. Names such as “Beef for Dogs” or “Tuna Cat Food.” require that at least 95% of the product must be the named ingredient (beef or tuna, respectively), not counting the water added for processing and “condiments.” When including the added water, the named ingredient still must comprise 70% of the product. Ingredient ists must be declared in the proper order of predominance by weight, “beef” or “tuna” should be the first ingredient listed, followed often by water, and then other components such as vitamins and minerals. Names that include a combination of ingredients, such as “Chicken ‘n Liver Dog Food,” require that the two named ingredients together must comprise 95% of the total weight. The first ingredient named in the product name must be the one of higher predominance in the product.
2. The “25%” or “dinner” rule. Applies to many canned and dry products. If the named ingredients comprise at least 25% of the product (not counting the water for processing), but less than 95%, the name must include a qualifying descriptive term, such as “Dinner” as in “Beef Dinner for Dogs.” Counting the added water, the named ingredients still must comprise 10% of the product. Many descriptors other than “dinner” are used, however, with “Platter,” “Entree,” “Nuggets” and “Formula” being a few examples. If more than one ingredient is included in a “dinner” name, the combination of the named ingredients must total 25% of the product and be listed in the same order as found on the ingredient list. Also, each named ingredient must be at least 3% of the total. Therefore, “Chicken n’ Fish Dinner Cat Food” must have 25% chicken and fish combined, and at least 3% fish. Also, unlike the “95%” rule, this rule applies to all ingredients, whether of animal origin or not. For example, a “Lamb and Rice Formula for Cats” would be an acceptable name as long as there was more lamb in the product than rice and the amounts of lamb and rice combined totaled 25%.
3. The “3%” or “with” rule was originally intended to apply only to ingredients highlighted on the principal display panel, but outside the product name, in order to allow manufacturers to point out the presence of minor ingredients that were not added in sufficient quantity to merit a “dinner” claim. For example, a “Cheese Dinner,” with 25% cheese, would not be feasible or economical to produce, but either a “Beef Dinner for Dogs” or “Chicken Formula Cat Food” could include a side burst “with cheese” if at least 3% cheese is added. The AAFCO model regulations now allow use of the term “with” as part of the product name, such as “Dog Food With Beef” or “Cat Food With Chicken.”
4. The “flavor” rule. Under this rule a specific percentage is not required, but a product must contain an amount sufficient to be able to be detected. In the example of “Beef Flavor Dog Food,” the word “flavor” must appear on the label in the same size, style and color as the word “beef.” The corresponding ingredient may be beef, but more often it is another substance that will give the characterizing flavor, such as beef meal or beef by-products.
With respect to flavors, pet foods often contain “digests,” which are materials treated with heat, enzymes and/or acids to form concentrated natural flavors. Only a small amount of a “chicken digest” is needed to produce a “Chicken Flavored Cat Food,” even though no actual chicken is added to the food. Stocks or broths are also occasionally added. Whey is often used to add a milk flavor. Often labels will bear a claim of “no artificial flavors.” Actually, artificial flavors are rarely used in pet foods. The major exception to that would be artificial smoke or bacon flavors, which are added to some treats.