|
Interpreting Pet Food Labels
The following
consumer information is provided by David A. Dzanis, DVM,
Ph.D., DACVN.
Pet food labeling is
regulated at two levels. The Federal regulations,
enforced by the FDA's Center for Veterinary Medicine (CVM),
establish standards applicable for all animal feeds:
proper identification of product, net quantity
statement, manufacturer's address, and proper listing of
ingredients. Some States also enforce their own labeling
regulations. Many of these have adopted the 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.
Product Name
The product name is
the first part of the label noticed by the consumer, and
can be a key factor in the consumer's decision to buy
the product. For that reason, manufacturers often use
fanciful names or other techniques to emphasize a
particular aspect. Since many consumers purchase a
product based on the presence of a specific ingredient,
many product names incorporate the name of an ingredient
to highlight its inclusion in the product. The
percentages of named ingredients in the total product
are dictated by four AAFCO rules.
The "95%" rule
applies to products consisting primarily of meat,
poultry or fish, such as some of the canned products.
They have simple names, such as "Beef for Dogs" or "Tuna
Cat Food." In these examples, at least 95% of the
product must be the named ingredient (beef or tuna,
respectively), not counting the water added for
processing and "condiments." Counting the added water,
the named ingredient still must comprise 70% of the
product. Since ingredient lists 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. If the name includes a combination of
ingredients, such as "Chicken 'n Liver Dog Food," the
two 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. For example,
the product could not be named "Lobster and Salmon for
Cats" if there is more salmon than lobster in the
product. Because this rule only applies to ingredients
of animal origin, ingredients that are not from a meat,
poultry or fish source, such as grains and vegetables,
cannot be used as a component of the 95% total. For
example, a "Lamb and Rice Dog Food" would be misnamed
unless the product was comprised of at least 95% lamb.
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 "Beef Dinner for Dogs." Many descriptors
other than "dinner" are used, however. "Platter,"
"entree," "nuggets" and "formula" are just a few
examples. Because, in this example, only one-quarter of
the product must be beef, it would most likely be found
third or fourth on the ingredient list. Since the
primary ingredient is not always the named ingredient,
and may in fact be an ingredient that is not desired,
the ingredient list should always be checked before
purchase. For example, a cat owner may have learned from
his or her finicky feline to avoid buying products with
fish in it, since the cat doesn't like fish. However, a
"Chicken Formula Cat Food" may not always be the best
choice, since some "chicken formulas" may indeed contain
fish, and sometimes may contain even more fish than
chicken. A quick check of the ingredient list would
avert this mistake.
If more than one
ingredient is included in a "dinner" name, they must
total 25% and be listed in the same order as found on
the ingredient list. Each named ingredient must be at
least 3% of the total, too. 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
the amounts of lamb and rice combined totaled 25%.
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.
Recent amendments to the AAFCO regulations now allow use
of the term "with" as part of the product name, too,
such as "Dog Food With Beef" or "Cat Food With Chicken."
Now, even a minor change in the wording of the name has
a dramatic impact on the minimum amount of the named
ingredient required, e.g., a can of "Cat Food With Tuna"
could be confused with a can of "Tuna Cat Food," but,
whereas the latter example must contain at least 95%
tuna, the first needs only 3%. Therefore, the consumer
must read labels carefully before purchase to ensure
that the desired product is obtained.
Under the "flavor"
rule, a specific percentage is not required, but a
product must contain an amount sufficient to be able to
be detected. There are specific test ods, using animals
trained to prefer specific flavors, that can be used to
confirm this claim. 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.
Net Quantity
Statement
The net quantity
statement tells you how much product is in the
container. There are many FDA regulations dictating the
format, size and placement of the net quantity
statement. None of these do any good if the consumer
does not check the quantity statements, especially when
comparing the cost of products. For example, a 14-ounce
can of food may look identical to the one-pound can of
food right next to it. Also, dry products may differ
greatly in density, especially some of the "lite"
products. Thus, a bag that may typically hold 40 pounds
of food may only hold 35 pounds of a food that is
"puffed up." A cost-per-ounce or per-pound comparison
between products is always prudent. Manufacturer's
Name and Address The "manufactured by..."
statement identifies the party responsible for the
quality and safety of the product and its location. If
the label says "manufactured for..." or "distributed
by...," the food was manufactured by an outside
manufacturer, but the name on the label still designates
the responsible party. Not all labels include a street
address along with the city, State, and zip code, but by
law, it should be listed in either a city directory or a
telephone directory. Many manufacturers also include a
toll-free number on the label for consumer inquiries. If
a consumer has a question or complaint about the
product, he or she should not hesitate to use this
information to contact the responsible party.
Ingredient List All ingredients are required to
be listed in order of predominance by weight. The
weights of ingredients are determined as they are added
in the formulation, including their inherent water
content. This latter fact is important when evaluating
relative quantity claims, especially when ingredients of
different moisture contents are compared.
For example, one pet
food may list "meat" as its first ingredient, and "corn"
as its second. The manufacturer doesn't hesitate to
point out that its competitor lists "corn" first ("meat
meal" is second), suggesting the competitor's product
has less animal-source protein than its own. However,
meat is very high in moisture (approximately 75% water).
On the other hand, water and fat are removed from meat
meal, so it is only 10% moisture (what's left is mostly
protein and minerals). If we could compare both products
on a dry matter basis (mathematically "remove" the water
from both ingredients), one could see that the second
product had more animal-source protein from meat meal
than the first product had from meat, even though the
ingredient list suggests otherwise.
That is not to say
that the second product has more "meat" than the first,
or in fact, any meat at all. Meat meal is not meat
per se, since most of the fat and water have been
removed by rendering. Ingredients must be listed by
their "common or usual" name. Most ingredients on pet
food labels have a corresponding definition in the AAFCO
Official Publication. For example, "meat" is defined as
the "clean flesh of slaughtered mammals and is limited
to...the striate muscle...with or without the
accompanying and overlying fat and the portions of the
skin, sinew, nerve and vessels which normally accompany
the flesh." On the other hand, "meat meal" is "the
rendered product from mammal tissues, exclusive of any
added , hair, horn, hide trimmings, manure, stomach and
rumen contents." Thus, in addition to the processing, it
could also contain parts of animals one would not think
of as "meat." Meat meal may not be very pleasing to
think about eating yourself, even though it's probably
more nutritious. Animals do not share in people's
aesthetic concerns about the source and composition of
their food. Regardless, the distinction must be made in
the ingredient list (and in the product name). For this
reason, a product containing "lamb meal" cannot be named
a "Lamb Dinner."
Further down the
ingredient list, the "common or usual" names become less
common or usual to most consumers. The majority of
ingredients with chemical-sounding names are, in fact,
vitamins, minerals, or other nutrients. Other possible
ingredients may include artificial colors, stabilizers,
and preservatives. All should be either "Generally
Recognized As Safe (GRAS)" or approved food additives
for their intended uses.
If scientific data
are presented that show a health risk to animals of an
ingredient or additive, CVM can act to prohibit or
modify its use in pet food. For example, propylene
glycol was used as a humectant in soft-moist pet foods,
which helps retain water and gives these products their
unique texture and taste. It was affirmed Generally
Recognized As Safe (GRAS) for use in human and animal
food before the advent of soft-moist foods. It was known
for some time that propylene glycol caused Heinz Body
formation in the red cells of cats (small clumps of
proteins seen in the cells when viewed under the
microscope), but it could not be shown to cause overt
anemia or other clinical effects. However, recent
reports in the veterinary literature of scientifically
sound studies have shown that propylene glycol reduces
the red cell survival time, renders red cells more
susceptible to oxidative damage, and has other adverse
effects in cats consuming the substance at levels found
in soft-moist food. In light of this new data, CVM
amended the regulations to expressly prohibit the use of
propylene glycol in cat foods.
Another pet food
additive of some controversy is ethoxyquin, which was
approved as a food additive over thirty-five years ago
for use as an antioxidant chemical preservative in
animal feeds. Approximately ten years ago, CVM began
receiving reports from dog owners attributing the
presence of ethoxyquin in the dog food with a myriad of
adverse effects, such as allergic reactions, skin
problems, major organ failure, behavior problems, and
cancer. However, there was a paucity of available
scientific data to support these contentions, or to show
other adverse effects in dogs at levels approved for use
in dog foods. More recent studies by the manufacturer of
ethoxyquin showed a dose-dependent accumulation of a
hemoglobin-related pigment in the liver, as well as
increases in the levels of liver-related enzymes in the
. Although these changes are due to ethoxyquin in the
diet, the pigment is not made from ethoxyquin itself,
and the health significance of these findings is
unknown. More information on the utility of ethoxyquin
is still needed in order for CVM to amend the maximum
allowable level to below that which would cause these
effects, but which still would be useful in preserving
the food. While studies are being conducted to ascertain
a more accurate minimum effective level of ethoxyquin in
dog foods, CVM has asked the pet food industry to
voluntarily lower the maximum level of use of ethoxyquin
in dog foods from 150 ppm (0.015%) to 75 ppm.
Regardless, most pet foods that contained ethoxyquin
never exceeded the lower amount, even before this
recommended change.
Guaranteed
Analysis
At minimum, a pet
food label must state guarantees for the minimum
percentages of crude protein and crude fat, and the
maximum percentages of crude fiber and moisture. The
"crude" term refers to the specific od of testing the
product, not to the quality of the nutrient itself.
Some manufacturers
include guarantees for other nutrients as well. The
maximum percentage of ash (the mineral component) is
often guaranteed, especially on cat foods. Cat foods
commonly bear guarantees for taurine and magnesium as
well. For dog foods, minimum percentage levels of
calcium, phosphorus, sodium, and linoleic acid are found
on some products.
Guarantees are
declared on an "as fed" or "as is" basis, that is, the
amounts present in the product as it is found in the can
or bag. This doesn't have much bearing when the
guarantees of two products of similar moisture content
are compared (for example, a dry dog food versus another
dry dog food). However, when comparing the guaranteed
analyses between dry and canned products, one will note
that the levels of crude protein and most other
nutrients are much lower for the canned product. This
can be explained by looking at the relative moisture
contents. Canned foods typically contain 75-78%
moisture, whereas dry foods contain only 10-12% water.
To make meaningful comparisons of nutrient levels
between a canned and dry product, they should be
expressed on the same moisture basis.
The most accurate
means of doing this is to convert the guarantees for
both products to a dry matter basis. The percentage of
dry matter of the product is equal to 100% minus the
percentage of moisture guaranteed on the label. A dry
food is approximately 88-90% dry matter, while a canned
food is only about 22-25% dry matter. To convert a
nutrient guarantee to a dry matter basis, the percent
guarantee should be divided by the percentage of the dry
matter, then multiplied by 100. For example, a canned
food guarantees 8% crude protein and 75% moisture (or
25% dry matter), while a dry food contains 27% crude
protein and 10% moisture (or 90% dry matter). Which has
more protein, the dry or canned? Calculating the dry
matter protein of both, the canned contains 32% crude
protein on a dry matter basis (8/25 X 100 = 32), while
the dry has only 30% on a dry matter basis (27/90 X 100
= 30). Thus, although it looks like the dry has a lot
more protein, when the water is counted out, the canned
actually has a little more. An easier way is to remember
that the amount of dry matter in the dry food is about
four times the amount in a canned product. To compare
guarantees between a dry and canned food, multiply the
guarantees for the canned food times four first.
It is especially
important to look at the moisture guarantee for canned
foods, even when comparing a canned food with another
canned. Under AAFCO regulations, the maximum percentage
moisture content for a pet food is 78%, except
for products labeled as a "stew," "in sauce," "in
gravy," or similar terms. The extra water gives the
product the qualities needed to have the appropriate
texture and fluidity. Some of these exempted products
have been found to contain as much as 87.5% moisture.
This doesn't sound like much difference until the dry
matter contents are compared. For example, a product
with a guarantee of 87.5% moisture contains 12.5% dry
matter, only half as much as a product with a 75%
moisture guarantee (25% dry matter).
Nutritional
Adequacy Statement
Any claim that a
product is "complete," "balanced," "100% nutritious," or
similarly suggests that a product is suitable for sole
nourishment that is not, in fact, nutritionally adequate
is a potentially unsafe product. For this reason, an
AAFCO nutritional adequacy statement is one of the most
important aspects of a dog or cat food label. A
"complete and balanced" pet food must be substantiated
for nutritional adequacy by one of two means.
The first od is for
the pet food to contain ingredients formulated to
provide levels of nutrients that meet an established
profile. Presently, the AAFCO Dog or Cat Food Nutrient
Profiles are used. Products substantiated by this od
should include the words, "(Name of product) is
formulated to meet the nutritional levels established by
the AAFCO (Dog/Cat) Food Nutrient Profiles." This means
the product contains the proper amount of protein,
calcium, and other recognized essential nutrients needed
to meet the needs of the healthy animal. The
recommendations of the National Research Council (NRC)
were once used as the basis for nutritional adequacy,
but they are no longer considered valid for this
purpose.
The alternative means
of substantiating nutritional adequacy is for the
product to be tested following the AAFCO Feeding Trial
Protocols. This means that the product, or "lead" member
of a "family" of products, has been fed to dogs or cats
under strict guidelines and found to provide proper
nutrition. These products should bear the nutritional
adequacy statement "Animal feeding tests using AAFCO
procedures substantiate that (name of product) provides
complete and balanced nutrition."
Regardless of the od
used, the nutritional adequacy statement will also state
for which life stage(s) the product is suitable, such as
"for maintenance," or "for growth." A product intended
"for all life stages" meets the more stringent
nutritional needs for growth and reproduction. A
maintenance ration will meet the needs of an ,
non-reproducing dog or cat of normal activity, but may
not be sufficient for a growing, reproducing, or
hard-working animal. On the other hand, an all life
stages ration can be fed for maintenance. Although the
higher levels of nutrients would not be harmful to the
healthy animal, they are not really necessary.
Occasionally a product may be labeled for a more
specific use or life stage, such as "senior" or for a
specific size or breed. However, there is little
information as to the true dietary needs of these more
specific uses, and no rules governing these types of
statements have been established. Thus, a "senior" diet
must meet the requirements for maintenance, but no more.
A product that does not meet either of these ods must
state that "this product is intended for intermittent or
supplemental feeding," except if it is conspicuously
identified as a snack or treat.
Feeding
Directions
Feeding directions
instruct the consumer on how much product should be
offered to the animal. At minimum, they should include
verbiage such as "feed ___ cups per ___ pounds of body
weight daily." On some small cans, this may be all the
information that can fit. The feeding directions should
be taken as rough guidelines, a place to start. Breed,
temperament, environment, and many other factors can
influence food intake. Manufacturers attempt to cover
almost all contingencies by setting the directions for
the most demanding. The best suggestion is to offer the
prescribed amount at first, and then to increase or cut
back as needed to maintain body weight in s or to
achieve proper rate of gain in puppies and kittens. A
nursing mother should be offered all the food she wants
to eat. Calorie Statement Pet foods can
vary greatly in calorie content, even among foods of the
same type (dry, canned) and formulated for the same life
stage. Feeding directions vary among manufacturers, too,
so the number of calories delivered in a daily meal of
one food may be quite different from another. The number
of calories in a product roughly relates to the amount
of fat, although varying levels of
non-calorie-containing components, such as water and
fiber, can throw this correlation off. The best way for
consumers to compare products and determine how much to
be fed is to know the calorie content. However, until
recently, calorie statements were not allowed on pet
food labels. New AAFCO regulations were developed to
allow manufacturers to substantiate calorie content and
include a voluntary statement.
If a calorie
statement is made on the label, it must be expressed on
a "kilocalories per kilogram" basis. Kilocalories are
the same as the "Calories" consumers are used to seeing
on food labels. A "kilogram" is a unit of metric
measurement equal to 2.2 pounds. Manufacturers are also
allowed to express the calories in familiar household
units along with the required statement (for example,
"per cup" or "per can"). Even without this additional
information, however, consumers can make meaningful
comparisons between products and pick the product best
suited for their animals' needs. As with the guaranteed
analysis, the calorie statement is made on an "as fed"
basis, so corrections for moisture content must be made
as described above. To roughly compare the caloric
content values between a canned and a dry food, multiply
the value for the canned food by four.
Other Label
Claims
Many pet foods are
labeled as "premium," and some now are "super premium"
and even "ultra premium." Other products are touted as
"gourmet" items. Products labeled as premium or gourmet
are not required to contain any different or higher
quality ingredients, nor are they held up to any higher
nutritional standards than are any other complete and
balanced products.
The term "natural" is
often used on pet food labels, although that term does
not have an official definition either. For the most
part, "natural" can be construed as equivalent to a lack
of artificial flavors, artificial colors, or artificial
preservatives in the product. As mentioned above,
artificial flavors are rarely employed anyway.
Artificial colors are not really necessary, except to
please the pet owner's eye. If used, they must be from
approved sources, the same as for human foods.
Especially for high-fat dry products, some form of
preservative must be used to prevent rancidity.
Natural-source preservatives, such as mixed tocopherols
(a source of vitamin E), can be used in place of
artificial preservatives. However, they may not be as
effective.
"Natural" is not the
same as "organic." The latter term refers to the
conditions under which the plants were grown or animals
were raised. There are no official rules governing the
labeling of organic foods (for humans or pets) at this
time, but the United States Department of Agriculture is
developing regulations dictating what types of
pesticides, fertilizers and other substances can be used
in organic farming.
Summary
Pet owners and
veterinary professionals have a right to know what they
are feeding their animals. The pet food label contains a
wealth of information, if one knows how to read it. Do
not be swayed by the many marketing gimmicks or
eye-catching claims. If there is a question about the
product, contact the manufacturer or ask an appropriate
regulatory agency.
|
