Excerpt from an October, 1994 FDA Consumer Bulletin

Understanding Pet Food Labels

by David A. Dzanis, D.V.M., Ph.D

As Americans become more health conscious, they are reading food labels and choosing products more carefully. Many people are extending this scrutiny to food for their pets as well. Pet food labels are regulated by different rules than foods for human consumption, but reading and understanding a pet food label can help consumers make proper food choices for their pets, too.

Pet food labeling is regulated at two levels. The federal regulations, enforced by the Food and Drug Administration's Center for Veterinary Medicine, establish standards for all animal feeds: proper identification of the product, net quantity statement, manufacturer's address, and proper listing of ingredients. Some states also enforce their own labeling regulations. Many of these follow the model pet food regulations of the Association of American Feed Control Officials (AAFCO), a non-government advisory body with representatives from all states. These model regulations are more specific, covering aspects of labeling such as product name, guaranteed analysis, nutritional adequacy statement, feeding directions, and calorie statements.

Product Name

The product name is the first part of the label a consumer notices, and can be a key factor in the decision to buy a product. For that reason, manufacturers often use fanciful names or other techniques to emphasize a particular aspect. Many product names incorporate the name of an ingredient to highlight its presence in the product. Consumers are often confused, however, as to how much of a named ingredient is actually in the product. The percentages of named ingredients in the total product are dictated by four AAFCO model rules.

The first of these is the "95 percent" rule. It applies to products consisting primarily of meat, poultry or fish, such as some of the canned products. They have simple names, such as "Dave's Beef for Dogs." In this example, at least 95 percent of the named ingredient must be beef, exclusive of water for processing. Counting the added water, it still must comprise 70 percent of the product.

Since ingredient lists must be in the proper order of predominance by weight, "beef" 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 "Dave's Chicken 'n' Fish Cat Food," the two together must comprise 95 percent of the total weight, and there must be more chicken than fish.

The second rule, the "25 percent" or "dinner" rule, applies to many canned and dry products. If the named ingredient(s) comprise at least 25 percent of the product exclusive of water for processing, but less than 95 percent, the name must include a qualifying descriptive term, such as "Dave's Beef Dinner for Dogs." Many descriptors other than "dinner" are used, however. "Platter," "entrée," "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 the named ingredient, and may in fact be an undesired ingredient, the list should always be checked before purchase. For example, a cat owner may complain that her cat's "chicken dinner" smells like fish. She avoids buying fish, since her cat doesn't like it, but she is more concerned that the food might be spoiled. In reading the ingredient list, however, she discovers that the primary ingredient is indeed fish.

If more than one ingredient is included in a "dinner" name, they must total 25 percent and be listed in the same order as found on the ingredient list. Each named ingredient must be at least 3 percent of the total, too. Therefore, "Dave's Chicken 'n' Fish Dinner Cat Food" must have 25 percent chicken and fish, and at least 3 percent fish.

The third rule is the "3 percent" or "with" rule. It is intended to apply to ingredients highlighted on the label but which appear outside the product name. This allows manufacturers to point out the presence of minor ingredients that are not or cannot be added in sufficient quantity to merit a "dinner" claim. For example, a "Bacon Dinner," with 25 percent bacon, would not be feasible, nor would it most likely be palatable or nutritionally sound. However, both "Dave's Beef Dinner for Dogs" and "Dave's Chicken Dinner for Dogs" could include a side burst "with bacon" if at least 3 percent bacon is added. If the burst reads "with bacon and cheese," it must contain at least 3 percent bacon and 3 percent cheese.

Some manufacturers have been using the "with" designation as part of the product name, which may give the impression that more of an ingredient is present than really is. For example, one may not expect a "Dave's Dog Food with Beef" to contain as much as "Dave's Beef Dinner," but not as little as 3 percent. The AAFCO Pet Food Committee is considering new model regulations to address this issue.

Under the fourth rule or "flavor" 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 "Dave's 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 byproducts. Pet foods often contain "digests," which are materials treated with heat, enzymes and acids to form concentrated natural flavors. 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

It's important to check the net quantity statement when comparing products. Today, many canned products are sold in non-standardized sizes, so even though the products look the same, one may be a better buy. 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" with air.

When new federal regulations go into effect requiring "dual declarations" on pet food labels, not only will the customary "pound" or "ounce" declaration be made, but a unit of metric measurement, such as "kilogram" or "gram" ("kg" or "g") will also appear on the label. Many pet food labels already bear both measurements.

Manufacturer's Name and Address

The "manufactured by" statement identifies the party responsible for the quality and safety of the product and its location. A consumer who has a question or complaint about a product should not hesitate to contact the manufacturer. Many manufacturers also include an "800" telephone number on the label for consumer inquiries.

Ingredient List

As mentioned, ingredients are required to be listed in their proper order of predominance by weight. The weights of ingredients are determined as they are added in the formulation, with their inherent water content. This is important when evaluating relative quantity claims, especially when ingredients of different moisture contents are compared.

For example, one pet food may list "chicken" as its first ingredient, and "corn" as its second. The manufacturer doesn't hesitate to point out that its competitor lists "corn" first (chicken meal is second). However, chicken is very high in moisture (approximately 75 percent water). On the other hand, water and fat are removed from chicken meal, so it is only 10 percent moisture. Comparing both products on a dry matter basis, the second product has more chicken meal than the first product has chicken.

That is not to say that the second product has more chicken, or in fact, any chicken at all. Chicken meal is not chicken per se, since all 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 common 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 blood vessels which normally accompany the flesh." On the other hand, "meat meal" is "the rendered product from mammal tissues, exclusive of any added blood, hair, horn, hide trimmings, manure, stomach and rumen contents." Meat meal may not be very pleasing to think about eating, even though it's probably more nutritious, but the distinction must be made in the ingredient list.

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 include artificial colors, stabilizers, and preservatives. All must be either "Generally Recognized as Safe, (GRAS) or approved food additives for their intended uses. When there are health risks with an ingredient, FDA takes appropriate action. (See "When There Are Health Risks.")

Guaranteed Analysis

At minimum, a pet food label must state guarantees for minimum percentages of crude protein and crude fat, and maximum percentages of crude fiber and moisture. The "crude" term refers to the specific method of testing the product, not to the quality of the nutrient itself.

Some manufacturers include guarantees for other nutrients as well. Maximum ash is often guaranteed, especially on cat foods. Cat foods commonly bear guarantees for Taurine and magnesium as well. For dog foods, minimum levels of calcium, phosphorus, sodium, and linoleic acid are found on some products. If the guarantees don't include information on a particular nutrient that you're interested in, ask the company or don't buy the product.

The levels of crude protein and most other nutrients are much lower for the canned product than for a comparable dry product due to differences in moisture contents. Canned foods typically contain 75 to 78 percent moisture, while dry foods contain only 10 to 12 percent water. A rough approximation of comparable nutrient levels of a canned and dry product can be made by multiplying the guarantees for the canned product by four.

When buying a canned food, look at the moisture guarantee. The maximum moisture content for a pet food is 78 percent, except for products labeled as a "stew," "in sauce," "in gravy," or similar terms. The extra water gives the product the qualities necessary for appropriate texture and fluidity, but you are paying for it.

Nutritional Adequacy Statement

Manufacturers must substantiate the nutritional adequacy of a "complete and balanced" pet food by one of two means. By the first method, the pet food must contain ingredients formulated to provide nutrient levels established by the AAFCO dog or cat nutrient profile. (The recommendations of the National Research Council [NRC] are no longer used as the basis for nutritional adequacy. If a pet food label claims "meets or exceeds NRC," it means the product is old or the manufacturer has yet to comply with the new model regulations.)

The alternative means of substantiating nutritional adequacy is for the product to be tested following the AAFCO Feeding Trial Protocols. These products should bear a nutritional adequacy statement that begins, "Animal feeding tests þ." However, not all products that bear the claim are the ones actually tested. Some may be members of a "family" formulated to be nutritionally similar or superior to the product tested. Because of some concerns regarding the application of the family concept by manufacturers, AAFCO is considering new model regulations.

The nutritional adequacy statement also tells for which life stage(s) the product is suitable. 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 adult, 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 higher levels of nutrients are not harmful to the healthy adult animal, they are not really necessary.

Feeding Directions

Feeding directions tell how much of the product should be offered 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. However, feeding directions for other pet foods are much more elaborate, especially on dry product labels.

The feeding directions should be taken as rough guidelines. They tend to overestimate an animal's needs, possibly to make sure that highest calorie requirements (such as those of working dogs, pregnant and lactating dogs, and certain active breeds) are met. So don't be afraid to adjust portions to your pet's needs, especially if you feel it's gaining too much weight.

Calorie Statement

Until recently, calorie statements were not allowed on pet food labels. New AAFCO model regulations 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 equal to 2.2 pounds. Manufacturers may also express the calories in familiar household measurements (cup, pound) along with the required statement.

Other label statements are not required but sometimes appear on the label nonetheless (see "Premium? Natural? Light?").

Pet owners have a right to know what they are feeding their animals. The pet food label contains a wealth of information, if you know how to read it. Don't be swayed by marketing gimmicks or eye-catching claims. If you have a question about the product, contact the manufacturer, your state regulatory agency, or FDA.

--D.A.D.

David A. Dzanis is a veterinary nutritionist with FDA's Center for Veterinary Medicine.

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