During the AAFCO Mid-Year meeting that took place from January 23rd to the 25th, a litany of ingredients saw regulatory changes. In tandem with the upcoming PFLM changes (read more here) many brands will require substantial changes to their packaging and potentially even marketing statements. Read on to find out if your business may be affected by these changes, and how you can be prepared for these changes.
It is now codified that particular fish must be named according to the FDA Seafood List using the accepted name or common name but NOT the scientific or vernacular name. One exception to the rule: Ocean Whitefish (allowed to describe white fleshed ocean fish, doesn’t have to only refer to tilefish as listed in the FDA Seafood List).
Collagen was on the agenda of the Ingredient Definition Committee meeting, to the excitement of many attendees. However, the brief report given only indicated that no firm has yet submitted a dossier to define collagen as an ingredient. The workgroup has drafted an ingredient definition, but are waiting for a company to submit it to begin approval. Knowing the length of time for most ingredient approvals, we are likely several years out before we see an ingredient definition for collagen.
Some ingredient names have been updated to align more closely with what the ingredient actually is. The new names were approved by membership with a sunsetting of the previous names in 2025. However, AFIA requested an extension for this change to align with the implementation period for PFLM in order for firms to avoid changing packaging now and again when they are ready to launch their PFLM compliant packaging. Because these are now official definitions, firms do have the ability to update their labels if they choose:
Corn gluten meal is now corn protein meal
Corn gluten feed is now corn protein feed
Grain sorghum gluten meal is now grain sorghum protein meal
Grain sorghum gluten feed is now grain sorghum protein feed
There is a new approved ingredient to be aware of:
Porcine oligosaccharides-peptides complex - source of amino acids, peptides and glycopeptides in food for cats and dogs, maximum inclusion 1.5%
These are in tentative status (not accepted by all states):
Black soldier fly larvae oil for use in cat food
Dried mealworm meal for use in adult dog food (30% maximum inclusion)
Dried chicory root pulp for all animals
Dried crickets for use in adult dog food
The Ingredient Definitions Committee passed some ingredient definitions that will be voted on by membership at the Annual AAFCO meeting in August.
Adult cats to the black soldier fly tentative definition.
Hemp seed meal tentative definition for laying hens (not for dogs or cats at this time)
Deboned fish protein tentative definition for all animals
Meat and bone meal new definition to be moved from tentative to official
A discussion about proper use of feed terms with defined ingredients was intended to educate regarding some practices that are in place in the industry that do not align with the regulations. Any process term that alters the nutritional content of an approved ingredient is not allowed unless there is already an approved definition. For example: “cultured potatoes” or “fermented oats” would not be allowed as the nutritional content of the cultured or fermented ingredient would be different from the original ingredient prior to undergoing the process. In addition, pomaces of approved ingredients are not allowed unless specifically defined. For example, blueberry pomace is not allowed whereas tomato pomace is.
The Pet Food Committee again discussed copper. No changes have been made to nutrient requirements regarding copper minimum or maximum levels for dogs. In addition, the ability of firms to use a “low copper” or “controlled copper” claim was voted down and the workgroup was disbanded. As more research becomes available, this topic likely will be revisited. Interestingly, the FDA is offering a webinar about this topic on February 8th so we may have more to share after attending.
An interesting discussion took place about calcium, phosphorus and the ratio between the two for cat foods. The Japanese Pet Food Authority requested that the FDA and AAFCO investigate whether changes should be made to the nutrient requirements for cats due to concerns regarding renal health. FEDIAF has established maximums and provides required ratio levels. The data used by FEDIAF to determine these values was submitted for review. An expert panel will be established to evaluate whether or not there should be changes to the nutrient profiles. I am sure there will be more to come on this topic!
All in all, the meeting was relatively uneventful, with no big surprises for those of us that are engaged in regular AAFCO topics. As always, we are here to assist with any regulatory questions or concerns that you may have. Reach out today!