Regulatory Changes - Are You Ready?

Did you know that there are numerous regulatory updates that were made and included in the 2016 AAFCO Official Publication (OP)? These changes require review of formulations and packaging updates. New products launched after January 1, 2016 must be compliant by January 1, 2017 while existing products in the marketplace prior to January 1, 2016 must be compliant by January 1, 2018. Despite typographical errors made in the printed OP as well as the online version, the compliance dates remain intact. 

Some of the new requirements in place at this time include:

1.     Every dog food that is labeled for all life stages or for growing puppies must have a new AAFCO statement.

2.     Nutrient requirements or ratios for 35 essential nutrients have been changed for growing puppies and pregnant or nursing adult dogs and 28 have changed for adult dogs. Particularly notable are the changes in minimum protein and fat levels for growth, maximum calcium for large breed puppies (greater than 70 lbs as an adult) and new maximum vitamin D levels. Use the green links to see the charts of changes.

3.     If you only make cat foods, you are not off the hook. Nutrient requirements for 20 essential nutrients for growth and reproduction and 15 for adult cats have been changed.

4     Puppy and kitten diets must contain a minimum level of a combination of the omega-3 fatty acids eicosapentaenoic acid (EPA) and docosahexaenoic acid (DHA). The amount required is 0.05% on a dry matter basis. This may require the addition of fish oil to many formulations. There are some non-fish sources of DHA, particularly algae based products. In the past, these ingredients have fallen under the Fat Product, Feed Grade definition. However, a vote to eliminate the current definition and replace it with one that is written in such a way that does not include algae sources of DHA. While the sustainability of fish oil has been a hot topic recently, these changes are going to either drive the industry to use much more fish oil or convert many all life stages diets to maintenance only. With the length of time it takes for a new ingredient to gain approval, algae products are running out of time to fill this void. 

Not so new, but still pertinent are requirements for calorie labeling not only on pet foods, but also on snacks, treats or supplements. The calories should not be included in the guaranteed analysis, but in their own section with the heading "Calorie Content". Calories are most commonly expressed as Calculated Metabolizable Energy and should be expressed not only as kcal/kg but also in a common unit such as cups for dry kibble, cans for canned product, pouches for pouch products and individual portions for treats or snacks.

A thorough review of formulations and packaging for compliance should be on the agenda for the upcoming months, particularly if you have new products in development or plans for relaunches that include any ingredient or guarantee changes, rendering them "new products" according to many states.