The AAFCO Annual meeting took place from August 6th to the 9th in San Antonio, Texas. Over 400 AAFCO committee members, FDA and industry met in person or virtually to discuss the agendas across the various meetings. In our previous blog, we discussed the ending of the MOU between AAFCO and the FDA. This wasn’t all that happened though, with several changes to new and existing ingredients.
First we have 3 ingredients with new Official definitions::
Black Soldier Fly Larvae Oil for use in adult cat food
Antarctic Krill Meal was approved as a new color additive but can only be used in freshwater and marine salmonid feed
Purified Yeast Cell Wall for use in all animals received a No Questions letter from FDA and will be added to Table 101.1
The Common Food Index is a relatively new feature that AAFCO has put into place to provide a list of foods that might be commonly used and not have any safety concerns but are not specifically defined. Not all states will accept ingredients listed in the CFI and with the decision not to renew the MOU between AAFCO and the FDA, it will be interesting to see what happens to the ingredients found in the CFI.
The following are new items for inclusion to the Common Food Index:
Rice (Orzya sativa varietals), Butternut squash, Collard greens, King oyster mushrooms, Bell pepper, Okra and Maitake mushroom
Definitions that will be voted on to move to Official status by the Board at the AAFCO meeting in January 2025:
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
Black soldier fly larvae oil for use in adult cat food
Clam Meal for use in non-salmonid finfish feed
Ingredients in tentative status (not accepted by all states):
Hempseed Meal, Mechanically Extracted is the first hemp-derived ingredient to be approved as a Tentative definition by AAFCO. It can only be used in diets of laying hens as a source of protein and fat.
Deboned Fish Protein for all animals
Black Soldier Fly Larvae for use in adult cat food
Taxonomic reclassification:
In section 36.14, Lactobacillus animalis will be renamed to Ligilactobacillus animalis
Microorganism Corynebacterium lilium reclassified to Corynebacterium glutamicum. The current ingredient definition 36.1 in the 2024 AAFCO OP includes both Corynebacterium lilium and Corynebacterium glutamicum. Ingredient definition 36.1 of the AAFCO OP shall be amended by deleting Corynebacterium lilium to reflect the updated nomenclature
Creating definitions for Fish and Shellfish was not discussed in this meeting and will be placed on the agenda for October after the workgroup revises the definitions that were previously created. If you aren’t aware, there are no current definitions for “fish” or “shellfish” like there are for meat and poultry.
Copper Workgroup: The Pet Food Committee disbanded the copper workgroup after a virtual meeting where a proposed regulation to establish a voluntary “controlled copper” claim for dog food was voted against due to insufficient data and lack of scientific basis.
Human Grade Claims: The FAQ document regarding human grade claims was approved and is expected to be posted on the AAFCO website in approximately 60 days.
Calcium to Phosphorus Ratio for Cat Food: At the 2024 Mid-year meeting in January, Dr. Burkholder from FDA-CVM was tasked with forming an expert panel to investigate whether there should be a range for the Calcium to phosphorus ratio in the Cat Food Nutrient Profiles and a maximum level of phosphorus due to recent literature suggesting that different phosphorus sources have varying impacts on renal health in cats. The panel is considering setting both a minimum and maximum calcium to phosphorus ratio and a maximum phosphorus level for cat foods. Further discussions will continue, with updates anticipated by the 2025 Mid-Year meeting.
Nutrient Profile Review: A workgroup was formed to explore the feasibility of a routine review of the Nutrient Profiles and the historical context of their creation. The goal is to present a report with a recommendation by the AAFCO Mid-Year Meeting in 2025.
PFLM Implementation: The PFLM Implementation survey for the states reported 43 of the 50 states responded to the survey. A few of the state obstacles include: state labs not being able to test for dietary fiber, some states will not start the process until the PURR Act is passed or defeated, legislation process to add new regulations to state laws is complicated and some states said it is not a top priority.
2 states have implemented PFLM - North and South Dakota finished the process to adopt the modernized regulations
21 states will be implementing within the next two years (12 states have started the process)
4 states will be implementing in 2027-2028
6 states will be implementing in 2028-2030
10 states have no implementation date
6 states have already received labels following the new regulations of PFLM. Although these states have not yet incorporated the new regulations into their state laws, they are using regulatory discretion to accept the new format. Some of these states have mentioned that there are errors on the labels so having a thorough regulatory review prior to using the new format is very important. One thing mentioned is that some brands are using a mashup of the old regulations and new regulations, which is not allowed. The labels have to be in either the old format or new format, not a combination of the two.
Uniform Licensing and Registration: The Enforcement Issues Committee discussed uniformity in licensing, registration and tonnage schedules. Unfortunately, there was not much discussion, and most states did not participate in the discussion. The variations are largely dictated by state laws, so uniformity might not be achieved soon.
Enforcement Discretion and Sunset Date in the 2025 OP for Corn Gluten/Protein Meal: Industry representatives requested that states use enforcement discretion to minimize the number of label updates required for PFLM changes, particularly regarding the transition from corn gluten meal to corn protein meal.
Overall, the meeting highlighted ongoing regulatory updates and challenges in the pet food industry, with significant developments expected in the coming years. Remember that we are staying on top of regulatory changes and hot topics in order to help you navigate this challenging space. Contact us today!