Important Changes to the AAFCO Pet Food Model Regulations
The Association of American Feed Control Officials (AAFCO) recently sent out an email requesting comments on the draft model pet food regulations. This is the Pet Food Label Modernization (PFLM) that has been in the works for years. AAFCO is requesting feedback by email by October 31st. I encourage you to review the regulations and submit any changes to PFC@aafco.org in order to allow your voice to be heard.
Here is the link to the complete document: https://www.aafco.org/Portals/0/SiteContent/Regulatory/Committees/Pet-Food/Draft-Model_Pet_Food_Regulations-9-28-22.pdf
Below is a summary of some of the proposed changes to be made (apologies for the length, but there are quite a few changes coming your way). If you want to reach out to me to submit requested revisions on your behalf, please send me an email at nre@northriverenterprises.com. I have begun a list of questions/clarifications and requested changes and will be submitting them prior to the deadline.
Regulation PF1 Definitions and Terms has 6 new terms added and defined: Pet Nutrition Facts, Specialty Pet Nutrition Facts, Veterinary Diet, Food supplement, Food Mixer and Daily Food.
The nutrition facts terms indicate the new graphic box that includes nutritional information (replacing the current Guaranteed Analysis).
Veterinary diets are intended to be used under veterinary supervision only.
Food supplement is a product that is intended to supply specific nutrients or food components, but is not a complete diet.
Food mixer is a product intended to accompany or contribute to a complete diet but is not generally intended to be a complete diet.
Daily food pertains to specialty pet foods with no recognized nutritional authority.
Regulation PF2 Label Format and Labeling has been changed to replace the Guaranteed Analysis with the Pet Nutrition Facts or Specialty Pet Nutrition Facts. The Calorie Content statement is no longer listed as part of PF2 because it is becoming part of the Pet Nutrition Facts box. The maximum moisture of 78% and accompanying requirement for indicating higher moisture with terms such as “broth”, “stew”, etc was moved from PF4 to PF2 but no other changes were made.
Regulation PF4 Intended Use and Nutritional Adequacy Claims has significant changes. The use of quotes indicates a requirement for verbatim language. For foods that are complete and balanced for all life stages and sizes, the verbiage on the principal display panel (PDP) shall be: “Complete (Species) Food”. So a dog food that is complete and balanced for all life stages, including growth of large breed puppies, will need to say, “Complete Dog Food” on the PDP. For a food that is not complete and balanced for all life stages, there are examples given for acceptable intended use statements. These all begin with “Complete Food for [blank]. The examples for [blank] are listed below:
“Adult [Species]”
“Puppies”, “Kittens” or Growing [species other than dog or cat]
“Puppies < 70 lbs as an adult”
“Dogs except puppies > 70 lbs as an adult”
There are alternate options available to use the “Complete [Blank] Food” using the singular of puppy, kitten and dog in examples 2-4 above.
For veterinary diets, treats, food supplements and food mixers, the specific intended use language must be used.
The intended use statement will need to be in the bottom 30% of the label panel and generally parallel to the base of the label. For labels that are less than 5 square inches, the intended use does not have to be in the bottom 30% of the label. It must be as large as the statement of net quantity, of which the size is determined by FDA guidelines. The intended use statement must be in the same color and style and on the same background color as the statement of net quantity. It must also be separated from any other printed label information by a distance equal to the height of the “N” in net and twice the width of the “N” in net.
Regulation PF5 Pet and Specialty Pet Nutrition Facts will replace the Guaranteed Analysis that we all know and love.
There are specific requirements for this box from a stylistic perspective. The box must be prominent and shall be all black or single color type printed on white or other neutral contrasting background with the heading “Pet Nutrition Facts” that is centered in the top row of the box and twice the size of all other text in the box. A hairline rule must separate “Pet Nutrition Facts” from the next line of text.
Under the heading (right justified) will be the familiar household unit for the product (such as cup, treat, etc). Grams per familiar household unit must be included. Example: 1 cup (110 grams).
Under this should be a bold line followed by the calorie content which is just below the Calorie content heading which must be left justified. Calories will now be declared per common household unit and no longer in kcal/kg.
Below the calorie content statement, the number of calories from Protein, Fat and Carbohydrate must be declared. Changes to nutrient guarantees include removing “crude” from protein, fat and fiber guarantees.
Required guarantees will be Protein, Fat, Total Carbohydrate, Dietary Fiber and Moisture. Total Carbohydrate and Dietary Fiber will be max guarantees.
Any non-essential guarantees should be separated from other guarantees by a hairline.
Below the nutrition facts, a bold line should separate this information from the nutritional adequacy statement, which has not changed from current regulations.
For small packages with printable area less than 40 square inches, the required information can be linear, instead of in a box.
Regulation PF6 Ingredients has a few additions to it.
Ingredients consisting of fish, fish parts or “fish ___” from one or more fish species, the name must be an accurate description of the fish used. “White fish” is specifically mentioned and I know this one has been a headache for many brands since the FDA seafood list has specific defined species that are “whitefish”. So add a space and any white-fleshed fish can be called “white fish”. The FDA Seafood List is mentioned as the resource for correcting naming purposes.
Sugar refers to sucrose obtained from sugar cane or sugar beets. For all other labeling purposes, “sugar” will be synonymous with “sugars” from the Official Feed Terms.
The term “organic” is specifically allowed for within the ingredient list with proper substantiation. You still cannot claim that the food is made with organic ingredients unless the product itself is certified organic, but can call attention to organic ingredients in the ingredient listing.
Regulation PF12 Handling and Storage Instructions. If handling and storage instructions are included on a package, they must be under a bolded header, “Handling and Storage Instructions” unless the total printable label is less than 40 square inches and then the header is not required. If any graphics are used to support handling and storage instructions, only the graphics from the AAFCO website can be used. There are minimum size requirements for handling and storage instructions.