By The Farmer's Dog | September 11, 2020

Food is one of the most important decisions we make for ourselves, and for our pets. The kinds of foods we eat influence all facets of health, so, many people are paying closer attention to where their food comes from.

But even those who ARE paying attention might not know what they’re really feeding their dogs if they’re feeding kibble or canned food because of the way the pet food industry makes, regulates, and labels its dog food products.

To help cut through the confusion and catchphrases and help dog owners make informed choices, we’ve assembled some answers to key questions about pet food standards. 

Is pet food regulated in the United States?

Technically, yes. But effectively, pet food skirts meaningful regulation.

There are two main bodies that have some say over how pet food is manufactured and labeled: the Food and Drug Administration (FDA) and the Association of American Feed Control Officials (AAFCO). But neither regulates pet food in the same way, or to the same standard, that our food is regulated. 

The FDA states, simply, that it “regulates that can of cat food, bag of dog food, or box of dog treats or snacks in your pantry.” But there’s nothing simple about the way that those regulations are actually developed and applied. 

The FDA doesn’t provide any pre-market approval for pet food products. The organization does specify some high-level animal-food standards—it’s responsible for inspections of pet food manufacturers and ingredient suppliers (excluding USDA-regulated suppliers), and investigations based on complaints from consumers. But in practice, the rules aren’t rigorously enforced. Inspections are infrequent, and even when egregious behavior is uncovered, the consequences amount to a warning and a written letter of acknowledgement. 

The State Departments of Agriculture also play a role in the regulation of pet food, but, like the FDA, don’t take an active role in enforcing laws, as would happen with human food. 

The FDA delegates the generation and publication of pet food rules to a body called The Association of American Feed Control Officials, or AAFCO. 

What is AAFCO?

AAFCO is a private, voluntary-membership organization in North America that deals with animal-feed regulations, including those for pet food. Pet owners may be familiar with AAFCO from seeing it on their pet food’s label, next to the assurance that the food is “complete and balanced.” The guidelines for meeting this standard relate only to the nutrient profile of the product—AAFCO sets guidelines for labeling requirements, ingredient definitions and nutritional requirements, not the state or source of the ingredients that have gone into making the product. 

AAFCO’s membership is made up of representatives from several North American agencies who enforce regulations (such as the state department of agriculture, FDA, and Canadian Food Inspection Agency), and while these members all have authority to regulate animal feed laws within their respective jurisdiction, AAFCO itself has no regulatory authority. 

Per the AAFCO site, “AAFCO does not approve, certify or otherwise endorse pet foods. There is no AAFCO-approved pet food.”

So what ARE pet food standards?

Pet “food”—the food you feed your dog every day of their 10, 12, 15, or more years of life —is subject to the same regulations (or, more accurately, lack of regulations), as commercial animal “feed.” Pet food companies can say on their labels that they are selling “food” and using “food” ingredients, while actually using feed-grade ingredients inside the bag or can. Those ingredients are subject to high-heat processing which kills pathogens, but in turn creates substances that are dangerous for dogs to eat (more on that later). 

Wait, so pet food isn’t technically food?

Not as far as FDA regulations go. Dog food is not subject to the same scrutiny, regulation, and rule-enforcement that applies to actual food. According to the U.S. Department of Agriculture (USDA), food has to be officially “edible” to be deemed safe for human consumption, which means it’s produced according to a set of FDA guidelines. Pet food, or feed, does not have to meet these standards, and does not have to be, officially, edible. 

So what is my dog actually eating when I buy a bag or can of pet food?

Edible food is made of USDA-approved meat. Conversely, “feed” can include meat that is expired, diseased, or contaminated with drugs.

Pet food—kibble and canned food—is typically made from parts of animals left over from the process of making human food. This can include hide, hair, bones, digestive systems, udders, beaks, and the like. But other stuff gets in there too. While diseased and other adulterated meats aren’t technically allowed in pet food, they can and do end up in kibble and canned food. How? Parts of sick animals, road kill, things like expired packs of meat (wrapping included), and restaurant grease may be used in pet food via the process of “rendering” (see sidebar below). The best example of a rendered product, and one that’s commonly found in commercial pet food, is “meal,” usually listed in the ingredients list as chicken meal or beef meal. 

Source: AAFCO

 

Because of the “feed” designation governing pet food, all manner of things that should not go into food, can be allowed into your dog’s food. 

The FDA says that “adulterated” food may be diverted into animal feed including: pesticide contamination in excess of typically allowed levels; contamination by industrial chemicals, “natural toxicants,” or filth, “unpermitted drug residues, or “rodent, roach, or bird excreta.”

Even euthanized animals, including pets, can make their way into kibble—along with the deadly drugs still in their systems. According to a November 2015 report by The Cornucopia Institute, a nonprofit national food and farm policy watchdog group,  loopholes in FDA regulations specify that “no regulatory action will be considered for animal feed ingredients resulting from the ordinary rendering process of industry, including those using animals which have died otherwise than by slaughter, provided they are not otherwise in violation of the law.” 

In plain terms, there are no regulations against using euthanized animals if they find their way into “feed” via the rendering process. And evidence shows that that’s exactly what happens—the FDA has found pentobarbital, the drug used to euthanize pets, in at least 30 different dog foods. 

Source: FDA

 

What is rendering? In the words of the National Rendering Association (the NRA), “Rendering is a process of both physical and chemical transformation,” involving “the application of heat, the extraction of moisture, and the separation of fat.” The rendering process converts the many by-products of agriculture, and other materials noted here (like expired meats and euthanized animals), into powder meals and liquid fats. About 85% of this product is utilized as animal feed ingredients.

What is “meal?” You’ve probably seen the words chicken meal, or meat meal on a bag of dry pet food. Meal is an end product of the rendering process and a staple of kibble. As defined by AAFCO, it’s “the rendered product from mammal tissues, exclusive of any added blood, hair, hoof, horn, hide trimmings, manure, stomach and rumen contents except in such amounts as may occur unavoidably in good processing practices.” That last part, “as may occur unavoidably” is a recurring loophole through which things (like plastic, flea collars, metal, and other substances) that are simply too hard to remove from the scraps about to be rendered may pass, and end up in the final product. Rendered protein meals are powders that go by the names meat meal, meat and bone meal, poultry meal, poultry byproduct meal and fish meal. Poultry byproduct meal includes “parts of the carcasses of slaughtered poultry such as necks, feet, undeveloped eggs and intestines.” Meat meal is so called because there’s no way to determine if the source was chicken, cow, or any number of the other animals that can end up in the render slurry.

Some of the conclusions from The Cornucopia Institute’s research into the pet food industry paint a dark picture of what many owners may unknowingly be feeding their pets. “The chase for convenience…has resulted in continuous, repeat exposure to potentially harmful ingredients,” the report says. “Pet food is highly processed, resulting in hidden and questionable ingredients.”

And that’s the other, equally important, part of the kibble puzzle. All kibble—including the “premium,” or boutique-brand variety–is ultra-processed food, and that high-heat process creates substances that can impact your dog’s health. Kibble has been found to contain heterocyclic amines, a chemical formed when meat is cooked at high temperatures, and a suspected carcinogen. A 2003 study analyzed 25 commercial pet foods and found “mutagenic activity” or carcinogens in 24 of them and posited a “connection between these heterocyclic amines and cancer in animals consuming these foods.”  A 2012 study found a type of heterocyclic amine, PhIP, in the fur of 14 out of 16 dogs tested. The process used to make kibble also produces acrylamide, a chemical formed via what’s called the Maillard Reaction, when starchy foods are cooked at high temperatures. The FDA has issued warnings about the substance, and recommended that it be reduced in (human) food because it’s been shown to cause cancer in lab animals, and can be “reasonably anticipated to be a human carcinogen.” The European Food Safety Authority has said that evidence from animal studies shows that acrylamide damages DNA and causes cancer.

Is all of this reflected on pet food labels?

No. Because of the lack of active, standardized regulation, pet food manufacturers can take advantage of labeling requirement loopholes.

On the front of a kibble bag, consumers might find glistening, meaty chicken breasts or marbled chunks of beef that look ready for the barbecue, rather than a depiction of the real ingredients used. But while these images may be misleading, people generally know to be skeptical of food photography. The real tricks are on the back of the bag. While food labels are typically where the truth of a product lies, they’re instead the most commonly manipulated part of pet food packaging.

The hidden and questionable nature of ingredients has come to light via studies and legal cases involving deceptive pet food labeling—cases in which the meats advertised on the bag don’t match what’s inside. And because all kibble looks like dried pellets, it’s impossible for a consumer to tell by looking at the product itself whether it contains any of the meats or vegetables on the labels. 

A company could legally and prominently label their product as “made with beef,” when a mere 3% of the product is a form of beef. 

There are many less-than-transparent tactics like this that companies can employ to make their food sound healthier and more appetizing than it is. For example, most people would reasonably conclude that the first ingredient on a nutritional facts label is the most abundant ingredient in the food (an ingredient label is organized by the weight of the ingredient—before cooking—in descending order). But this isn’t necessarily so. Knowing that most consumers are looking for a protein source as the top ingredient in their pet’s food, companies frequently manipulate ingredient lists via “ingredient splitting,” where they list ingredients broken down into composite parts. 

A product label containing 20% meat and 80% starches could either look like this:

Rice (30%), peas (30%), beef (20%), potatoes (20%)

Or this: 

Beef (10%), beef heart (10%), long grain rice (10%), brown rice (10%), white rice (10%), split peas (10%), pea protein (10%), English peas (10%), potato (10%), potato starch (10%)

With the ingredients segmented down to specific parts and now equal, beef can suddenly move into the coveted first-ingredient slot. 

What should a dog owner do? 

Just becoming aware of these kinds of tactics, and the realities of pet food making and marketing, is an important first step. By being aware of the code, and knowing how to decipher it, you’ll be able to make informed decisions about what you’re buying and feeding your dog. 

The most logical endpoint is to choose a food that’s made to food standards—that is, food that is “edible.” It’s the only reliable way to assure that what you’re feeding your dog is safe and suitable for a living creature that you want to live a long and healthy life.