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INFORMATION FOR CONSUMERS

FOOD AND DRUG ADMINISTRATION

CENTER FOR VETERINARY MEDICINE 

INTERPRETING PET FOOD LABELS 

The following consumer information is provided by David A. Dzanis, DVM,
Ph.D., DACVN.

Pet food labeling is regulated at two levels. The Federal regulations,
enforced by the FDA's Center for Veterinary Medicine (CVM), establish
standards applicable for all animal feeds: proper identification of
product, net quantity statement, manufacturer's address, and proper
listing of ingredients. Some States also enforce their own labeling
regulations. Many of these have adopted the model pet food regulations
established by the Association of American Feed Control Officials
(AAFCO). These regulations are more specific in nature, covering aspects
of labeling such as the product name, the guaranteed analysis, the
nutritional adequacy statement, feeding directions, and calorie
statements. 

Product Name

The product name is the first part of the label noticed by the consumer,
and can be a key factor in the consumer's decision to buy the product.
For that reason, manufacturers often use fanciful names or other
techniques to emphasize a particular aspect. Since many consumers
purchase a product based on the presence of a specific ingredient, many
product names incorporate the name of an ingredient to highlight its
inclusion in the product. The percentages of named ingredients in the
total product are dictated by four AAFCO rules. 

The "95%" rule applies to products consisting primarily of meat, poultry
or fish, such as some of the canned products. They have simple names,
such as "Beef for Dogs" or "Tuna Cat Food." In these examples, at least
95% of the product must be the named ingredient (beef or tuna,
respectively), not counting the water added for processing and
"condiments." Counting the added water, the named ingredient still must
comprise 70% of the product. Since ingredient lists must be declared in
the proper order of predominance by weight, "beef" or "tuna" should be
the first ingredient listed, followed often by water, and then other
components such as vitamins and minerals. If the name includes a
combination of ingredients, such as "Chicken 'n Liver Dog Food," the two
together must comprise 95% of the total weight. The first ingredient
named in the product name must be the one of higher predominance in the
product. For example, the product could not be named "Lobster and Salmon
for Cats" if there is more salmon than lobster in the product. Because
this rule only applies to ingredients of animal origin, ingredients that
are not from a meat, poultry or fish source, such as grains and
vegetables, cannot be used as a component of the 95% total. For example,
a "Lamb and Rice Dog Food" would be misnamed unless the product was
comprised of at least 95% lamb. 

The "25%" or "dinner" rule applies to many canned and dry products. If
the named ingredients comprise at least 25% of the product (not counting
the water for processing), but less than 95%, the name must include a
qualifying descriptive term, such as "Beef Dinner for Dogs." Many
descriptors other than "dinner" are used, however. "Platter," "entree,"
"nuggets" and "formula" are just a few examples. Because, in this
example, only one-quarter of the product must be beef, it would most
likely be found third or fourth on the ingredient list. Since the
primary ingredient is not always the named ingredient, and may in fact
be an ingredient that is not desired, the ingredient list should always
be checked before purchase. For example, a cat owner may have learned
from his or her finicky feline to avoid buying products with fish in it,
since the cat doesn't like fish. However, a "Chicken Formula Cat Food"
may not always be the best choice, since some "chicken formulas" may
indeed contain fish, and sometimes may contain even more fish than
chicken. A quick check of the ingredient list would avert this mistake. 

If more than one ingredient is included in a "dinner" name, they must
total 25% and be listed in the same order as found on the ingredient
list. Each named ingredient must be at least 3% of the total, too.
Therefore, "Chicken n' Fish Dinner Cat Food" must have 25% chicken and
fish combined, and at least 3% fish. Also, unlike the "95%" rule, this
rule applies to all ingredients, whether of animal origin or not. For
example, a "Lamb and Rice Formula for Cats" would be an acceptable name
as long as the amounts of lamb and rice combined totaled 25%. 

The "3%" or "with" rule was originally intended to apply only to
ingredients highlighted on the principal display panel, but outside the
product name, in order to allow manufacturers to point out the presence
of minor ingredients that were not added in sufficient quantity to merit
a "dinner" claim. For example, a "Cheese Dinner," with 25% cheese, would
not be feasible or economical to produce, but either a "Beef Dinner for
Dogs" or "Chicken Formula Cat Food" could include a side burst "with
cheese" if at least 3% cheese is added. Recent amendments to the AAFCO
model regulations now allow use of the term "with" as part of the
product name, too, such as "Dog Food With Beef" or "Cat Food With
Chicken." Now, even a minor change in the wording of the name has a
dramatic impact on the minimum amount of the named ingredient required,
e.g., a can of "Cat Food With Tuna" could be confused with a can of
"Tuna Cat Food," but, whereas the latter example must contain at least
95% tuna, the first needs only 3%. Therefore, the consumer must read
labels carefully before purchase to ensure that the desired product is
obtained. 

Under the "flavor" rule, a specific percentage is not required, but a
product must contain an amount sufficient to be able to be detected.
There are specific test methods, using animals trained to prefer
specific flavors, that can be used to confirm this claim. In the example
of "Beef Flavor Dog Food," the word "flavor" must appear on the label in
the same size, style and color as the word "beef." The corresponding
ingredient may be beef, but more often it is another substance that will
give the characterizing flavor, such as beef meal or beef by-products. 

With respect to flavors, pet foods often contain "digests," which are
materials treated with heat, enzymes and/or acids to form concentrated
natural flavors. Only a small amount of a "chicken digest" is needed to
produce a "Chicken Flavored Cat Food," even though no actual chicken is
added to the food. Stocks or broths are also occasionally added. Whey is
often used to add a milk flavor. Often labels will bear a claim of "no
artificial flavors." Actually, artificial flavors are rarely used in pet
foods. The major exception to that would be artificial smoke or bacon
flavors, which are added to some treats. 

Net Quantity Statement 

The net quantity statement tells you how much product is in the
container. There are many FDA regulations dictating the format, size and
placement of the net quantity statement. None of these do any good if
the consumer does not check the quantity statements, especially when
comparing the cost of products. For example, a 14-ounce can of food may
look identical to the one-pound can of food right next to it. Also, dry
products may differ greatly in density, especially some of the "lite"
products. Thus, a bag that may typically hold 40 pounds of food may only
hold 35 pounds of a food that is "puffed up." A cost-per-ounce or
per-pound comparison between products is always prudent. Manufacturer's
Name and Address The "manufactured by..." statement identifies the party
responsible for the quality and safety of the product and its location.
If the label says "manufactured for..." or "distributed by...," the food
was manufactured by an outside manufacturer, but the name on the label
still designates the responsible party. Not all labels include a street
address along with the city, State, and zip code, but by law, it should
be listed in either a city directory or a telephone directory. Many
manufacturers also include a toll-free number on the label for consumer
inquiries. If a consumer has a question or complaint about the product,
he or she should not hesitate to use this information to contact the
responsible party. Ingredient List All ingredients are required to be
listed in order of predominance by weight. The weights of ingredients
are determined as they are added in the formulation, including their
inherent water content. This latter fact is important when evaluating
relative quantity claims, especially when ingredients of different
moisture contents are compared. 

For example, one pet food may list "meat" as its first ingredient, and
"corn" as its second. The manufacturer doesn't hesitate to point out
that its competitor lists "corn" first ("meat meal" is second),
suggesting the competitor's product has less animal-source protein than
its own. However, meat is very high in moisture (approximately 75%
water). On the other hand, water and fat are removed from meat meal, so
it is only 10% moisture (what's left is mostly protein and minerals). If
we could compare both products on a dry matter basis (mathematically
"remove" the water from both ingredients), one could see that the second
product had more animal-source protein from meat meal than the first
product had from meat, even though the ingredient list suggests
otherwise. 

That is not to say that the second product has more "meat" than the
first, or in fact, any meat at all. Meat meal is not meat per se, since
most of the fat and water have been removed by rendering. Ingredients
must be listed by their "common or usual" name. Most ingredients on pet
food labels have a corresponding definition in the AAFCO Official
Publication. For example, "meat" is defined as the "clean flesh of
slaughtered mammals and is limited to...the striate muscle...with or
without the accompanying and overlying fat and the portions of the skin,
sinew, nerve and blood vessels which normally accompany the flesh." On
the other hand, "meat meal" is "the rendered product from mammal
tissues, exclusive of any added blood, hair, horn, hide trimmings,
manure, stomach and rumen contents." Thus, in addition to the
processing, it could also contain parts of animals one would not think
of as "meat." Meat meal may not be very pleasing to think about eating
yourself, even though it's probably more nutritious. Animals do not
share in people's aesthetic concerns about the source and composition of
their food. Regardless, the distinction must be made in the ingredient
list (and in the product name). For this reason, a product containing
"lamb meal" cannot be named a "Lamb Dinner." 

Further down the ingredient list, the "common or usual" names become
less common or usual to most consumers. The majority of ingredients with
chemical-sounding names are, in fact, vitamins, minerals, or other
nutrients. Other possible ingredients may include artificial colors,
stabilizers, and preservatives. All should be either "Generally
Recognized As Safe (GRAS)" or approved food additives for their intended
uses. 

If scientific data are presented that show a health risk to animals of
an ingredient or additive, CVM can act to prohibit or modify its use in
pet food. For example, propylene glycol was used as a humectant in
soft-moist pet foods, which helps retain water and gives these products
their unique texture and taste. It was affirmed Generally Recognized As
Safe (GRAS) for use in human and animal food before the advent of
soft-moist foods. It was known for some time that propylene glycol
caused Heinz Body formation in the red blood cells of cats (small clumps
of proteins seen in the cells when viewed under the microscope), but it
could not be shown to cause overt anemia or other clinical effects.
However, recent reports in the veterinary literature of scientifically
sound studies have shown that propylene glycol reduces the red blood
cell survival time, renders red blood cells more susceptible to
oxidative damage, and has other adverse effects in cats consuming the
substance at levels found in soft-moist food. In light of this new data,
CVM amended the regulations to expressly prohibit the use of propylene
glycol in cat foods. 

Another pet food additive of some controversy is ethoxyquin, which was
approved as a food additive over thirty-five years ago for use as an
antioxidant chemical preservative in animal feeds. Approximately ten
years ago, CVM began receiving reports from dog owners attributing the
presence of ethoxyquin in the dog food with a myriad of adverse effects,
such as allergic reactions, skin problems, major organ failure, behavior
problems, and cancer. However, there was a paucity of available
scientific data to support these contentions, or to show other adverse
effects in dogs at levels approved for use in dog foods. More recent
studies by the manufacturer of ethoxyquin showed a dose-dependent
accumulation of a hemoglobin-related pigment in the liver, as well as
increases in the levels of liver-related enzymes in the blood. Although
these changes are due to ethoxyquin in the diet, the pigment is not made
from ethoxyquin itself, and the health significance of these findings is
unknown. More information on the utility of ethoxyquin is still needed
in order for CVM to amend the maximum allowable level to below that
which would cause these effects, but which still would be useful in
preserving the food. While studies are being conducted to ascertain a
more accurate minimum effective level of ethoxyquin in dog foods, CVM
has asked the pet food industry to voluntarily lower the maximum level
of use of ethoxyquin in dog foods from 150 ppm (0.015%) to 75 ppm.
Regardless, most pet foods that contained ethoxyquin never exceeded the
lower amount, even before this recommended change. 

Guaranteed Analysis 

At minimum, a pet food label must state guarantees for the minimum
percentages of crude protein and crude fat, and the maximum percentages
of crude fiber and moisture. The "crude" term refers to the specific
method of testing the product, not to the quality of the nutrient
itself. 

Some manufacturers include guarantees for other nutrients as well. The
maximum percentage of ash (the mineral component) is often guaranteed,
especially on cat foods. Cat foods commonly bear guarantees for taurine
and magnesium as well. For dog foods, minimum percentage levels of
calcium, phosphorus, sodium, and linoleic acid are found on some
products. 

Guarantees are declared on an "as fed" or "as is" basis, that is, the
amounts present in the product as it is found in the can or bag. This
doesn't have much bearing when the guarantees of two products of similar
moisture content are compared (for example, a dry dog food versus
another dry dog food). However, when comparing the guaranteed analyses
between dry and canned products, one will note that the levels of crude
protein and most other nutrients are much lower for the canned product.
This can be explained by looking at the relative moisture contents.
Canned foods typically contain 75-78% moisture, whereas dry foods
contain only 10-12% water. To make meaningful comparisons of nutrient
levels between a canned and dry product, they should be expressed on the
same moisture basis. 

The most accurate means of doing this is to convert the guarantees for
both products to a dry matter basis. The percentage of dry matter of the
product is equal to 100% minus the percentage of moisture guaranteed on
the label. A dry food is approximately 88-90% dry matter, while a canned
food is only about 22-25% dry matter. To convert a nutrient guarantee to
a dry matter basis, the percent guarantee should be divided by the
percentage of the dry matter, then multiplied by 100. For example, a
canned food guarantees 8% crude protein and 75% moisture (or 25% dry
matter), while a dry food contains 27% crude protein and 10% moisture
(or 90% dry matter). Which has more protein, the dry or canned?
Calculating the dry matter protein of both, the canned contains 32%
crude protein on a dry matter basis (8/25 X 100 = 32), while the dry has
only 30% on a dry matter basis (27/90 X 100 = 30). Thus, although it
looks like the dry has a lot more protein, when the water is counted
out, the canned actually has a little more. An easier way is to remember
that the amount of dry matter in the dry food is about four times the
amount in a canned product. To compare guarantees between a dry and
canned food, multiply the guarantees for the canned food times four
first. 

It is especially important to look at the moisture guarantee for canned
foods, even when comparing a canned food with another canned. Under
AAFCO regulations, the maximum percentage moisture content for a pet
food is 78%, except for products labeled as a "stew," "in sauce," "in
gravy," or similar terms. The extra water gives the product the
qualities needed to have the appropriate texture and fluidity. Some of
these exempted products have been found to contain as much as 87.5%
moisture. This doesn't sound like much difference until the dry matter
contents are compared. For example, a product with a guarantee of 87.5%
moisture contains 12.5% dry matter, only half as much as a product with
a 75% moisture guarantee (25% dry matter). 

Nutritional Adequacy Statement 

Any claim that a product is "complete," "balanced," "100% nutritious,"
or similarly suggests that a product is suitable for sole nourishment
that is not, in fact, nutritionally adequate is a potentially unsafe
product. For this reason, an AAFCO nutritional adequacy statement is one
of the most important aspects of a dog or cat food label. A "complete
and balanced" pet food must be substantiated for nutritional adequacy by
one of two means. 

The first method is for the pet food to contain ingredients formulated
to provide levels of nutrients that meet an established profile.
Presently, the AAFCO Dog or Cat Food Nutrient Profiles are used.
Products substantiated by this method should include the words, "(Name
of product) is formulated to meet the nutritional levels established by
the AAFCO (Dog/Cat) Food Nutrient Profiles." This means the product
contains the proper amount of protein, calcium, and other recognized
essential nutrients needed to meet the needs of the healthy animal. The
recommendations of the National Research Council (NRC) were once used as
the basis for nutritional adequacy, but they are no longer considered
valid for this purpose. 

The alternative means of substantiating nutritional adequacy is for the
product to be tested following the AAFCO Feeding Trial Protocols. This
means that the product, or "lead" member of a "family" of products, has
been fed to dogs or cats under strict guidelines and found to provide
proper nutrition. These products should bear the nutritional adequacy
statement "Animal feeding tests using AAFCO procedures substantiate that
(name of product) provides complete and balanced nutrition." 

Regardless of the method used, the nutritional adequacy statement will
also state for which life stage(s) the product is suitable, such as "for
maintenance," or "for growth." A product intended "for all life stages"
meets the more stringent nutritional needs for growth and reproduction.
A maintenance ration will meet the needs of an adult, non-reproducing
dog or cat of normal activity, but may not be sufficient for a growing,
reproducing, or hard-working animal. On the other hand, an all life
stages ration can be fed for maintenance. Although the higher levels of
nutrients would not be harmful to the healthy adult animal, they are not
really necessary. Occasionally a product may be labeled for a more
specific use or life stage, such as "senior" or for a specific size or
breed. However, there is little information as to the true dietary needs
of these more specific uses, and no rules governing these types of
statements have been established. Thus, a "senior" diet must meet the
requirements for adult maintenance, but no more. A product that does not
meet either of these methods must state that "this product is intended
for intermittent or supplemental feeding," except if it is conspicuously
identified as a snack or treat. 

Feeding Directions 

Feeding directions instruct the consumer on how much product should be
offered to the animal. At minimum, they should include verbiage such as
"feed ___ cups per ___ pounds of body weight daily." On some small cans,
this may be all the information that can fit. The feeding directions
should be taken as rough guidelines, a place to start. Breed,
temperament, environment, and many other factors can influence food
intake. Manufacturers attempt to cover almost all contingencies by
setting the directions for the most demanding. The best suggestion is to
offer the prescribed amount at first, and then to increase or cut back
as needed to maintain body weight in adults or to achieve proper rate of
gain in puppies and kittens. A nursing mother should be offered all the
food she wants to eat. Calorie Statement Pet foods can vary greatly in
calorie content, even among foods of the same type (dry, canned) and
formulated for the same life stage. Feeding directions vary among
manufacturers, too, so the number of calories delivered in a daily meal
of one food may be quite different from another. The number of calories
in a product roughly relates to the amount of fat, although varying
levels of non-calorie-containing components, such as water and fiber,
can throw this correlation off. The best way for consumers to compare
products and determine how much to be fed is to know the calorie
content. However, until recently, calorie statements were not allowed on
pet food labels. New AAFCO regulations were developed to allow
manufacturers to substantiate calorie content and include a voluntary
statement. 

If a calorie statement is made on the label, it must be expressed on a
"kilocalories per kilogram" basis. Kilocalories are the same as the
"Calories" consumers are used to seeing on food labels. A "kilogram" is
a unit of metric measurement equal to 2.2 pounds. Manufacturers are also
allowed to express the calories in familiar household units along with
the required statement (for example, "per cup" or "per can"). Even
without this additional information, however, consumers can make
meaningful comparisons between products and pick the product best suited
for their animals' needs. As with the guaranteed analysis, the calorie
statement is made on an "as fed" basis, so corrections for moisture
content must be made as described above. To roughly compare the caloric
content values between a canned and a dry food, multiply the value for
the canned food by four. 

Other Label Claims 

Many pet foods are labeled as "premium," and some now are "super
premium" and even "ultra premium." Other products are touted as
"gourmet" items. Products labeled as premium or gourmet are not required
to contain any different or higher quality ingredients, nor are they
held up to any higher nutritional standards than are any other complete
and balanced products. 

The term "natural" is often used on pet food labels, although that term
does not have an official definition either. For the most part,
"natural" can be construed as equivalent to a lack of artificial
flavors, artificial colors, or artificial preservatives in the product.
As mentioned above, artificial flavors are rarely employed anyway.
Artificial colors are not really necessary, except to please the pet
owner's eye. If used, they must be from approved sources, the same as
for human foods. Especially for high-fat dry products, some form of
preservative must be used to prevent rancidity. Natural-source
preservatives, such as mixed tocopherols (a source of vitamin E), can be
used in place of artificial preservatives. However, they may not be as
effective. 

"Natural" is not the same as "organic." The latter term refers to the
conditions under which the plants were grown or animals were raised.
There are no official rules governing the labeling of organic foods (for
humans or pets) at this time, but the United States Department of
Agriculture is developing regulations dictating what types of
pesticides, fertilizers and other substances can be used in organic
farming. 

Summary 

Pet owners and veterinary professionals have a right to know what they
are feeding their animals. The pet food label contains a wealth of
information, if one knows how to read it. Do not be swayed by the many
marketing gimmicks or eye-catching claims. If there is a question about
the product, contact the manufacturer or ask an appropriate regulatory
agency.

