New model pet food regulations intended to make labels more consumer friendly have been approved by the Association of American Feed Control Officials. These changes affect how the intended use of the product is conveyed, nutrient content information is presented, ingredients are declared, and handling and storage directions appear on the label.
One key change requires the word “complete” to be prominently displayed to help pet owners more easily select complete and balanced foods. A new “pet nutrition facts” box, mimicking the nutrition facts box on human food labels, includes new information to simplify calorie and major nutrient comparisons between diets. Optional pet food handling and storage instructions may be included as well. These label changes should facilitate the nutritional management of pets.
Take-Home Points
- New consumer-friendly labels will start to appear on pet foods over the coming years.
- Owners should be reasonably assured that a healthy pet is consuming an appropriate quantity of all essential nutrients if 90% or more of its daily calories come from foods conspicuously labeled “complete” (for the appropriate species, life stage, and size of animal).
- A “pet nutrition facts” box will provide nutrient information relative to a familiar household unit, not a serving size or kilogram of diet.
- It will be possible to deduce the average amount of major nutrients in the diet because calories from protein, fat, and carbohydrate are calculated using modified Atwater factors based on average amounts in the diet.
- A guaranteed maximum of total dietary fiber, which includes both soluble and insoluble fiber, will replace a guaranteed maximum of crude fiber, which measures only insoluble fiber.
- Food handling and storage instructions, albeit optional, will be standardized to ensure the consumer receives consistent information regardless of brand.
For the first time in decades, the Association of American Feed Control Officials (AAFCO) approved substantial amendments to its model pet food label regulations in 2023. These amendments are intended to help pet owners better understand what they are feeding their pets. The complete revised regulations appear in the 2024 AAFCO Official Publication1; a summary can be found at go.navc.com/3uHNqhg. AAFCO suggests a 6-year transition period for state regulatory bodies to implement and begin enforcement of the amended rules. During that period, companies will need to alter their labels to meet the requirements, and products with new labels will gradually appear in stores and online. This review explains the implications and limitations of the major pet food label changes.
Intended Use Statement
Perhaps the most important change is that the word “complete” must appear on the lower front panel of any pet food label substantiated to be complete and balanced by AAFCO methodology. “Complete” is to be followed by the intended species along with any life stage or size limitations, such as “Complete Adult Cat Food” or “Complete Food for Puppies (< 70 lb. as an adult).” This designation must be located near the net weight statement with the same background color, in the same font style and color, and of the same size as or larger than the net weight statement (FIGURE 1). Searching the small print on the back of the label for this key information will no longer be necessary.
Figure 1. Hypothetical intended use statement as it appears on a pet food label. Yeti studio/shutterstock.com
Veterinarians should recommend that clients feed 90% or more of their pet’s daily calories from one or more complete foods appropriate for the species, life stage, and size of the animal in a sufficient quantity to maintain body condition. Then, pet owners can be reasonably assured their pet is consuming adequate quantities of essential nutrients.
Diets that are not complete cannot use the term “complete” in their intended use statement and must further qualify their intended use with terms such as “veterinary diet,” “treat,” or “food supplement.” A new designation, “food mixer,” pertains to products such as gravies and single-ingredient foods that are primarily added to improve palatability, not necessarily nutritional content. “Food mixers” and other incomplete foods such as treats should be limited to less than 10% of a pet’s daily caloric intake.
Pet Nutrition Facts Box
A consolidated, prominently displayed “pet nutrition facts” box (FIGURE 2) that mimics the “nutrition facts” box on human food labels will become standard on the back of pet food labels. That box will include the following components: familiar household unit (FHU), calorie content, guaranteed nutrient composition, and nutritional adequacy statement.
Figure 2. Hypothetical pet nutrition facts box
Familiar Household Unit
In place of “serving size” used on human food labels, expression of nutritional content will be based on an FHU, such as a can, standardized measuring cup, or number of treats, along with its weight in grams.
Calorie Content
The total calorie content per FHU appears next, followed by the calories per FHU contributed by protein, fat, and carbohydrate. Calories per kilogram of the diet is no longer provided, but dividing calories per FHU by weight of FHU will give calories per gram of the diet.
Although the unit on current pet food labels, kilocalorie metabolizable energy (kcal ME), is more technically accurate than the calorie unit on human food labels, kcal ME will no longer appear on pet food labels due to confusion with its meaning outside of the scientific community. For consistency with human food labels, all references to calories, regardless of the capitalization or abbreviation, should be presumed to be “food calories” in which 1 food calorie equals 1 kcal.
AAFCO recognizes that the calorie content estimated using modified Atwater factors may provide different results from feeding trials, but the method of determining calorie content remains unchanged. Carbohydrate continues to be estimated as nitrogen-free extract (NFE), excluding crude fiber. More accurate methods of calculating total calorie content, such as those recommended by the National Research Council,2 have not been incorporated in these model regulations due to limitations in time and resources. The authors encourage AAFCO to pursue this as its next priority for change.
One benefit is that calories per FHU contributed by each of the major nutrients—protein, fat, and carbohydrate—are calculated with modified Atwater factors from the average content of each nutrient in the diet. This allows the average grams of nutrient per megacalorie (Mcal; 1000 kcal) to be calculated from values reported in the “pet nutrition facts” box using the following formulas:
Crude protein (g/Mcal) = (calories from protein / 3.5) × (1000 / calories per FHU)
Crude fat (g/Mcal) = (calories from fat / 8.5) × (1000 / calories per FHU)
NFE (g/Mcal) = (calories from carbohydrate / 3.5) × (1000 / calories per FHU)
Alternatively, major nutrient content can be calculated as a percentage of total calories by dividing nutrient calories by total calories. Either method allows a more accurate comparison of major nutrient composition on an energy basis than is possible using minimum and maximum guaranteed values.
Making decisions about feeding pets requires some understanding of what constitutes a high or low dietary amount of protein, fat, carbohydrate, and fiber. A suggested classification ranging from “very low” to “very high” is provided in TABLES 1 AND 2.
Guaranteed Nutrient Composition
The new “pet nutrition facts” box will include mandatory minimum or maximum guarantees for protein, fat, total carbohydrate, dietary fiber, and moisture. The word “crude” will be eliminated before protein and fat. A guaranteed maximum “total carbohydrate” that does not exclude fiber is now mandatory; a guaranteed maximum dietary fiber must also be declared as a subset under “total carbohydrate.” Dietary fiber replaces crude fiber on the label and includes soluble fiber plus other components not measured by crude fiber. However, the ingredient list must be examined to estimate the relative amounts of fiber type.
Outside of the previously mentioned mandatory guarantees, other essential and nonessential nutrient guarantees are voluntary unless required to support specific nutrient claims. For example, listing the guaranteed maximum amounts of dietary starch and sugars is voluntary unless there is a label claim relating to carbohydrate content. If such a claim is made, both the guaranteed maximum amounts of dietary starch and sugars must be listed below the fiber maximum.
Minimum or maximum nutrient guarantees will now be followed by the corresponding weight of the nutrient per FHU. This practice allows the minimum or maximum nutrient content in g/Mcal to be calculated by dividing the reported amount per FHU by the calories per FHU and multiplying by 1000. Nutrient values obtained in this way will deviate from average values by a variable amount, but they remain useful for general assessment and comparison purposes.
Nutritional Adequacy Statement
No changes were made to the wording requirements for this statement, but it must now be located at the bottom of the new “pet nutrition facts” box. This consistent location is a major improvement from current regulations in which the statement’s location is variable and therefore challenging to locate.
Ingredient Statement
The ingredient statement remains largely unchanged except for a few minor clarifications, such as limiting the word “sugar” to sucrose from sugar cane or sugar beets. Some common practices that have been informally accepted by regulators over the years have been codified, such as adding “vitamins” and “minerals” before lists of premix ingredients. Overall, veterinarians and pet owners will not see noticeable differences in ingredient statements.
Handling and Storage Instructions
Standardized handling and storage instructions (with or without graphics) are encouraged by AAFCO but remain optional. These new guidelines promote conspicuous, consistent instructions to increase awareness that pet food should be handled and stored similarly to human foods (FIGURE 3).
Figure 3. Hypothetical handling instructions with graphics. Refrigerator: icon0.com/shutterstock.com. Mother and child: Viktorija Reuta/shutterstock.com
Summary
The authors acknowledge there are areas for further label improvements. Nonetheless, those members and advisors of AAFCO who worked for 8 years to modernize pet food label regulations are to be complimented for their work. Overall, these changes to pet food labels are a great improvement, helping veterinarians, clients, and ultimately, pets. New labels will help identify which pet foods are complete and the calories they provide. Despite some calculations still being necessary to evaluate and compare diets, nutrient content is listed in a more functional manner. Optional handling and storage instructions will hopefully promote consumer awareness. AAFCO has recommended a 6-year transition period to allow state regulators and pet food companies to implement these changes; in time, these label improvements will become standard online and in stores.
References
1. AAFCO. The AAFCO Official Publication. The Association of American Feed Control Officials, Inc.; 2024.
2. National Research Council, Division of Earth and Life Studies, Board on Agriculture and Natural Resources, Committee on Animal Nutrition, Subcommittee on Dog and Cat Nutrition. Nutrient Requirements of Dogs and Cats. The National Academies Press; 2006.