Most years, the second day of the AAFCO meeting is the meat and potatoes for manufacturers of real pet food. This is the day that the Pet Food and Ingredient Definitions Committees meet. While the trade association participates in other committees, the decisions which immediately impact our manufacturers happen here.
This meeting, there was also a little dessert. I’ll fill you in about that at the end, if you are still hungry.
Pet Food Committee – a lot of discussion about label updates and implementation. Basically, AAFCO is writing new guidance as well as has updates to the labels; nothing puts these updates into state regulations until regulators and legislatures decide to make updates.
To repeat: nothing is official yet.
The soonest any changes will be required of manufacturers is 3 years from implementation date. We are probably 2 years from these suggestions being official in the AAFCO Official Publication (that adds up to 5+ years for full implementation).
No one likes to spend money to make label changes. The good news is:
- There is plenty of time
- You will know as soon as anything is final
- You’ll probably change your labels between now and then anyway
- All the states still have to accept the AAFCO suggestions
- You’ll like the changes to total carbohydrate reporting – mirroring human food will allow you to better portray your product to your customer
Most importantly: the reason for these changes is to meet FSMA requirements, improving transparency to the consumer. Ultimately, the new labels will look similar to the human food labels including the Facts Box information – consumers will better be able to select pet foods meeting their needs.
Updates to the Human Grade work group: USDA/AMS are currently conducting a pilot evaluation of one manufacturer to test that the protocols work. The work group continues to uphold the definition of human grade.
What’s frustrating for some is that while many manufacturers use all or almost all human grade ingredients, if these companies/products are not under USDA inspection, the human grade certification can’t be achieved/claimed. This is not new – this is how the classification was written in the first place. On the positive side, the stringent rules make it so that every company can’t jump on the human grade bandwagon thereby diluting the marketplace.
Ingredient Definitions Committee: there’s a new feed term – “common or usual.” As long as an ingredient is safe for the use intended, and it doesn’t violate law, you can use a food that has a common name. What does this mean? Let me give a few examples to help clarify.
Onions are poisonous to dogs – can’t use them. Hemp is not approved for pet food, thus, currently, illegal. Mushrooms are common and usual (as long as you are using safe ones like button mushrooms).
This “common or usual” term is going to be a growing process. It will open dialogue between regulators and manufacturers.
Need help? Reach out – this is another benefit of membership in NGPFMA.
We had some fluff this year. Farm Babe and the New Mexico Milkmaid. Both speakers discussed conventional farming systems and the importance of communicating how these systems work to consumers. While the speakers were correct that communication is a vital part of what everyone does, it becomes apparent that conventional systems are on the defense as they work very hard to justify their practices.
For example, we were told by “farm babe“ that chemicals make human lives better, therefore they make plant lives better; justifying the use in agriculture. I could go on. I won’t belabor the point. But it is interesting to observe conventional producers in all aspects of the feed industry (you notice I said feed and not food) defending their dwindling turf.