For the last year, AAFCO Pet Food Committee members have debated the validity of a reduced copper claim in the OP. The reduced claim would still have allowed a diet to be complete and balanced under AAFCO rules, but to be limited in how much copper is contained in a food. The purpose of the proposed language was two-fold:
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- To give standard regulatory framework for all state regulators to regulate diets with restricted copper levels.
- To present an option to pet owners who are concerned about copper in their pets’ food.
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The debate was long and circular. I’m not going to repeat the debate here. Instead, if you want to read the debate, CLICK HERE.
Where are we now? Here are facts you should know:
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- The FDA declined to vote, even though they chaired the work group.
- The conventional pet food industry was adamantly against a restricted claim.
- The AVMA was against a restricted claim.
- The American College of Veterinary Nutritionists, holistic veterinarian advisors, and our own (NGPFMA) science committee were in favor of a restricted claim.
- Five state regulators were for the new motion. Nine state regulators were against.
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End the end, the motion died.
So, what does this mean for us as pet food manufacturers?
It means a manufacturer can still make a voluntary reduced/restricted/controlled copper claim. It just won’t be regulated in the AAFCO OP. And, because state regulators failed to agree on the language, you can use any adjective you want. You simply don’t want to call it “low” copper because then it will not be complete and balanced.
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Low copper, less than 7.3 mg/kg DM, is a therapeutic diet. A prescription diet. An unbalanced diet.
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Why would you want to formulate a diet with a restricted copper claim?
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Some pet owners have experienced liver disease in their dogs and would like a bit more control over the ingredients. Let’s give it to them. As of now, you can still make a modified copper claim. You’ll just have to justify it on a state-by-state basis. This isn’t new. You do that every year when you register your labels anyway.
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I say “Go for it!”
Let’s have some niche differentiation.
