The Most Sweeping Change in Pet Food Label Transparency – Truth about Pet Food

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Have you ever ever wondered why AAFCO has to define pet food ingredients? As example, chicken is already legally defined through the Poultry Products Inspection Act. So why would the chicken utilized in pet food require one other definition?

The reply: because pet food chicken is held to a totally different standard than the chicken consumers are aware of. The commonly known chicken is required to satisfy the legal standards of the Poultry Products Inspection Act, however the chicken utilized in (most) pet foods is NOT required to satisfy the legal standards of the Poultry Products Inspection Act (the exception could be human grade pet foods). To the confusion of tens of millions of pet food consumers, each chicken ingredients have the very same name regardless that they’re held to 2 very different standards. Legally speaking, pet food chicken is a nonstandardized food (it doesn’t meet the ‘standard’ of food chicken).

But, federal law takes into consideration this confusion attributable to two very different ingredients of the identical name. The truth is, federal law – specific to animal food – requires the confusion to be addressed within the ingredient name.

Title 21, Chapter I, Subpart E, Part 502 Common or Usual Names for Nonstandardized Animal Foods states (daring added for emphasis):

“General Principles (a) The common or usual name of a food, which could also be a coined term, shall accurately discover or describe, in as easy and direct terms as possible, the essential nature of the food or its characterizing properties or ingredients. The name shall be uniform amongst all similar or similar products and will not be confusingly just like the name of every other food that just isn’t reasonably encompassed inside the same name. Each class or subclass of food shall be given its own common or usual name that states, in clear terms, what it’s in a way that distinguishes it from different foods.”

There couldn’t be far more “confusingly similar” names than nonstandardized ingredients of pet food which have the EXACT SAME name as standard ingredients of food. The pet food ingredients chicken, beef, lamb, turkey, corn, peas, and on and on have a typical name that’s ‘confusingly similar’ (actually it’s similar) to standardized foods.

Most pet food ingredients are feed grade, a “subclass” of food. Law clearly requires that any “subclass of food shall be given its own common or usual name…that distinguishes it from different foods.” There isn’t a doubt about it – feed grade ingredients are a subclass of food they usually are required to be given a unique name.

So…(here is where we’d like your support)…

Based on this law (and a number of others) we’ve submitted an official request to the FDA to amend current pet food ingredient names. Based on the legal requirements inside animal food law, we’ve requested FDA to require pet food label disclosure of the subclass ingredients feed grade.

The official request sent to FDA is termed a “Citizen Petition”, a process where individuals or organizations could make requests to FDA for changes in policy. Citizen Petitions submitted to FDA are posted on the federal government website Regulations.gov and are open for public comment. FDA is required by law to reply inside 150 days (though they commonly ignore this legal deadline).

Our Citizen Petition will be read here. We make several legal arguments, proving to FDA that law requires the label disclosure of feed grade ingredients. As required, our Citizen Petition explains what we’re requesting in Section A. We included in Section A existing laws and proposed laws that might make it clear to industry the feed grade disclosure requirements. Section B of our petition includes the grounds for our request, where we quote quite a few sections of law evidencing feed grade is required to be disclosed on the pet food label.

Your part…Submit a Comment!

It’s significantly necessary for FDA to see that pet food consumers support this modification. As well, it’s significantly necessary for FDA to see that pet foods using human grade ingredients support this modification. And it is easy to indicate your support.

Our Citizen Petition is posted on the federal government website Regulations.gov. Click on the blue “Comment” box. You may include your name or you may remain anonymous. Added after original posting: Under the section “What’s Your Comment About?” there’s a drop down menu to decide on a category, select the category “Individual Consumer“.

Please share the Petition with every pet owner you realize and ask them to post a comment. Your comment will be so simple as ‘I support this petition’ to as detailed as you’d wish to make it. Be happy to inform the FDA why you suspect label disclosure of feed grade ingredients is essential.

Everyone (however the pet feed industry) advantages.

These sweeping changes to pet food labeling will profit tens of millions of pet owners. After many years of pet food label deception, if FDA implements these changes as law requires, pet owners would finally know in the event that they are purchasing pet food or pet feed.

We suspect the pet feed industry won’t be too blissful about our Citizen Petition. We suspect they will likely be lobbying their members of Congress urging them to influence the FDA to disregard these legal requirements. To battle their lobbying efforts, we ask pet owners to share the Petition with their members of Congress too.

Send your Senate and House Representatives in Congress a message stating you might be in support of Citizen Petition FDA-2022-P-1643-0001. Ask your Representative to induce the FDA to amend the common names of pet food ingredients disclosing the subclass feed grade as animal food law requires.

Wishing you and your pet one of the best –

Susan Thixton
Pet Food Safety Advocate
TruthaboutPetFood.com
Association for Truth in Pet Food

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