Understanding Pet Food Labels
by David A. Dzanis, D.V.M., Ph.D

     As Americans become more health conscious, they are reading
food labels and choosing products more carefully. Many people are
extending this scrutiny to food for their pets as well. Pet food
labels are regulated by different rules than foods for human
consumption, but reading and understanding a pet food label can
help consumers make proper food choices for their pets, too.
     Pet food labeling is regulated at two levels. The federal
regulations, enforced by the Food and Drug Administration's Center
for Veterinary Medicine, establish standards for all animal feeds:
proper identification of the product, net quantity statement,
manufacturer's address, and proper listing of ingredients. Some
states also enforce their own labeling regulations. Many of these
follow the model pet food regulations of the Association of
American Feed Control Officials (AAFCO), a nongovernment advisory
body with representatives from all states. These model regulations
are more specific, covering aspects of labeling such as product
name, guaranteed analysis, nutritional adequacy statement, feeding
directions, and calorie statements.

Product Name
     The product name is the first part of the label a consumer
notices, and can be a key factor in the decision to buy a product.
For that reason, manufacturers often use fanciful names or other
techniques to emphasize a particular aspect. Many product names
incorporate the name of an ingredient to highlight its presence in
the product. Consumers are often confused, however, as to how much
of a named ingredient is actually in the product. The percentages
of named ingredients in the total product are dictated by four
AAFCO model rules.
     The first of these is the "95 percent" rule. It applies to
products consisting primarily of meat, poultry or fish, such as
some of the canned products. They have simple names, such as
"Dave's Beef for Dogs." In this example, at least 95 percent of the
named ingredient must be beef, exclusive of water for processing.
Counting the added water, it still must comprise 70 percent of the
product.
     Since ingredient lists must be in the proper order of
predominance by weight, "beef" 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 "Dave's Chicken and Fish Cat Food," the two
together must comprise 95 percent of the total weight, and there
must be more chicken than fish.
     The second rule, the "25 percent" or "dinner" rule, applies to
many canned and dry products. If the named ingredient(s) comprise
at least 25 percent of the product exclusive of water for
processing, but less than 95 percent, the name must include a
qualifying descriptive term, such as "Dave's Beef Dinner for Dogs."
Many descriptors other than "dinner" are used, however.  "Platter,"
"entrÇe," "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 the named ingredient, and
may in fact be an undesired ingredient, the list should always be
checked before purchase. For example, a cat owner may complain that
her cat's "chicken dinner" smells like fish. She avoids buying
fish, since her cat doesn't like it, but she is more concerned that
the food might be spoiled. In reading the ingredient list, however,
she discovers that the primary ingredient is indeed fish.
     If more than one ingredient is included in a "dinner" name,
they must total 25 percent and be listed in the same order as found
on the ingredient list. Each named ingredient must be at least 3
percent of the total, too. Therefore, "Dave's Chicken and Fish
Dinner Cat Food" must have 25 percent chicken and fish, and at
least 3 percent fish.
     The third rule is the "3 percent" or "with" rule. It is
intended to apply to ingredients highlighted on the label but which
appear outside the product name. This allows manufacturers to point
out the presence of minor ingredients that are not or cannot be
added in sufficient quantity to merit a "dinner" claim. For
example, a "Bacon Dinner," with 25 percent bacon, would not be
feasible, nor would it most likely be palatable or nutritionally
sound. However, both "Dave's Beef Dinner for Dogs" and "Dave's
Chicken Dinner for Dogs" could include a side burst "with bacon" if
at least 3 percent bacon is added. If the burst reads "with bacon
and cheese," it must contain at least 3 percent bacon and 3 percent
cheese.
     Some manufacturers have been using the "with" designation as
part of the product name, which may give the impression that more
of an ingredient is present than really is. For example, one may
not expect a "Dave's Dog Food with Beef" to contain as much as
"Dave's Beef Dinner," but not as little as 3 percent. The AAFCO Pet
Food Committee is considering new model regulations to address this
issue.
     Under the fourth rule or "flavor" rule, a specific percentage
is not required, but a product must contain an amount sufficient to
be able to be detected. In the example of "Dave's 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 byproducts.
Pet foods often contain "digests," which are materials treated with
heat, enzymes and acids to form concentrated natural flavors.
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
     It's important to check the net quantity statement when
comparing products. Today, many canned products are sold in
nonstandardized sizes, so even though the products look the same,
one may be a better buy. 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" with air.
     When new federal regulations go into effect requiring "dual
declarations" on pet food labels, not only will the customary
"pound" or "ounce" declaration be made, but a unit of metric
measurement, such as "kilogram" or "gram" ("kg" or "g") will also
appear on the label. Many pet food labels already bear both
measurements.

Manufacturer's Name and Address
     The "manufactured by œ" statement identifies the party
responsible for the quality and safety of the product and its
location. A consumer who has a question or complaint about a
product should not hesitate to contact the manufacturer. Many
manufacturers also include an "800" telephone number on the label
for consumer inquiries.

Ingredient List
     As mentioned, ingredients are required to be listed in their
proper order of predominance by weight. The weights of ingredients
are determined as they are added in the formulation, with their
inherent water content. This is important when evaluating relative
quantity claims, especially when ingredients of different moisture
contents are compared.
     For example, one pet food may list "chicken" as its first
ingredient, and "corn" as its second. The manufacturer doesn't
hesitate to point out that its competitor lists "corn" first
(chicken meal is second). However, chicken is very high in moisture
(approximately 75 percent water). On the other hand, water and fat
are removed from chicken meal, so it is only 10 percent moisture.
Comparing both products on a dry matter basis, the second product
has more chicken meal than the first product has chicken.
     That is not to say that the second product has more chicken,
or in fact, any chicken at all. Chicken meal is not chicken per se,
since all 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 common
definition in the AAFCO official publication. For example, "meat"
is defined as the "clean flesh of slaughtered mammals and is
limited to œ the striate muscle œ 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." Meat meal may not be very pleasing to
think about eating, even though it's probably more nutritious, but
the distinction must be made in the ingredient list.
     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 include
artificial colors, stabilizers, and preservatives. All must be
either "Generally Recognized as Safeœ (GRAS) or approved food
additives for their intended uses. When there are health risks with
an ingredient, FDA takes appropriate action. (See "When There Are
Health Risks.")

Guaranteed Analysis
     At minimum, a pet food label must state guarantees for minimum
percentages of crude protein and crude fat, and 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. Maximum ash is often guaranteed, especially on cat foods. Cat
foods commonly bear guarantees for taurine and magnesium as well.
For dog foods, minimum levels of calcium, phosphorus, sodium, and
linoleic acid are found on some products. If the guarantees don't
include information on a particular nutrient that you're interested
in, ask the company or don't buy the product.
     The levels of crude protein and most other nutrients are much
lower for the canned product than for a comparable dry product due
to differences in moisture contents. Canned foods typically contain
75 to 78 percent moisture, while dry foods contain only 10 to 12
percent water. A rough approximation of comparable nutrient levels
of a canned and dry product can be made by multiplying the
guarantees for the canned product by four.
     When buying a canned food, look at the moisture guarantee. The
maximum moisture content for a pet food is 78 percent, except for
products labeled as a "stew," "in sauce," "in gravy," or similar
terms. The extra water gives the product the qualities necessary
for appropriate texture and fluidity, but you are paying for it.

Nutritional Adequacy Statement
     Manufacturers must substantiate the nutritional adequacy of a
"complete and balanced" pet food by one of two means. By the first
method, the pet food must contain ingredients formulated to provide
nutrient levels established by the AAFCO dog or cat nutrient
profile. (The recommendations of the National Research Council
[NRC] are no longer used as the basis for nutritional adequacy. If
a pet food label claims "meets or exceeds NRC," it  means the
product is old or the manufacturer has yet to comply with the new
model regulations.)
     The alternative means of substantiating nutritional adequacy
is for the product to be tested following the AAFCO Feeding Trial
Protocols. These products should bear a nutritional adequacy
statement that begins, "Animal feeding tests œ." However, not all
products that bear the claim are the ones actually tested. Some may
be members of a "family" formulated to be nutritionally similar or
superior to the product tested. Because of some concerns regarding
the application of the family concept by manufacturers, AAFCO is
considering new model regulations.
     The nutritional adequacy statement also tells for which life
stage(s) the product is suitable. 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 higher levels of nutrients are not harmful to
the healthy adult animal, they are not really necessary.

Feeding Directions
     Feeding directions tell how much of the product should be
offered 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. However,
feeding directions for other pet foods are much more elaborate,
especially on dry product labels.
     The feeding directions should be taken as rough guidelines.
They tend to overestimate an animal's needs, possibly to make sure
that highest calorie requirements (such as those of working dogs,
pregnant and lactating dogs, and certain active breeds) are met. So
don't be afraid to adjust portions to your pet's needs, especially
if you feel it's gaining too much weight.

Calorie Statement
     Until recently, calorie statements were not allowed on pet
food labels. New AAFCO model regulations 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 equal to 2.2 pounds. Manufacturers may also
express the calories in familiar household measurements (cup,
pound) along with the required statement.
     Other label statements are not required but sometimes appear
on the label nonetheless (see "Premium? Natural? Light?").
     Pet owners have a right to know what they are feeding their
animals. The pet food label contains a wealth of information, if
you know how to read it. Don't be swayed by marketing gimmicks or
eye-catching claims. If you have a question about the product, 
contact the manufacturer, your state regulatory agency, or FDA. n

David A. Dzanis is a veterinary nutritionist with FDA's Center for
Veterinary Medicine.

When There Are Health Risks
     If there is scientific evidence showing an ingredient or
additive presents a health risk to animals, FDA's Center for
Veterinary Medicine can prohibit or require manufacturers to modify
its use in pet food. For example, propylene glycol is used as a
humectant in semi-moist pet foods, giving these products their
unique texture and taste. It was affirmed GRAS (generally
recognized as safe) for use in human and animal food before the
advent of semi-moist foods.
     It was known for some time that propylene glycol caused a red
blood cell disorder in cats called Heinz body formation, but it
could not be shown to cause overt anemia or other clinical effects.
However, recent reports of scientifically sound studies show that
propylene reduces 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 semi-
moist food. Therefore, the center is working to amend the
regulations to expressly prohibit the use of propylene glycol in
cat foods.
     Another somewhat controversial pet food additive is
ethoxyquin. Ethoxyquin was approved as a food additive more than 30
years ago as an antioxidant chemical preservative in animal feeds.
A few years ago, the center began receiving reports from dog owners
attributing myriad adverse effects to the presence of ethoxyquin in
dog food. The reported effects include allergic reactions, skin
problems, major organ failure, behavior problems, and cancer.
However, there is little available scientific data to support these
contentions, or to show other adverse effects in dogs at levels
approved for use in dog food. As such, there is no sound scientific
basis to warrant a change in the regulatory status of ethoxyquin at
this time. n

--D.A.D.

Premium? Natural? Light?
     Many pet foods are labeled as "premium," and some now are
"superpremium" and even "ultrapremium." Other products are touted
as "gourmet" or "natural." None of these terms have any official
FDA or state regulatory standing. 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.
Products labeled "natural" do not approximate the natural diet of
the animal, as the products do not contain whole bodies of birds or
small mammals. Nor do they exclude artificial ingredients, since
all complete and balanced products must contain some chemically
synthesized ingredients, such as vitamin supplements. (Some
products will include the disclaimer "natural ingredients with
added vitamins and minerals.")
     For the most part, "natural" can be construed to mean the
product contains no artificial flavors, colors or preservatives.
Artificial flavors are rarely employed anyway, and 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 are
not as effective. If a product smells bad, or the pet doesn't eat
it or gets sick, take the product back to the store or contact the
manufacturer.
     Following trends in human foods, many pet food labels carry
the claim to be "lite" or "light." However, unlike human foods,
there are presently no standards for "light" pet foods. A
manufacturer's light product is only light relative to another of
the company's products. In some cases, one company's light product
may contain more calories than another's regular product. AAFCO is
considering new model regulations to address this problem. n

--D.A.D.