Ingredients & Additives
An animal food (feed) ingredient is a component part, constituent, or any combination/mixture added to and comprising the animal food. Animal food ingredients might include grains, milling by-products, added vitamins, minerals, fats/oils, and other nutritional and energy sources. Animal foods provide a practical outlet for plant and animal by-products not suitable for human consumption. Legally, under the Federal Food, Drug, and Cosmetic Act (FD&C Act) any substance added to or expected to become a component of animal food, either directly or indirectly, must be used in accordance with a food additive regulation unless it is Generally Recognized as Safe for that use (GRAS). Approved food additives are listed in Title 21 of the Code of Federal Regulations (21 CFR), parts 573 and 579, and a partial listing of substances that are considered GRAS for an intended use are found in 21 CFR 582 and 584.
The Official Publication of the Association of American Feed Control Officials (AAFCO) contains the most complete list of animal food ingredients with their definitions. The Official Publication includes the list of approved animal food additives as well as a list of substances that are GRAS for an intended use. In addition, many of the ingredients in the AAFCO Official Publication are not approved food additives and may not meet the criteria needed to be recognized as GRAS for a use (21 CFR 570.30). Nevertheless, FDA has accepted the listing of certain ingredients (e.g., those used as sources of nutrients, aroma, or taste) in the AAFCO Official Publication for their marketing in interstate commerce, provided there were no apparent safety concerns about the use or composition of the ingredient.
Federal regulations require ingredients be listed on the product label by their common or usual name in descending order of predominance according to weight (21 CFR 501.4). A common or usual name is one that accurately identifies or describes the basic nature of the ingredient (21 CFR 502.5). FDA has recognized the definitions as they appear in the Official Publication of AAFCO as the common or usual name for animal food ingredients including pet food (Compliance Policy Guide 665.100). There is only one exception to the requirement to list the common or usual name on the label--it is when the ingredient is part of a collective name (term). Regulation 21 CFR 501.110 describes the use of collective names. The following are acceptable collective names: animal protein products, forage products, grain products, plant protein products, processed grain by-products, and roughage products. These collective names may be used in the ingredient list for livestock and poultry feeds, but not pet foods.
Association of American Feed Control Officials (AAFCO)
AAFCO is composed of state, federal, and international regulatory officials who are responsible for the enforcement of state laws regulating the safe production and labeling of animal food, including livestock and poultry feed and pet food. FDA and AAFCO work together in the area of animal food regulation, particularly in the establishment of definitions to describe new feed ingredients. Each year, AAFCO publishes its Official Publication, which includes a model feed bill for States to voluntarily adopt in regulating animal food products and a list of accepted feed ingredients. Most States have adopted all or part of the model bill and allow ingredients listed in the publication to be used in their respective territories. For more information about AAFCO, please see www.aafco.org.