USDA and other Label Nuances: Pet Food Ingredients A to Z

We continue our Pet Food Ingredients A to Z series with the letter “U”. In reality, there are not a lot of ingredients that start with the letter U. We decided on “USDA”. Although it is not an ingredient, it is an adjective used in some rare cases to describe a protein used in the food. For example, you might see USDA Beef or USDA Chicken as an ingredient. We will stray a bit from our normal “A to Z” format and discuss what USDA and other general pet food labeling terms mean.

There are a whole set of pet food label terms that can be confusing, if not misleading. Learning which of these actually mean something and which are simply marketing ploys can help a pet owner determine if they need to reconsider their food choices.

Pet food nutritional guidelines

Pet food label guidelines are defined by the Association of Animal Feed Control Officials (AAFCO), a non-government, self regulatory organization. However, AAFCO has no official regulatory power to enforce food or labeling compliance. Regulation is done at the state level. Here is a passage taken from the AAFCO site:

AAFCO does not regulate, test, approve or certify pet foods in any way.

AAFCO establishes the nutritional standards for complete and balanced pet foods, and it is the pet food company's responsibility to formulate their products according to the appropriate AAFCO standard.

It is the state feed control official's responsibility in regulating pet food to ensure that the laws and rules established for the protection of companion animals and their custodians are complied with so that only unadulterated, correctly and uniformly labeled pet food products are distributed in the marketplace and a structure for orderly commerce.

The above does not suggest that AAFCO guidelines are toothless. Rather, it means that the guidelines developed by AAFCO are enforced and regulated by the states.

Confusing pet food label terms

USDA and Human Grade Ingredients

The use of USDA before a named meat is not a common practice. The use of USDA to describe an ingredient is meant to suggest that it is USDA inspected which could mean that it was sourced from a USDA inspected facility. AAFCO does not offer an opinion on the rules for labeling foods in this way.

Even if an ingredient is sourced from a USDA inspected plant, this does not imply that the food is “human grade”. Here is a snippet from AAFCO”s statement on human grade labeling:

A claim that something is “human-grade” or “human-quality” implies that the article being referred to is “edible” for people in legally defined terms. The terms “human grade” or “human quality” have no legal definition. Thus, for all practical purposes, the term “human grade” represents the product to be human edible. For a product to be human edible, all ingredients in the product must be human edible and the product must be manufactured, packed and held in accordance with federal regulations in 21 CFR 110, Current Good Manufacturing Practice in Manufacturing, Packing, or Holding Human Food. If these conditions exist, then human-grade claims may be made. If these conditions do not exist, then making an unqualified claim about ingredients being human grade misbrands the product.

Natural

The term “natural” is often used on pet food labels, although that term does not have an official definition according to the FDA. AAFCO has developed a feed term definition for what types of ingredients can be considered “natural” and “Guidelines for Natural Claims” for pet foods. For the most part, “natural” can be defined as a lack of artificial flavors, artificial colors, or artificial preservatives in the product, except for vitamins, minerals, and other trace ingredients.

Companies can “stretch” this definition and have the word “natural” printed on their labels thanks to the part of the regulation that allows the term “natural” to be used to describe a specific ingredient, provided that the term refers only to that ingredient and not the product as a whole.

In summary, “natural” does not mean that the pet food is minimally processed, nor does the term indicate anything about the quality of the ingredients other than the fact that they're not chemically synthesized.

Organic

According to the FDA, “organic” refers to the conditions under which the plants were grown or animals were raised and there are no official rules governing the labeling of organic foods for pets at this time. However, the USDA does have labeling standards for using the term “organic” on human food and pet food companies should abide by these rules when using the term organic.

Pet foods meeting the human standard may display the USDA organic seal with the following restrictions/rules:

“Organic”: If the food is made up of 100% organic ingredients, the label may display the official USDA organic seal. The USDA organic seal can also be used if at least 95% of the content is organic by weight, excluding salt and water.

“Made with Organic”: If at least 70% of the pet food content is organic. Can cite up to three specific ingredients or classes of ingredients on the front panel as being organic. Cannot use the USDA official organic seal.

Ingredient specific label only: If less than 70% of the content is organic only those organic ingredients may be listed and only on the ingredients panel with no mention of ‘organic’ elsewhere on the product. These foods cannot display the USDA official organic seal.

Premium/ Holistic

Pet food labels including the terms “premium”, “super premium”, and holistic are meaningless as there are no AAFCO definitions of what these mean. There’s nothing necessarily bad about these labels, but they can be misleading. In fact, pet foods using these terms are not required to contain any different or higher-quality ingredients than any other complete and balanced pet foods, according to the FDA’s web site.

Grain Free

“Grain free” pet diets are also becoming more common. This is another term that is not regulated by AAFCO, and can have several meanings. The “grain free” designation does not guarantee that the diet is low in carbohydrates. Many of these grain free foods simply substitute other carbohydrate sources such as potato or tapioca for grains. Make sure to research the foods dry matter macro nutrient profile before assuming that your pet’s grain free food is not full of carbs.