ORLANDO, FLA. — For the last eight years, the Association of American Feed Control Officials (AAFCO) has been in the midst of what Executive Director Austin Therrell describes as a “huge undertaking,” with the end goal of realigning pet food labels with consumer expectations and understandings. This effort, dubbed pet food label modernization (PFLM), is finally coming to a head this fall, and it’s crucial for processors to be aware of how proposed changes will affect their product packaging.
Therrell and Bill Bookout, president and founder of the National Animal Supplement Council (NASC) and pet food consultant with the American Pet Products Association (APPA), presented an update on PFLM during Global Pet Expo 2023, held March 22 to 24 in Orlando.
The idea of pet food label modernization started in 2015 following consumer requests for dog and cat food and treat labels that were more transparent and easier to understand.
“That initial charge to the AAFCO Pet Food Committee led to eight years of work and thousands of dollars invested by AAFCO in consumer research to help guide that process,” Therrell said.
In 2018, AAFCO conducted a round of consumer research to determine which changes needed to be made as part of PFLM. In 2019 and again in 2022, follow-up rounds of consumer research were conducted to track consumer feedback as AAFCO presented potential changes to pet food labels. This research included a range of dog and cat owners ages 21 to 65, focusing on owners that are solely or jointly responsible for pet food purchasing decisions. These pet owners were asked open-ended questions and presented with both traditional and modernized labels, which they provided qualitative feedback about their understanding of the product and its intended use.
Using feedback gathered during this research — as well as received during a 30-day public comment period in the fall of 2022 — the AAFCO Pet Food Committee came up with four key modernization initiatives: standards for an optional handling and storage statement, an updated nutrition facts box that more closely resembles those seen on human foods, improved guidelines for ingredient statements (specifically for sugar, dietary starch and fiber), and a more prominent and unified intended use statement, such as seen on the front of pet food packaging.
Handling and storage
PFLM does not require brands to include handling and storage information on packaging; however, it does provide a standard appearance and set of graphics for including these types of instructions. Specific instructions will be based on product type, and the size of fonts depends on the size of the packaging panel. Brands can benefit from a range of streamlined optional icons that depict common safe handling guidelines.
“If someone did want to include handling and storage instructions, it needs to be in a bolded header… and has to be kept separate and distinct from the feeding directions,” Therrell explained.
Nutrition facts box
A new “Pet Nutrition Facts” box will replace the existing guaranteed analysis statement (or expression of guarantees) currently required on the back of pet food packaging. The idea is to offer consumers a more familiar visual, not far from nutrition facts they may find on the labels of their own food products.
“The required guarantees are similar, crude protein, crude fat, but instead of crude fiber, now you'll have total carbohydrates — including dietary fiber — and moisture. Any additional guarantees that you want to be made on the label should follow moisture,” Therrell said.
In the new Pet Nutrition Facts box, the calorie statement will be required underneath the unit of measure. Therrell explained that there are some exemptions for small packages with a total printable area of less than 40 square inches, such as small cans of wet food. In these cases, the Pet Nutrition Facts may be stated in paragraph form. This section can be abbreviated even further for packages with less than 12 square inches of printable area, he added.
Additionally, the Pet Nutrition Facts box has been updated to include a common household unit of measurement to help pet owners ensure they are feeding the correct amount to their pets, as well as the suggested weight in grams per serving. No changes have been made to the existing nutritional adequacy statement: “This product is formulated to meet the nutritional levels established by the AAFCO [Dog or Cat] Food Nutrient Profiles.”
For specialty pet food labels, the calorie statement and maximum starch and sugar guarantees are not required as a part of the Pet Nutrition Facts box.
Some changes to the ingredient statement seen in PFLM have already been implemented by AAFCO, including the use of common names for certain ingredients, as well as key vitamins and minerals. Therrell described this as a harmonization of “consumer-friendly vitamin nomenclature.”
For example, vitamins, such as vitamin B1, can be listed as “Vitamin B1 (Thiamine Hydrochloride),” with scientific names following in parenthesis. Vitamin and mineral premixes “can be declared as ‘vitamin’ or ‘minerals,’ followed by a parenthetical listing of those vitamins and minerals in the order of predominance by weight as they occur in the ingredient statement of the premix label,” according to Therrell.
Another PFLM change to the ingredient statement is regarding fish-based ingredients. For ingredients consisting of fish, fish meal, or fish by-products, the name of the ingredient may include “fish” without further specification of the type of the fish or may bear a name descriptive to the type of fish it is (i.e., ocean whitefish, salmon by-products, sea bass, bream, cod meal, etc.) Lastly, PFLM makes it possible for brands to call out organic ingredients in the ingredient statement (i.e., “organic blueberries,” “organic rice”) as long as they are in fact certified by the USDA National Organic Program.
Intended use statement
The intended use statement will have front-of-pack implications with the intention of making it easier for consumers to quickly recognize a product’s intended use (i.e. “Complete food for puppies,” “Complete adult cat food,” “Dog food mixer,” “Cat treat,” etc.). This new PFLM standard will require the intended use statement to be displayed on the front of a package — or the panel most likely to be presented and examined at retail, known as the principal display panel (PDP). This statement will be required in the bottom 30% of the PDP, unless the PDP measures 5 square inches or less.
According to AAFCO, various intended use statements have been defined as follows:
- “Veterinary Diet for [Species]” — for food to be used under veterinary supervision
- “[Species] Treat” — for food provided occasionally for enjoyment, not a complete food or nutritional supplement
- “[Species] Food Supplement” — for food intended to supply specific nutrients but are not a complete diet
- “Food Mixer” — a food product that is intended to… contribute to a complete diet
- “Daily [Specialty Pet Species] Food” — for food products that are intended to be the daily diet for specialty pets where no recognized nutritional authority exists. A limited life stage diet may be indicated as: “Daily [Specialty Pet Species] Food for [Juveniles or Adults]”
According to Therrell, when presented with modernized labels, 75% of consumers on average noticed the intended use statement right away without being prompted, and more than 80% of consumers said they found the label information easy to understand.
Timeline and implementation
AAFCO will put PFLM up for a membership vote in August. If the vote goes in favor, it will then be implemented on a state-by-state basis. Regulators in each state will decide if they will adopt the new PFLM guidelines in full, partially, or not at all.
According to Therrell, 28% of states, or 14 states, say they plan to enact PFLM changes, while 8% do not plan to enact the changes, and the majority — 64% — of states are still deciding how to work through their specific rule making procedures.
Anticipated obstacles for implementing PFLM include staffing and resources, understanding of the new guidelines, industry education, training, agency and state support, technological implications and budget.
AAFCO is currently developing training and outreach materials to support the industry as well as regulators, retailers, veterinarians, and consumers in the case that PFLM is approved in August. Therrell also noted AAFCO has seen buy-in and support from across the industry.
“I don’t think we’ve had pushback to any significant degree or extent,” he said. “The only issue that’s been at all contentious is how long [industry members] will have to implement this — the industry wants to be sure that business is not disrupted, and I want to reinforce that AAFCO has been very conscious of that.”
AAFCO expects the implementation period for PFLM will be between five to seven years. During the transition period, Therrell noted regulators in each state would likely exercise enforcement discretion, understanding that companies are investing in making changes to meet state-by-state guidelines as they may change.
“We realize it's a huge undertaking,” Therrell said. “This is one of the largest projects that AAFCO has ever worked on.”
Find more resources about PFLM from the AAFCO Pet Food Committee.
For more regulatory news affecting the pet food market, visit our Regulatory page.