KANSAS CITY, MO. — Membership of the Association of American Feed Control Officials (AAFCO) recently approved new dog and cat food label guidelines following the yearslong pet food label modernization, or PFLM, initiative. The PFLM project was designed to revamp pet food labels in order to provide consistency and transparency for consumers. The revised Model Regulations for Pet Food and Specialty Pet Food will include new standards for nutrition information, ingredient statements, and storage and handling instructions.

AAFCO has been working with feed and pet food regulatory professionals, industry members and consumers since 2015 to develop, collect feedback and finalize strategic updates in order to develop these new label regulations.

Realizing pet food and treat brands will face an arduous process to make updates to their packaging following all the new guidelines, the association is advocating for a six-year implementation period. During this time, regulators will use discretion when reviewing labels against the new Model Regulations.

“As states begin the rulemaking process of adopting and enforcing the Model Regulations for Pet Food and Specialty Pet Food, AAFCO strongly encourages uniform and timely adoption to ensure alignment and consistency,” AAFCO stated. “Each state should make a determination on adoption and enforcement with the recommendation to begin the formal rulemaking process. AAFCO is committed to working with our members and partners to ensure as much of a uniform adoption process as possible.”

Preparing for the upcoming changes will be a laborious undertaking, one that will most likely take an organized effort involving numerous stakeholders in the industry at every stage of the production cycle. Pet food and treat processors will be looking to others in the industry to assist in the process — in understanding what needs to be done, how it can be accomplished, and what checks and balances need to be achieved along the way. As a provider of sustainable engineering, architecture, construction and consulting solutions to the food and beverage industries, including pet food, Kansas City-based CRB is offering solutions and suggestions to get processors started.  

“Whether you’re a small organization, medium or large, you need to treat this like a project,” said Katie Ireland, senior principal packaging engineer for CRB, in an exclusive with Pet Food Processing. “Put together a plan, get all the cross-functional people together. You need to determine which seats at the table are empty that you need filled to get this work done. Can you call a consultant to help? Do you need a graphic designer? What seats are missing at the table? You can’t start the process until you pull all those people together.

“I think it’s a good time to get the checklist prepared and plan,” Ireland added. “It’s going to be a huge collaborative project. You’re going to need R&D folks, QA folks, labs, packaging engineers, and your supply base on hand to help make those changes.”

One of the major changes to current pet food and treat labels involves the addition of a new Pet Nutrition Facts Box, which will more closely resemble those found on human food labels. The 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 new version will include crude protein and crude fat that was listed previously on the analysis statement, but now instead of crude fiber, the label will feature total carbohydrates — including dietary fiber — and moisture.

In addition, the new labels require an Intended Use Statement, which will be updated to a new location on the lower-third of the front display panel to help consumers easily identify the purpose of the pet nutrition product (complete-and-balanced meal versus treat or supplement). The Ingredient Statement will clarify the use of consistent terminology and will allow for common and usual names of vitamins included in the product. Finally, Handling and Storage Information is an optional addition to the new labels.

These extensive changes to the pet food and treat product labels are far more than cosmetic adjustments to packaging graphics. Because of the changes to the nutritional and ingredient statements, companies may need to change recipes or formulations. Testing of existing pet food and treat formulations, as well as new recipes, will be necessary in order to better define the ingredients and nutritional components that will end up on the label. This would be one of the first steps in the process, long before any label or packaging could be redesigned.

“When it comes to testing, the biggest challenge is going to be testing for nutritional fiber, which is now a requirement — it wasn’t something that was regularly tested for in the past,” said Pablo Coronel, Ph.D., senior fellow for Food Process & Food Safety at CRB. “There’s going to be a lot more testing needed to prepare for these changes — that’s an expense that companies will have to get ready for.”

Testing could be performed through in-house labs or third-party verification services.

“It’s more than just changing the nutritional panel on the label,” Ireland said. “If you change an ingredient you need to look through your recipe and your production process; are there any other adjustments that need to be done to make sure you end up with the same quality product? And, if you do need to change an ingredient, you also have to look at the supply chain — is that ingredient accessible right now? Will there be supply chain issues if you switch ingredients? There are so many factors to consider.”

Making adjustments to product formulations in order to create more desirable, consumer-friendly product labels can lead to a domino effect throughout the entire production process. Processors need to take this into account as they work through the PFLM process. And, it’s important to make those changes once and then commit to the changes — adjustments too far down the road could result in the need to restart the process from the beginning.

“After you set your nutritional panel, the product’s recipe can no longer be changed,” Coronel said. “If you change an ingredient, the whole panel will need to be changed and all your work will be wasted.”

After the planning is in place, background work has been done to determine if recipes need to be adjusted, and testing has been completed, the final step is tweaking the look and feel of the product’s packaging.

“The packaging is really the last piece of the process before you launch,” Ireland said. “Leave yourself plenty of time to make the final decisions about what’s going to be on the label. This whole process is going to take some time, but plenty of things have to be done before you can even get to that final step.”

The Pet Food Label Modernization initiative, while a daunting project for all pet food and treat processors, is providing the industry with an opportunity to deliver more transparency to consumers. The new labeling guidelines will provide pet parents with more information about the food they are feeding their four-legged family members, which will benefit the industry as a whole.

“It’s a great opportunity to look at your packaging and graphics in a more holistic way,” Coronel said. “I would look at it as a project in which you’re going to be able to revamp your brand and introduce it back to the market. You’re going to be able to renew the way your customers look at your brand.”

Despite the magnitude of the task at hand, processors should take a proactive, methodical approach in order to meet the proposed six-year deadline.

“Don’t leave everything to the last minute — we saw with FSMA (Food Safety Modernization Act) that never works. Try to get it right the first time to avoid unnecessary costs,” Coronel said. “Be positive. Don’t be afraid of it. Just take it step by step.”

Read more about pet food label modernization, and listen to our More Than Kibble podcast episode on PFLM with Austin Therrell, executive director of AAFCO, to learn more about PFLM.