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The Truth Behind The FDA, AAFCO, & NRC: Regulations in Commercial Dog Food.

Updated: Apr 25

dog looking at dog kibble in a bowl

The Food and Drug Administration (FDA), the National Research Council (NRC), and the Association of American Feed Control Officials (AAFCO) are three pivotal entities involved in regulating commercial dog food. While their responsibilities are interconnected, each organization operates autonomously.

In 1993, AAFCO utilized NRC data to create nutrition profiles for commercial (kibble and wet or canned) dog foods, which are still updated yearly. These profiles serve as the primary reference for nutrient guidelines in commercial dog foods in the United States. Despite this, the NRC has not issued new requirements since 2006, rendering the existing information outdated and not fully reflective of current nutrition research trends.

German Shepherd with eye glasses looking surprised

So, What is the FDA's Function:

The FDA, part of the U.S. Department of Health and Human Services, is vital for protecting public health. It ensures that medications, medical devices, vaccines, food, cosmetics, and other products for both humans and pets are safe and effective. By closely monitoring these products, the FDA helps ensure that consumers can rely on their quality.

The FDA in the US monitors the safety of commercial dog foods, regulating production, labeling, and distribution to prevent any risks. It also addresses complaints and recalls products if needed.

So what happens if there is a recall?

  1. Investigating Dog Food Concerns: A dog food company investigates contamination or quality issues through internal inquiry on production and ingredients.

  1. FDA Notification: If a safety/quality issue arises, the company must report it to the FDA, which monitors dog food safety.

  1. FDA Assessment: The FDA reviews company reports, may investigate further, assesses the risk to dogs, and determines the necessity of a recall.

  1. Product Recall: The FDA collaborates with dog food companies on voluntary recalls to remove harmful products.

  1. FDA Supervision: The FDA manages recalls to ensure efficiency and speed, informing consumers through public announcements.

Moving on to the NRC:

The NRC examines subjects such as animal nutrition, agriculture, environment, and technology. It has previously produced reports about what healthy dogs need to eat. These reports help companies make what they consider to be good commercial-brand dog food. The NRC used research to decide how much nutrients dogs need as they grow up. However, as previously stated, the last report was in 2006, so it's not up-to-date with new research on nutrition.

puppy covering eyes with paw

Now, on to AFFCO:

AAFCO has been regulating dog food in the US since 1909, ensuring safety and nutrition. Rules were updated in the 1950s to set ingredient standards. Industry reps meet twice a year to discuss policies. AAFCO establishes regulations for animal feeds and dog foods, which states adopt as law. Nutrient requirements for different life stages must be met, and label claims must be approved. New ingredients are checked for safety, and guidelines for claims on labels are set. Manufacturers must follow specific rules when testing products.

While AAFCO does not ban or approve dog foods, they provide guidelines for manufacturers who wish to use terms like complete and balanced on labels.

There are three types of active voting members in AAFCO: 1) Officials who enforce laws about animal feed production, labeling, and sale. 2) Department heads or staff from labs that test animal feed. 3) Researchers who study animal feed. The Board of Directors has nine members who vote yearly and create groups to work on tasks set by the President. Industry experts can also join these groups as advisors. Anyone can attend AAFCO meetings as an observer, and those interested in dog food can apply to be non-voting advisors appointed by the President of the Board.

Billboard with AAFCO information

Dog foods that do not meet AAFCO standards:

It may come as a surprise to some well-meaning dog parents that some dog food companies don't follow AAFCO guidelines. In fact, a study of over 150 dog foods found that many didn't meet these guidelines. 

This is because labeling rules are voluntary and depend on trust, with FDA investigations only starting from complaints. Therefore, standards for analyzing dog food ingredients are not well-established.

Furthermore, the NRC doesn't appear to consider essential fatty acids to be important for dogs' nutrition. In 1985, they said only linoleic acid was essential, but studies have found four more essential fatty acids that our dogs need: ALA, ARA, EPA, and DHA. Perhaps it’s because of cost. AAFCO mainly focuses on LA as an essential fat, or possibly because the other essential fatty acids shorten the kibble's shelf life due to oxidation. Regardless, it most likely comes down to the all-mighty dollar and not truly our dog’s health and well-being.

So, what ingredients are used to establish guidelines:

AAAS (American Association for the Advancement of Science) guidelines use common feedlot ingredients like carbohydrate, fat, fiber, and protein sources chosen for their cost efficiency. Examples include meat and bone meal, animal by-product meal, fish meal, and more. These ingredients are nutritionally deficient due to high-temperature exposure during manufacturing, leading to the formation of harmful compounds. Then synthetic vitamins and minerals are usually added to meet AAFCO guidelines for dog food, but this type of vitamin delivery does not convert well in our dogs, leaving many voids of vital nutrients.

Passing dog Food Safety Standards:

Dog food manufacturers must adhere to the rigorous standards of AAFCO to ensure their products' nutritional adequacy and safety. One key aspect of these guidelines is the requirement that dog foods pass a feeding trial, which critically evaluates the food's ability to provide essential nutrients for dogs over an extended period. During this trial, a group of dogs is fed solely with the specific dog food being tested while veterinarians and researchers closely monitor their health and well-being.

An effective food test ensures that at least six out of eight dogs remain alive for 26 weeks, with none losing more than 15% of their body weight and all blood values meeting the required minimum.

By adhering to these strict guidelines, dog food manufacturers can demonstrate that their products meet the nutritional requirements established by AAFCO to ensure optimal dog health and wellness.

No Just No meme

AAFCO Standards will not work well for home-cooked or even raw dog diets and could be harmful. These guidelines are made for processed kibble, which differs from home-cooked or raw food regarding nutrient availability. Home-cooked or raw food diets have fewer phytates than kibble, so minerals are absorbed better. 

In other words, following AAFCO guidelines for home-cooked raw diets could cause mineral toxicities, which could make your dog sick or worse. Processed kibble needs artificial supplements because nutrients are cooked out during manufacturing, but home-cooked or raw food naturally has all the needed nutrients.

In conclusion, canine nutrition experts are questioning the rules made by the FDA, AAFCO, and NRC for commercial dog food. These rules aim to make sure dog food is safe and nutritious, but they often don't meet all the dietary needs of dogs. The strict standards from these agencies might limit the variety of ingredients in dog food, which can cause nutrient problems and harm dogs' health. Also, relying on minimum requirements instead of optimal nutrition levels could lead to poor quality control in the dog food industry. Dog owners need to carefully check the nutrition and sourcing of commercial dog food to make sure their dog gets a balanced diet that meets their health needs.

Home-cooked or raw food provides numerous benefits for our dogs compared to kibble. These natural diets offer higher-quality ingredients and better nutritional value and can help address specific health issues. By preparing meals at home, dog owners have more control over what their dogs eat and can tailor their diet to meet their individual needs. Additionally, feeding fresh food can improve digestion, healthier skin and coat, and increase energy levels in our furry companions.

It is time we consider switching to home-cooked or raw food for our dogs to ensure they lead long, healthy lives filled with vitality and happiness.


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