Pet food manufacturer are selling more and more dog foods labeled “natural,” “human grade” and “organic,” and the industry considers them to be the hot new trend. Let’s take a look at exactly what these words mean in connection with dog food.
The government has never bothered to define “natural” for human foods, so this word means anything the manufacturer says it does. For pet foods, however, the Association of American Feed Control Officials (AAFCO) has a definition:
Natural: A feed or ingredient derived solely from plant, animal or mined sources, either in its unprocessed state or having been subject to physical processing, heat processing, rendering, purification, extraction, hydrolysis, enzymolysis or fermentation, but not having been produced by or subject to a chemically synthetic process and not containing any additives or processing aids that are chemically synthetic except in amounts as may occur unavoidably in good manufacturing processes.
Clear as mud, right? You can grind, heat, render or extrude a pet food to an unrecognizable mush, but it’s “natural” according to AAFCO if you haven’t added anything synthetic—unless your “good manufacturing process” requires you to. AAFCO also says that “natural” must not mislead and if the word appears on the label, every ingredient in the product must meet the definition. Unfortunately that is a standard that is impossible to meet. Pet food companies typically buy vitamins, minerals and other additives from factories overseas because they are cheaper, and, where, as we learned in last year’s pet food recalls, quality controls are sometimes nonexistent. US and European sources have strict quality controls and are a bona fide source for natural ingredients.
We do not see too many claims about human-grade ingredients on package labels, mainly because AAFCO does not have an official definition of the term, and without an approved AAFCO definition, an ingredient or term is not supposed to be used on pet food labels. AAFCO says “human-grade” is false and misleading, and constitutes misbranding, unless every ingredient in the product—and every processing method—meets FDA and USDA requirements for producing, processing and transporting foods suitable for consumption by humans, and every producer of the ingredients is licensed to perform those tasks. Few pet food companies can meet these criteria.
In spite of the above, AAFCO’s unease does not stop pet food makers from using the term, particularly because the law appears to be on their side. In 2007, a case against The Honest Kitchen led the Ohio courts to rule that the company had a constitutional right to truthful commercial free speech, and could use “human-grade” on its labels. The Honest Kitchen advertises on its website that it is “the only pet food manufacturer in the United States to have proven to the Federal FDA that every ingredient it uses in its products are suitable for human consumption.”
Only a few other companies make human-grade claims on their food labels, but many use the term freely in their in-store materials and website advertising. For example, Newman’s Own Organics presents this information in a question-and-answer format: “Q: Does Newman’s Own Organics use human grade materials? Why isn't that written on the bag? A: Newman’s Own Organics organic pet food uses human grade and fit for human consumption ingredients such as natural chicken and organic grains. The AAFCO Board … actually prohibits the printing of ‘Human Grade’ on pet food packaging.”
So what about “organic” in the context of pet food? For human foods, “organic” has a precise meaning defined by the USDA’s National Organic Program (NOP). To be certified as organic, plant ingredients in pet foods must be grown without pesticides, artificial fertilizers, genetic modification, irradiation or sewage sludge. Animal ingredients must come from animals raised on organic feed, given access to the outdoors, and not treated with antibiotics or hormones. Producers must be inspected to make sure they adhere to these standards. (Note: Even if they are inspected, whether the standards are good enough is a separate question- see below regarding GMO animal feed.)
In 2002, the NOP did not include pet foods in the organic rules because it could not figure out how to do so. In 2005, it appointed a pet food task force to examine the issue, and this group recommended that organic standards for humans be applied to pet foods. In discussing their recommendations, the NOP cautioned, “these requirements will present challenges for pet food manufacturers, especially sourcing non-genetically engineered ingredients.” The NOP was referring to the fact that 88% of corn, 93% of soybeans, over 50% of the alfalfa and sugar beets grown in the US are all GMO products. These are all commonly used in either feeding animals used in pet food manufacturing or directly used in the manufacturing. Another very interesting fact is that there is no governmental requirement that these GMO items be labelled as GMO products. So how does a feed lot who professes to be non-GMO actually know it’s feed it non-GMO? The short answer is it probably doesn’t and is relying on the supplier.
And what does the term GMO actually mean for these animal feed and pet food products? The majority of these GMO products contain a pesticide that cannot be washed off. Most GMO products grown in the US are “Roundup Ready” which means they will be able to withstand spraying with Monsanto’s Roundup and grow while the weeds around it die. Of course, whether or not the Roundup ever gets washed off the product is another question.
To date, the NOP has not yet adopted the task force recommendations and organic pet foods are in regulatory limbo, leaving AAFCO to explain how to label “organic” pet foods. AAFCO says that (1) under NOP rules, pet foods may not display the USDA organic seal or claim that they were produced according to organic standards. But (2), NOP also says labeling terms such as “100% organic,” “organic” or “made with organic ingredients” on pet foods may be truthful and do not imply organic production or certification. Therefore (3), AAFCO recommends that labeling rules for human foods apply to pet foods.
So what does this actually mean in terms of pet food? Many industry insiders, and most of the pet food manufacturers think the statements imply that nobody is going to make a fuss about organic claims on pet foods, even when some, most or even all of their ingredients are not really organic.
Following the rules for organic labeling is extremely complicated. Even so, you can go into a pet food store and easily find products that violate these standards. In fact, most of the major pet food manufacturers are actually many of their products organic when their foods may contain only a single organic ingredient.
At the moment while “organic” means something for human food it does not mean much for pet food. Many industry insiders believe that the USDA doesn’t think pet foods are important enough to care what is said on their labels or have the budget to enforce pet food labels vs human food labels.
So how do you really know if a pet food is organic? We at Raw Wild can only speak for our product. Our ingredients come from wild animals from the Rocky Mountains and have no access to any GMO feed or pesticide or insecticide sprayed feed. They eat what they have for hundreds of thousands of years- naturally growing grasses and plants in the wilds of the American West.
In addition, Raw Wild is made in a USDA inspected, human grade facility that only processes wild game animals so there is no danger of any cross contamination with commercially raised animals.
Feel free to contact us at your convenience through the Contact Us section of our web site.