Info on pet food labeling requirements

Clarification on labeling rules
Admin | April 20, 2007 2:11 pm
One topic that has come up frequently in the past few days, especially due to more foods being recalled due to possible contamination, is the legality of pet food companies using outdated packaging material.

Many claim that there is a legal "grace period" to use up packaging materials that do not correctly reflect the ingredients used. Time frames cited vary depending on who you ask, the replies range from 3 months to 6 months.

Not too long ago I learned that there actually is no provision by AAFCO for a "grace period" to let pet food companies use up outdated packaging material that does not reflect ingredients correctly, as many companies claim.

Yesterday the following question was asked on the forum at OurDogsOnline:



[blockquote]Natural Balance said label laws prevent them from putting ingredient stickers on bags, therefore they were 'forced' to continue using up their old bags even though the formula changed.

Eagle Pack made one formula, a Prism one, with rice protein. They've removed that ingredient and reflected the change with ingredient stickers on the bags until the new ones arrive in May.

Is Eagle Pack breaking some law, or is Natural Balance lying?[/blockquote]


I wanted to provide up-to-date information, so I contacted John Marsman, the nutritionist at Eagle Pack for some first hand information, and this is what he told me:



[blockquote]For a while AAFCO sort of looked the other way about allowing makers to use up bags. At the AAFCO meeting 3-4 years ago they made a specific statement that they would no longer permit this.
[/blockquote]


A second source, Gregory Kean, Director of Product Development & Quality Assurance at Old Mother Hubbard, Inc. (Wellness brand foods) gave the following response:



[blockquote]Eagle pack stickering is correct. [...]

The entire industry seems to subscribe to some "6 month" rule by AAFCO or the FDA. The truth is that there is no such rule that allows for a grace period. I once asked Dave Dzanis (former head of the FDA/CVM) about this rule. He confirmed that there is no grace period. Interestingly though, some state regulators will give a grace period on old packaging for changing marketing claims they deem objectionable*. That is the only time I have heard of a grace period.[/blockquote]



* Emphasis here is mine, for clarification.

Many people are currently upset after finding out that foods contain ingredients not even mentioned in the ingredient list, to which I would like to make the following clarification:

The ingredient list does not have to contain all the ingredients present in a food. There are two exceptions:

1. A company does not have to declare ingredients that it did not add but were already present in a food ingredient bought from a supplier.
2. Any ingredient that is deemed a "processing aid" rather than an actual food ingredient.