Keeping pet food compliant
By Darren Stephens
The 2016 Association of American Feed Control Officials (AAFCO) Official Publication saw some much-anticipated changes to pet food nutrient profiles. For companies producing new products, this meant quickly adapting product specs to meet the Jan. 1 deadline. For others that have existing products on the shelves, the clock has begun to countdown to the grace period’s formal end on Jan. 1, 2018.
In this blog, we’ll review the most notable AAFCO changes and the steps pet food manufacturers must take to stay in compliance.
Critical Changes: Calcium requirements
Although important updates were made to various pet food nutrient values, including vitamin ranges and crude fat requirements, changes related to calcium inclusions in dog foods were viewed to be the most significant of the AAFCO updates. For companies whose product diets were/will be substantiated for nutritional adequacy by formulation, this often meant going so far as to reformulate new and/or existing products.
Specifically, calcium minimum requirements dropped from 0.6 percent to 0.5 percent dry matter (DM) for adult maintenance dog foods and jumped from 1.0 percent to 1.2 percent DM for dog food intended for growth and reproduction. While calcium limits for adult maintenance dog foods and dog foods intended for any life stage remained unchanged (2.5 percent), the maximums allowed for large-sized breeds (greater than 70-pound anticipated adult weight) was adjusted to 1.8 percent DM to better manage growth rates.
Reformulating, repackaging, relabeling
What does all of this mean for retailers whose store brand dog foods products are currently on shelves or were about to be released to market prior to the recent deadline? The calcium requirements change is a perfect example of how quickly pet food retailers need to adapt when new compliance requirements take effect. Even those that did not need to reformulate their product had to swiftly take action in order to remain in compliance.
For companies whose products now fall out of the tighter range of calcium allowed in dog foods intended for all life stages and sizes, reformulation was hard to avoid. In some cases, the other option was to repackage to designate the food for smaller dogs. However, even if a reformulation or repackaging was not required, all puppy and all-life-stage dog foods had to be relabeled, and the nutritional adequacy statement intending the dog food for “growth” or “all life stages” had to include an amendment, “including growth of large size dogs (70 pounds or more as an adult)” if the maximum calcium was 1.8 percent or less, or "except for growth of large size dogs (70 pounds or more as an adult)" if the maximum calcium is greater than 1.8 percent (without exceeding the limit of 2.5 percent). This means that virtually every dog food manufacturer has had or will have to make some change to products before they can safely hit the shelf after the grace period has ended.
Broad impact
As seen here, the impact of updated pet food guidelines and regulations can affect not only product development but also marketing, sales and beyond. That’s why it is critical that your in-house manufacturing unit or contract manufacturer maintain a constant and expert knowledge of AAFCO requirements. When a change occurs, the manufacturing enterprise should be ready to present the different paths for achieving compliance and the associated costs, along with a spec sheet and a guaranteed analysis of your product. Without taking the appropriate steps, your product could throw up red flags for state regulators and ultimately jeopardize your product registration.
The moral of the story? Whether your product is currently on the shelf anticipating the 2018 deadline or you are just getting started on a new formulation, work with a manufacturing team that keeps pace with regulations to ensure compliance, safeguard pet health and maintain an efficient and cost-effective route to successful and safe product release.
Stephens is senior vice president of technical services for the American Nutrition Inc.