They have to Prove It

They have to Prove It

 

Did you know that pet food manufacturers are required to prove all label and website claims? Here’s how you can play a significant role in holding pet food manufacturers accountable for their claims.

Take a look at the following examples of a pet food website and the pet food label…

They have to Prove It

The Cesar pet food brand holds the trademark name of “Home Delights”. The pet food description on the Cesar website claims “is the taste of home” and (more than) alludes to human grade quality of ingredients stating “made from ingredients that can be found in your own kitchen.”

The pet food packaging…

They have to Prove It

…makes claims of “Real Beef” and “Real Vegetables” plus includes an image of an actual human meal (alluding to the pet food “Flavor” Pot Roast).

This pet food is telling consumers – through words and images – that this dog food is human food pot roast in a bag.

Per the law, all pet foods are required to prove label and website claims are truthful.

Let’s look at the law.

Association of American Feed Control Officials (AAFCO) pet food regulation PF2(c) states: “A vignette, graphic, or pictorial representation on a pet food or specialty pet food label shall not misrepresent the contents of the package.”

It’s very simple, pictures on pet food labels MUST represent the contents within the pet food package. Per regulation PF2(c) the above exampled pet food is required to contain chunks of raw beef and vegetables as well as cooked beef and vegetables – just like what the image on the package displays. Anything less would mean the ‘pictorial representation’ of the pet food misrepresents the contents of the package.

Per AAFCO, pet food manufacturers are required to provide evidence/proof of all claims. “All claims are required to be supported by sound scientific or empirical evidence.” “The rules apply to all graphics and text in all labeling about the product.”

Empirical evidence “is information that verifies the truth (which accurately corresponds to reality) or falsity (inaccuracy) of a claim. Empirical evidence is information acquired by observation or experimentation.”

In other words, when questioned by a regulatory authority or consumer – pet food manufacturers are required to provide empirical evidence. In this case empirical evidence could be photographs of ingredients prior to manufacturing – to verify the accuracy of an image on a pet food label. Regulation clearly states images should “not misrepresent the contents of the package” – and when a request is made, the manufacturer is required to have evidence to support any image on the pet food label.

Responsibility.

AAFCO also tells us: “It is the state feed control official’s responsibility in regulating pet food to ensure that the laws and rules established for the protection of companion animals and their custodians are complied with so that only unadulterated, correctly and uniformly labeled pet food products are distributed in the marketplace and a structure for orderly commerce.”

Our State Department of Agriculture officials are the individuals responsible for enforcing law. Why aren’t they? Perhaps because they need to hear from consumers…pushing them to fully and properly enforce law.

Consumers voice.

Whenever you see a pet food label or website that displays beautiful images of ‘food’ ingredients, ask for the empirical evidence of ‘food’ ingredients in the pet food from your State Feed Control Official.

Step #1. Find your State Feed Control Official by visiting this page of the AAFCO website: https://www.aafco.org/Regulatory

Scroll to this map…They have to Prove It

…and click on your state.

On your state’s page, locate the email address of your “Main State Feed Control Official Contact”. And send that individual an email similar to the following…

(Using the above exampled Cesar dog food as the example.)

Subject: potential violation of labeling rules

I am a pet food consumer within the state of (insert your state). I am requesting empirical evidence to the ingredients used in Cesar Home Delights Pot Roast Flavor with Garden Vegetables dry dog food. The pet food label displays chunks of raw beef and vegetables, and displays what appears to be human edible cooked pot roast. You can see these images on the Cesar website here: https://www.cesar.com/products/dry/pot-roast-flavor-with-garden-vegetables.

AAFCO regulation PF2(c) states: “A vignette, graphic, or pictorial representation on a pet food or specialty pet food label shall not misrepresent the contents of the package.” The AAFCO website states: “All claims are required to be supported by sound scientific or empirical evidence.” “The rules apply to all graphics and text in all labeling about the product.”

Again, the ‘pictorial representation’ of this dog food displays chunks of raw beef and vegetables, and displays what appears to be human edible cooked pot roast. I am requesting the empirical evidence that supports the accuracy of the images on the label and on the website. If such evidence cannot be provided, I am requesting a stop sale order be issued for this pet food due to label violations (misleading images).

Thank you in advance for your investigation into this compliance issue.

(Your name.)

If you want to call to the regulatory authority’s attention more details of a pet food’s marketing alluding to human grade claims, this paragraph can be added…(again, for example purposes – the Cesar dog food displayed above is used)…

This Cesar dog food includes the following statement alluding to human grade ingredients: “made from ingredients that can be found in your own kitchen.” It is my understanding that human grade claims “is only acceptable in reference to the product as a whole. The feed term specifies that every ingredient and the resulting product must be stored, handled, processed, and transported in a manner that is consistent and compliant with regulations for current good manufacturing practices (cGMPs) for human edible foods as specified in 21 CFR part 117.” Source: AAFCO Guidelines for Human Grade Claims (1). If this pet food does not meet all the requirements of the human grade claim, should they be allowed to tell consumers the pet food is made from human grade ingredients?

Consumers can also ask pet food manufacturers for the empirical evidence validating the accuracy of images on a pet food label/website. Example email to a pet food manufacturer…

Subject: validation of label claims

(Using the above exampled Cesar dog food as the example.)

I am requesting empirical evidence to the ingredients used in Cesar Home Delights Pot Roast Flavor with Garden Vegetables dry dog food. The pet food label displays chunks of raw beef and vegetables, and displays what appears to be human edible cooked pot roast.

AAFCO regulation PF2(c) states: “A vignette, graphic, or pictorial representation on a pet food or specialty pet food label shall not misrepresent the contents of the package.” The AAFCO website states: “All claims are required to be supported by sound scientific or empirical evidence.” “The rules apply to all graphics and text in all labeling about the product.”

Again, the ‘pictorial representation’ of this dog food displays chunks of raw beef and vegetables, and displays what appears to be human edible cooked pot roast. I am requesting the empirical evidence that supports the accuracy of the images on the label.

Thank you in advance for providing validation to your label claims.

(Your name.)

Just to show how bad this problem of misleading images is (how regulatory needs more than a little push from consumers to enforce law), below are just a few examples of labels/websites that could be misleading…

This picture of a FreshPet dog food directly links an image of grilled chicken to the dog food product:

They have to Prove It

Freshpet should provide empirical evidence that grilled chicken is in this dog food.

This Iams cat food displays slices of roasted turkey, the name of the product includes the claim “Slow Cooked Turkey”

They have to Prove It

Iams should provide empirical evidence that roasted turkey is in this cat food and provide evidence the turkey was slow cooked.

The Iams website claims this dog food is “made with high-quality animal proteins”

They have to Prove It

Rachael Ray Nutrish makes a direct claim of human grade chicken breast in their Chicken Purrcata cat food…

They have to Prove It

Meow Mix displays an image of roasted chicken on the label…

They have to Prove It

And Meow Mix makes the claim of human grade cat food by directly linking “the restaurant experience” to their cat foods.

They have to Prove It

And this Merrick dog food displays an array of human grade ingredients including grilled chicken…

They have to Prove It

If all of these graphic and text claims are accurate – then each company should have no problem providing a consumer or regulatory authorities with the empirical evidence validating the claim.  But if they are not accurate/truthful claims, these pet food companies (and many more) are guilty of mislabeling and these pet foods should immediately be pulled from store shelves for misleading consumers.

We need to ask for the evidence to the claims. All claims.

Any consumer can request the scientific or empirical evidence to any label or website claim. It is your right to be provided with the evidence and their responsibility to provide it. If they claim it, they must prove it. By spending just a few minutes sending an email, consumers can play an active role in the regulatory process by holding manufacturers and regulatory authorities accountable to law. Those few minutes helps all pet food consumers.

Wishing you and your pet(s) the best,

Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
TruthaboutPetFood.com
Association for Truth in Pet Food

They have to Prove It
Become a member of our pet food consumer Association. Association for Truth in Pet Food is a a stakeholder organization representing the voice of pet food consumers at AAFCO and with FDA. Your membership helps representatives attend meetings and voice consumer concerns with regulatory authorities. Click Here to learn more.

What’s in Your Pet’s Food?
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They have to Prove It

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Cooking pet food made easy, Dinner PAWsible

 

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