Pet food labeling is regulated at two levels. The federal regulations, enforced by the United States Food and Drug Administration (FDA), establish standards applicable for all animal feeds: proper identification of product, net quantity statement, manufacturer's name and address, and proper listing of ingredients.
Some states also enforce their own labeling regulations. Many states have adopted the model pet food regulations established by the Association of American Feed Control Officials (AAFCO). These regulations are more specific in nature, covering aspects of labeling such as the product name, the guaranteed analysis, the nutritional adequacy statement, feeding directions, and calorie statements.
The "95%" rule applies to products consisting primarily of meat, poultry or fish, and most often are canned products. They have simple names, such as "Beef for Dogs" or "Tuna Cat Food." In these examples, at least 95% of the product must be the named ingredient (beef or tuna, respectively), not counting the water added for processing and "condiments." Counting the added water, the named ingredient still must comprise 70% of the product. Because ingredient lists must be declared in the proper order of predominance by weight, "beef" or "tuna" should be the first ingredient listed, followed often by water, and then other components such as vitamins and minerals. If the name includes a combination of ingredients, such as "Chicken 'n Liver Dog Food," the two named ingredients together must comprise 95% of the total weight. The first ingredient named in the product name must be the one of higher predominance in the product. For example, the product could not be named "Lobster and Salmon for Cats" if there is more salmon than lobster in the product. Because this rule only applies to ingredients of animal origin, ingredients that are not from a meat, poultry or fish source, such as grains and vegetables, cannot be used as a component of the 95% total. For example, a product named "Lamb and Rice Dog Food" would be misbranded unless the product was comprised of at least 95% lamb.
All ingredients are required to be listed in order of predominance by weight. The weights of ingredients are determined as they are added in the formulation, including their inherent water content. This latter fact is important when evaluating relative quantity claims, especially when ingredients of different moisture contents are compared.
For example, one pet food may list "meat" as its first ingredient, and "corn" as the second ingredient. The manufacturer doesn't hesitate to point out that its competitor lists "corn" first ("meat meal" is second), suggesting the competitor's product has less animal-source protein than its own. However, meat is very high in moisture (approximately 75% water). On the other hand, water and fat are removed from meat meal, so it is only 10% moisture (what's left is mostly protein and minerals). If we could compare both products on a dry matter basis (mathematically "remove" the water from both ingredients), one could see that the second product had more animal-source protein from meat meal than the first product had from meat, even though the ingredient list suggests otherwise.
At minimum, many state regulations require a pet food to guarantee the minimum percentages of crude protein and crude fat, and the maximum percentages of crude fiber and moisture. The "crude" term refers to the specific method of testing the product, not to the quality of the nutrient itself.
Any claim that a product is "complete," "balanced," "100% nutritious," or claims of a similarly nature that suggests a product is suitable for sole nourishment when it is not, in fact, nutritionally adequate for such purpose is a potentially unsafe product. For this reason, an AAFCO nutritional adequacy statement is one of the most important aspects of a dog or cat food label. A "complete and balanced" pet food must be substantiated for nutritional adequacy by one of two means.
Feeding directions instruct the consumer on how much product should be offered to the animal. At minimum, they should include verbiage such as "feed ___ cups per ___ pounds of body weight daily." On some small cans, this may be all the information that can fit. The feeding directions should be taken as rough guidelines, a place to start. Breed, temperament, environment, and many other factors can influence food intake. Manufacturers attempt to cover almost all contingencies by setting the directions for the most demanding. The best suggestion is to offer the prescribed amount at first, and then to increase or cut back as needed to maintain body weight in adults or to achieve proper rate of gain in puppies and kittens. A nursing mother should be offered all the food she wants to eat.
Pet foods can vary greatly in calorie content, even among foods of the same type (dry, canned) and formulated for the same life stage. Feeding directions vary among manufacturers, too, so the number of calories delivered in a daily meal of one food may be quite different from another. The number of calories in a product roughly relates to the amount of fat, although varying levels of non-calorie-containing components, such as water and fiber, can throw this correlation off. The best way for consumers to compare products and determine how much to be fed is to know the calorie content. AAFCO regulations have been developed to allow manufacturers to substantiate calorie content and include a voluntary statement.
Many pet foods are labeled as "premium," and some now are "super premium" and even "ultra premium." Other products are touted as "gourmet" items. Products labeled as premium or gourmet are not required to contain any different or higher quality ingredients, nor are they held up to any higher nutritional standards than are any other complete and balanced products.
Pet owners and veterinary professionals have a right to know what they are feeding their animals. The pet food label contains a wealth of information, if one knows how to read it. Do not be swayed by the many marketing gimmicks or eye-catching claims. If there is a question about the product, contact the manufacturer or ask an appropriate regulatory agency.
US Food and Drug Administration/February 2011