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Natural, Human Grade, Organic Dog Food: Really?
An Organic Primer

Stores are selling more and more dog foods labeled “natural,” “human grade” and “organic,” and the industry considers them to be the hot new trend. But what can these words mean?

Because the government has never bothered to define “natural” for human foods, this word essentially means anything the manufacturer says it does. For pet foods, however, the Association of American Feed Control Officials (AAFCO) has an official 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.

Got that? You can render or extrude a pet food to mush, but it’s “natural” if you haven’t added anything synthetic—unless you had to. AAFCO also says that “natural” must not mislead; if it appears on the label, every ingredient in the product must meet the definition. But even AAFCO knows this is impossible. Pet food companies typically buy vitamins, minerals and other additives from factories overseas, where, as we learned in last year’s pet food recalls, quality controls are sometimes nonexistent.

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. 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.

But AAFCO’s unease does not stop pet food makers from using the term, particularly because larger legal concepts appear 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.”

That brings us to organics. 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: They do, but whether the standards are good enough is a separate question.)

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 handle the figuring. A year later, this group quite sensibly recommended that organic standards for humans be applied to pet foods. But, the NOP cautioned, “these requirements will present challenges for pet food manufacturers, especially sourcing non-genetically engineered ingredients.” No kidding. More than 90 percent of soybeans and half the corn grown in United States now come from genetically modified varieties.

Because the NOP has not yet adopted the task force recommendations, organic pet foods are in regulatory limbo, leaving AAFCO with the unenviable task of explaining 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.

What to make of this? We 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.

Mind you, following the rules for organic labeling is complicated (see chart). Even so, you can go into a pet food store and easily find products that violate these standards. Our favorite: companies calling themselves organic when their foods do not contain a single organic ingredient. They get away with this because the USDA, unlike the FDA, doesn’t regulate company names.
 
At the moment, “organic” means something for human food; it does not mean much for pet food. We worry that the USDA doesn’t think pet foods are important enough to care what is said on their labels. This may be a good situation for unscrupulous marketers, but we do not think it is good for pet food companies, buyers of pet foods or the organic industry itself. If products are labeled organic, they should follow the rules for organic certification—all of them. If they do not, the organic standards won’t mean much.

Organic foods command higher prices because people believe in the integrity of the standards. If the standards are not met, why pay more? If the USDA allows weaker standards for pet foods, we wonder whether it will continue to defend strong organic standards for human foods. Without strong standards, organics are just about marketing, not production methods. We think everyone—pet food makers, the USDA, AAFCO and the readers of Bark—should demand nothing less than the highest possible standards for natural, human-grade and organic claims on dog foods.

 

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This article first appeared in The Bark,
Issue 50: Sept/Oct 2008

Marion Nestle, PhD, is the Paulette Goddard professor of nutrition, food studies and public health at NYU; her most recent book is Pet Food Politics.