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

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Submitted by Heidi Junger | December 13 2009 |

When I saw the title of this article, I was happy that an expert would finally clear the clouds hovering over organic pet food claims. But I soon was quite disappointed that the authors didn't realize that *certified* organic pet food claims ARE regulated and enforced by the government and its accredited organic certification agencies.

As certified organic pet food manufacturer (www.onestaorganics.com), I know this much. Unlike non-certified organic pet food claims, certified organic pet food claims are as stringently regulated and enforced as are certified organic claims for human foods. These claims are verified by an unbiased 3rd party (i.e., organic certifiers such as Oregon Tilth, OAI, etc.)

As pet food manufacturer, I believe that organic certification provides generally the best regulatory system available for pet foods. Among others, organic certification ascertains that those well known undesirable, undefinable ingredients (4Ds, GMOs, byproducts, pesticide-, hormone-, antibiotic-treated ingredients, etc.) are not included in certified organic pet foods.

Here is what a State compliance officer at CDFA (California Department of Food and Agriculture) wrote to me in 2008:
"It is buyer be ware of any pet food product that does not show that it is certified by one of the NOP certification agents."

Here is what a Green Seal staff member wrote to me:
"USDA organic certification is the best and most credible label for pet and human food products, also in respect to any green claims."

But you don't have to believe me, the CDFA officer, or Green Seal member who I communicated with. Simply call or email USDA or one of the organic certification agencies and ask if certified organic pet food claims are regulated and enforced or not (or if they even exist!). Just don't believe everything that's written; even otherwise very well-informed and knowledgeable expert's can't know everything or they may not be very clear. It's best to check at regulatory places which deal with particular issues on a daily basis.

I'd have loved to see a clarification on this topic in the Bark magazine. I unfortunately, never saw one, maybe I missed it, maybe it's still coming?

However, I still hear people doubting that "organic means something in the pet food industry" (quoting directly from the Bark article), while they refer to this article. Which is a shame because there is no doubt in this matter: certified organic pet foods simply are regulated and enforced, and the use of the words 'certified organic pet food' is *not* simply a marketing strategy as other non-certified pet food claims can be. A clarification on this issue would support the true (i.e., certified) organic movement for our pets and ourselves.

Anyway, Happy Holidays - Heidi

Submitted by Marion Nestle, ... | December 15 2009 |

We agree with Dr. Junger that it is certainly the case that the USDA regulates use of the term organic on foods for humans (as we explained in our article). However, the National Organic Standards Board (NOSB) has never defined what Certified Organic means for pet foods. Without established rules for pet foods, the USDA-designated certifying agencies can--and do--decide for themselves what Certified Organic means and do the best they can to apply the human standards to pet foods. This does not cause problems for treats because treats can be made with fully organic ingredients, as Dr. Junger's pet food company does. Certified Organic treats really do meet human food standards for organic certification. But certifying the organic status of complete-and-balanced pet foods presents serious problems because they contain non-organically produced vitamins, minerals, and other additives. The certifying organizations differ substantially in their interpretation of the rules about whether a complete-and-balanced food qualifies as Certified Organic. Some organizations refuse to certify any complete-and-balanced pet food because the vitamin and mineral mixes are not produced organically. Others overlook the problem, make an exception, and certify the food as organic. If you see a Certified Organic complete-and-balanced food, it means that the certifier chose to overlook the vitamin/mineral problem.

We also continue to see plenty of pet foods labeled as organic (although not Certified Organic) in their brand names or on their ingredients and we worry that most consumers cannot tell the difference between organic and Certified Organic. We think the NOSB has been sitting on this issue far too long and that clear, unambiguous organic standards for complete-and-balanced foods as well
as treats would be good for the pet food industry as well as for pet owners.

Submitted by Shireen | October 8 2013 |

These distinctions are very interesting to be aware of. There should be more awareness on the percent of organic ingredients and the labelling on packages. www.barkbites.com.au

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