Pet Food Standards Explained: What Dog Owners Need to Know

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This article was originally published in September of 2020, and has been updated.

Food is one of the most important decisions we make for ourselves, and for our pets. The kinds of foods we eat influence all facets of health, which is why many people are paying closer attention to where their food comes from.

But even those who are paying attention might not know what they’re really feeding their dogs—especially if they’re feeding kibble or canned food—because of the way the pet food industry makes, regulates, and labels its dog food products.

To help cut through the confusion and catchphrases, and help dog owners make informed choices, we’ve assembled some answers to key questions about pet food standards.

Is pet food regulated in the United States?

Technically, yes. But effectively, pet food is subject to little meaningful regulation.

There are two main bodies that have some say over how pet food is manufactured and labeled: the Food and Drug Administration (FDA) and the Association of American Feed Control Officials (AAFCO). But neither regulates typical pet food in the same way, or to the same standard, that our food is regulated.

The FDA states that “The Federal Food, Drug, and Cosmetic Act (FD&C Act) requires that all animal foods, like human foods, be safe to eat, produced under sanitary conditions, contain no harmful substances, and be truthfully labeled.” But there’s nothing simple about the way that those requirements are actually developed and applied.

The FDA doesn’t require any pre-market approval for pet food products. The organization does specify some high-level animal-food standards—it’s responsible for inspections of pet food manufacturers and ingredient suppliers (excluding USDA-regulated suppliers), and investigations based on complaints from consumers. But in practice, the rules aren’t rigorously enforced. Inspections are infrequent—and even when egregious behavior is uncovered, the consequences often amount to a warning and a written letter of acknowledgement.

State Departments of Agriculture also play a role in the regulation of pet food, but, like the FDA, don’t take an active role in enforcing laws, as would happen with human food. 

The FDA delegates the generation and publication of pet food rules to AAFCO.

What is AAFCO?

AAFCO is a private, voluntary-membership organization in North America that deals with animal-feed regulations, including those for pet food. Pet owners may be familiar with AAFCO from seeing it on their pet food’s label, next to the assurance that the food is “complete and balanced.” The guidelines for meeting this standard relate only to the nutrient profile of the product.

Per the AAFCO site, “AAFCO does not regulate, test, approve or certify pet food. It establishes model language that states and other governing bodies may adopt into law.”

AAFCO sets guidelines for labeling requirements, ingredient definitions and nutritional requirements but AAFCO itself has no regulatory authority. AAFCO’s membership is made up of representatives from North American agencies like state Departments of Agriculture, the FDA, and the Canadian Food Inspection Agency. These members all have authority to regulate animal feed under the laws within their respective jurisdictions.

What are pet food standards?

Traditional dog food is not subject to the same scrutiny, regulation, and rule-enforcement that applies to human food. Typical dry and canned pet food is subject to the same regulations as commercial animal “feed.”

What is my dog actually eating when I buy a bag or can of pet food?

Pet food—kibble and canned food—is typically made from parts of animals left over from the process of making human food.These ingredients are rendered at high heat into powdered “meals” (see below). The best example of a rendered product, and one that’s commonly found in commercial pet food, is “meal,” usually listed in the ingredients list as “chicken meal” or “beef meal.“ Per AAFCO’s ingredient definitions, “meal” may include not only meat and bones, but hair, hoofs, feathers, stomach contents, and the like that are unavoidable despite good processing practices.

What is rendering? 

In the words of the North American Renderers Association (NARA), “the rendering process reclaims… meat, bone, and fat and transforms it into ingredients for countless products. This physical and chemical process converts the many by-products of agriculture, and other materials noted here (like expired meats) into powder meals and liquid fats. About 85% of this product is utilized as animal feed ingredients.

What are AGEs?

All kibble—including the “premium,” or boutique-brand variety–is ultra-processed food, made via a high-heat process that robs food of nutritional value. The process also produces advanced glycation end products (AGEs). AGEs are harmful compounds linked to age-related decline. Higher AGE levels are associated with common age-related conditions like inflammation.

We ran a yearlong study comparing kibble to a fresh, human-grade food from The Farmer’s Dog. All dogs started on the same kibble. Then one group stayed on kibble, while the other switched to The Farmer’s Dog. We measured over a thousand biomarkers in their blood over time.

When we looked at all of those markers together, both groups started in the same place. But once dogs switched to The Farmer’s Dog, we saw a dramatic shift in their profiles within just 30 days—and that difference from kibble was sustained for an entire year.

Among the exciting findings was that dogs in the group that switched to The Farmer’s Dog had much lower levels of AGEs. 

Is all of this reflected on pet food labels?

No. 

On the front of a kibble bag, consumers might find images of glistening, meaty chicken breasts or marbled chunks of beef that look ready for the barbecue, rather than a photo closely resembling what’s on the inside of the package. But while these images may be misleading, people generally know to be skeptical of food photography. The back of the bag is another story. 

The sometimes mysterious nature of ingredients has come to light via studies that show that a substantial number of dry pet-food ingredient lists are inaccurate. And because all kibble looks like dried pellets, it’s impossible for a consumer to tell by looking at the product itself whether it contains any of the meats or vegetables on the labels.

Companies aren’t allowed to say that their product is made “with” a certain ingredient without using any of it at all—but they don’t have to use very much. If a food is labeled as being made “with chicken,” for example, it only has to include 3% chicken. So you’ll want to take a much closer look before you assume that what you’re feeding your dog is substantially made up of that ingredient.

There are many less-than-transparent tactics like this that companies can employ to make their food sound healthier and more appetizing than it is. For example, most people would reasonably conclude that if an ingredient comes first in the ingredient list, there’s a lot of it in the food. And it’s true that an ingredient list is organized by the weight of the ingredient, before cooking, in descending order. But, knowing that most consumers are looking for a protein source as the top ingredient in their pet’s food, companies frequently manipulate ingredient lists via “ingredient splitting,” where they list ingredients broken down into composite parts.

A product label containing 20% meat and 80% starches could either look like this:

Rice (30%), peas (30%), beef (20%), potatoes (20%)

Or this:

Beef (10%), beef heart (10%), long grain rice (10%), brown rice (10%), white rice (10%), split peas (10%), pea protein (10%), English peas (10%), potato (10%), potato starch (10%)

With the ingredients segmented down to specific parts and now equal, beef can suddenly move into the coveted first-ingredient slot. 

What should a dog owner do? 

Just becoming aware of these kinds of tactics, and the realities of pet food making and marketing, is an important first step. By being aware of labeling rules, and knowing how to decipher them, you’ll be able to make informed decisions about what you’re buying and feeding your dog. 

You can also choose a food that’s made to the standard of human-grade food. It’s one reliable way to assure that what you’re feeding your dog is safe and suitable for a living being to eat every day. Human-grade food is, most simply, made according to the same rigorous quality and safety standards that apply to human food.

AAFCO has set out guidelines for use of the term “human-grade.” The organization states that the use of “human-grade” is only acceptable in reference to a pet-food product as a whole. ​​While each of our recipes is a blend of human-grade meat and vegetables, it’s important to note that the human-grade standard doesn’t apply only to the ingredients in the food, but also to where and how the food is made. The Farmer’s Dog food is made in facilities approved to produce human food, alongside food made for humans.

Each step of our sourcing, cooking, packaging, and storing processes meets the same standards that govern human food. All our manufacturing locations are subject to third-party audits of food safety, good manufacturing processes (GMP), quality programs, and sanitary conditions. We have strict controls in place designed to prevent physical, chemical, microbial, and allergen carry-over and cross-contamination.

Read more about fresh, real food here. 

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