A savvy pet owner was taken aback by some advertising she spotted in Petsmart. She discovered a Wellness Pet Food display stating “Made from Human Grade Ingredients”. Interesting, since the ‘human grade’ claim is not defined by pet food regulations. The dilemma begins (continues).
AAFCO (American Association of Feed Control Officials) pet food regulation PF5.(d)(3) states “A reference to quality or grade of the ingredient does not appear in the ingredient statement.” Ok…but this pet food did not make the claim ‘human grade’ in the ingredient statement, it was in/on a separate display near the pet food line. Is this claim legal?
The question “A pet owner notified me that in Petsmart she discovered an advertising (not on the pet food product – but in store advertising display) for a pet food that stated “Made from Human Grade Ingredients”. Is a statement to grade or quality allowed in pet food advertising? As I understand the regulations, it is not allowed on product labels; but it is not clear if it is allowed on product advertising. Any clarification you can provide would be appreciated.” was sent to AAFCO; as of this writing no response has been received.
However, I took the question to an experienced professional in the ‘human grade claim’ field, Lucy Postins of The Honest Kitchen Pet Food Company. In November 2007, The Honest Kitchen Pet Food Company won a six-month lawsuit against the Ohio Department of Agriculture. Ohio had denied Honest Kitchen the license to sell its products because of pet food label statements “human grade”. From a press release about the lawsuit “The court determined that the labels were not in fact untruthful or misleading and ruled that the company had a constitutional right to make truthful statements about the human grade quality of its products, on the labels.” http://www.thehonestkitchen.com/2007/11/08/fresh-news/
While almost all pet foods are manufactured in a ‘pet food plant’, Honest Kitchen proved its foods were manufactured in a ‘human food plant’ and thus was entitled to the claim made with ‘human grade ingredients’. The consensus understanding of existing pet food regulations (through years of discussion with various pet foods) is that even if all human grade ingredients are used in a pet food, once those ingredients enter a ‘pet food plant’, they become ‘pet grade ingredients’.
Lucy Postins reply to my question of ‘is it legal for pet food advertising to make the human grade claim’?…“As far as I know any pet product on the market would have to undergo the same scrutiny we did in demonstrating to FDA that their product is truly human grade – so it would be interesting to ask them (or FDA’s CVM) whether they actually have.”
Well…I took the question to Wellness. The Wellness Customer Service Representative told me “yes, there are regulations stating no pet food is allowed to make the human grade claim; the display in the Petsmart must have been old advertising.” When I shared with the Wellness Representative that Honest Kitchen is allowed to make this claim, because their foods are processed in a human food plant, she stated “yes, you are correct, they can.”
Old advertising or not, no pet food company excluding The Honest Kitchen, can legally make the claim ‘human grade ingredients’; pet food manufacturing has never been provided this opportunity via regulations.
As pet food regulations currently stand, a manufacturer that searches high and low for the highest quality/grade of ingredients – human grade ingredients – (which by the way pet owners want to and deserve to know about) cannot legally make the ‘human grade’ claim in advertising or on product labels.
While many pet foods abide by existing (and limiting) regulations on labels and in advertising, most do not when it comes to email or phone response to pet owners. In fact, many take advantage of the lack of enforcement of the AAFCO ‘no reference to grade or quality’ regulation. Numerous pet food manufacturers that include clear non-human grade ingredients such as Meat and Bone Meal and By Product Meal have made the ‘human grade’ claim to me and my team of Secret Shoppers (numerous times).
Pet Owners deserve to know the grade/quality of every ingredient in their pet food/treat purchases. Quality minded pet food manufacturers deserve to establish a clear separation from companies that utilize non-human grade ingredients such as meat and bone meal or by-product meal. Since currently there is no official AAFCO definition or acceptance of the ‘human grade’ term, AAFCO needs to either enforce the existing regulations (no claim to grade or quality of ingredient) with all pet foods/treats OR finally develop a clear definition of the term.
If you are in a pet store and you see the ‘human grade claim’ advertised where it shouldn’t be, get out your camera phone and take a picture. Send it my way. Perhaps we’ll start a collection to send to AAFCO. Pet Owners should be able to see this claim on the pet foods that deserve it, but it should be there legally. Pressuring AAFCO could be the way to make that happen. Send me your pictures.
Wishing you and your pet(s) the best,
Pet Food Safety Advocate
Author, Buyer Beware
Co-Author Dinner PAWsible
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