Many of the terms used to describe pet foods on labels and in advertising materials are not legally defined. For example, there is no regulatory meaning for the terms holistic, premium, ultra- or super-premium, gourmet, or human grade.
The term “human grade” in particular is used frequently; however, there is no official definition. Pet foods are manufactured under FDA authority and, unlike human foods, are not subject to inspection by the USDA. The USDA officially defines products fit for human consumption to be “edible.” Thus, “edible” is a standard; human grade is not. For a product to be deemed edible for humans, all ingredients must be safe for human consumption, and the product must be manufactured, packed, and held in accordance with federal regulations detailed in 21 CFR 110, Current Good Manufacturing Practice in Manufacturing, Packing, or Holding Human Food. If a pet food meets these conditions, human-grade claims might be technically accurate. But a product formulated for a pet is unlikely to be nutritionally adequate for a human and vice versa. Because pets become like family members in many homes, it should be underscored that not everything that a human can eat is safe for a pet. To name a few, ingredients such as chocolate, macadamia nuts, and onions are edible and safe for humans but can be toxic to cats or dogs. In short, “human grade” does not mean a food is safe for animal consumption. Often, this term is used when the meat has come from a USDA meat-packing plant; however, not all products that come from a meat-packing plant are safe for your pet. Interpretation and use of the term varies, and the definition is therefore dependent on the philosophy and marketing strategies of the individual manufacturer.
The term “organic” is legally defined and is observed by the USDA: USDA ORGANIC PROGRAM. This definition applies to foods intended for humans and feed for food-producing animals. It is important to note, however, that this definition does not apply to pet foods at this time. Until such regulations are developed for pet foods, those for human foods are being applied.
The term “natural” does have a legal meaning when applied to a food or ingredient and is defined by the Association of American Feed Control Officials (AAFCO) as follows: “[foods] 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 might occur unavoidably in good manufacturing practices.” AAFCO specifies that the term is used only to describe products for which all of the ingredients and components of ingredients meet this definition. An exception is made to allow the use of chemically synthesized vitamins, minerals, or other trace nutrients to allow the food to be nutritionally complete and balanced; however, a disclaimer must be present in such cases.
According to AAFCO:
- There is no requirement or statement that natural feeds or ingredients are safer than those produced by a chemically synthetic process.
- Natural is a liberal term that includes more ingredients than it excludes—most pet food ingredients are derived from “plant, animal, or mined sources.”
- A feed ingredient can be manufactured using the generic equipment and processes and still be considered natural.
- A feed or feed ingredient can contain trace amounts of chemically synthetic compounds and still be considered natural.
- Ingredients that are chemically synthesized, such as vitamin ingredients, mineral ingredients, preservatives, and special-purpose food additives are NOT NATURAL. Some examples include chelated minerals, mineral amino acid complexes, vitamin supplements, propylene glycol, calcium ascorbate, and other preservatives such as BHA and BHT, as well as artificial flavors and colors.