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Understanding Pet Food Labels & Legal Requirements

understanding pet food labels

Last Updated: September 5, 2023 by Lisa Melillo

You may have never stopped to think about what’s written all over your pet’s bag of food – surely a company is free to call their product whatever they want, right?

Actually, much of what’s on your bag of pet food is highly regulated as to not mislead you. Everything from the name of the pet food to the ingredient list follows some different legal requirements and regulations. There are two main sources of the requirements – on the federal level, the FDA (Food and Drug Administration) has some standards and on the state level, most states have adopted the regulations proposed by the non-government group
Association of American Feed Control Officials (AAFCO).

Let’s take a deep dive into pet food labeling requirements so you can understand more about what you’re feeding your dog!

Product Name Regulations for Pet Food

When you were looking to buy pet food, the name of the product likely played a big role in your decision making even if you didn’t realize it at the time. Maybe you bought a dog food called “Salmon Recipe” – but did you check to see how much salmon was in it? Did you know if any salmon was even used?

Luckily, that’s not something you really need to worry about because the AAFCO has 4 rules around naming pet food products to prevent misleading consumers.

1. The 95% Rule

The 95% Rule says that for a pet food to have a simple name like “Chicken for Dogs” or “Tuna Cat Food”, at least 95% of the food (measured by weight) must be the ingredient in the name (chicken or tuna above), not counting moisture content. When accounting for added water content, the named ingredient still must be 70% or more of the product.

The 95% Rule can also apply to multiple ingredients, for example “Venison and Potato Dog Food” would need to have both ingredients together composing 95% of the weight. Also, the named ingredients must be named in order according to their total weight – so in the previous example venison must have more weight used than potato.

Overall the 95% rule doesn’t seem to come into play often as it’s hard to provide a fully balanced diet when 95% of the weight is coming from just one or two ingredients. Instead, most pet foods fall under the following rule.

2. The 25% Rule or “Dinner” Rule

Next up we have the 25% Rule. The 25% Rule is just like the 95% Rule, but of course the minimum for the ingredients is just 25% of the weight of the food.

turkey and potato recipe dog food

When a food falls under the 25% Rule, it can no longer call itself “Chicken Dog Food”. Instead the name must include a qualifying term like “Chicken Dinner Dog Food”, “Beef and Green Bean Recipe”, or “Venison Formula”. Most pet foods seem to fall into this 25%-94% range so you’ll almost always see a descriptive qualifier like these in the name.

Because the minimum requirement is only 25% by weight, it’s possible that the named ingredients in these cases are not the first or even second ingredient in the ingredient list. From my analysis it’s practically always the first ingredient listed when it falls under this rule, but it’s good to double-check as it’s not required.

sunday chicken dinner dog food

When more than one ingredient are listed in these names then they must still be in order by weight and the second ingredient must be at least 3% of the food’s weight.

3. The 3% Rule or “With” Rule

Here is where things start to get shady and potentially misleading, in my opinion. For a pet food to be listed as “with” some ingredient it only needs to contain 3% of that ingredient.

For example, a pet food could only contain 3% chicken to be named “Dog Food with Chicken”

To further emphasize how careful you need to be when reading a label, “Venison Dog Food” would have to have 95% venison whereas “Dog Food with Venison” would need only 3%!

Let’s take a look at how egregious the “with” rule can be. Take a look at this dog food label and see what you notice – Iams ProActive Health With Beef & Rice.

iams with beef and rice dog food

It looks like this dog food primarily contains a lot of beef! It’s named “with Beef and Rice”, and beef is the only meat shown on the bag. The label also calls out “#1 ingredient is premium protein” – that’s not very specific though, is it? Let’s take a look at the ingredient list…

Chicken, Ground Whole Grain Corn, Ground Whole Grain Sorghum, Chicken By-Product Meal, Beef, Brewers Rice, Dried Beet Pulp, Natural Flavor, Chicken Fat (Preserved with Mixed Tocopherols), Dried Egg Product, Potassium Chloride, Caramel Color, Salt, Flaxseed, L-Lysine Monohydrochloride, Choline Chloride, Calcium Carbonate, Carrots, Tomatoes, Fructooligosaccharides, Spinach, Green Peas, Minerals (Ferrous Sulfate, Zinc Oxide, Sodium Selenite, Manganese Sulfate, Copper Sulfate, Manganous Oxide, Potassium Iodide), Vitamins (Vitamin E Supplement, Ascorbic Acid, Calcium Pantothenate, Vitamin A Supplement, Biotin, Thiamine Mononitrate (Source of Vitamin B1), Vitamin B12 Supplement, Niacin, Riboflavin Supplement (Source of Vitamin B2), Inositol, Pyridoxine Hydrochloride (Source of Vitamin B6), Vitamin D3 Supplement, Folic Acid), Dried Brewers Yeast, Dl-Methionine, Dried Apple Pomace, L-Tryptophan, Mixed Tocopherols, L-Carnitine, Dried Blueberry Pomace, Rosemary Extract.

Beef is the 5th ingredient and rice is the 6th ingredient! This is essentially a chicken and corn formula dog food marketed as “with beef and rice”.

Also interesting how far down the ingredient list carrots are, yet they are pictured on the bag. This is a prime example of how companies can be misleading while staying within the regulatory framework.

4. The Flavor Rule

Last and possibly the most disappointing of all, the Flavor Rule.

You can call a pet food “Beef Flavor” without there needing to be any beef in the ingredients. It only has to taste like beef to a pet.

That’s right, as long as you can fool a pet into thinking the pet food is using the named ingredient (apparently this can be tested with dogs trained to prefer beef over chicken, for example) then you can call a pet food whatever flavor you want.

Here’s an example –
Pedigree Adult Complete Nutrition Grilled Steak & Vegetable Flavor.

pedigree adult dog food steak flavor

Here we see “Grilled Steak & Vegetable Flavor” is the name of the dog food, let’s take a look at the ingredients.

Ground Whole Grain Corn, Meat And Bone Meal (Source Of Calcium), Corn Gluten Meal, Animal Fat (Source Of Omega 6 [Preserved With Bha & Citric Acid]), Soybean Meal, Natural Flavor, Chicken By-Product Meal, Dried Plain Beet Pulp, Ground Whole Grain Wheat, Salt, Potassium Chloride, Brewers Rice, Choline Chloride, Natural Grilled Steak Flavor, Dried Peas, Calcium Carbonate, Zinc Sulfate, Dl-Methionine, Vitamin E Supplement, Niacin [Vitamin B3], Biotin, Dried Carrots, L-Tryptophan, Bha & Citric Acid (A Preservative), Blue 2, Yellow 5, Yellow 6, D-Calcium Pantothenate [Source Of Vitamin B5], Riboflavin Supplement [Vitamin B2], Red 40, Pyridoxine Hydrochloride [Vitamin B6], Copper Sulfate, Sodium Selenite, Potassium Iodide, Vitamin A Supplement, Thiamine Mononitrate [Vitamin B1], Vitamin B12 Supplement, Vitamin D3 Supplement, Folic Acid.

We can see that no real steak was used in this dog food at all despite the filleted steak depicted on the bag. Peas and carrots are barely used but also make an appearance on the bag.

This is the last “naming” rule for pet food and it really illustrates how important the ingredient list is for making an informed decision about what to feed your pets. Now let’s take a look at how ingredient lists are regulated.

Ingredient List Requirements

When it comes to the ever important ingredient list, the first requirement is that it’s listed on the packaging! The next important thing is that all ingredients are required to be listed in accordance to their weight as they are added to the formula.

dog food ingredient list
Ingredients on the bag are often very tiny and hard to read!

Due to the weight requirement, items with a heavier moisture content like meats will often come earlier as a result. The weight in unprocessed meat can be up to 75% water. As a result you may end up with an inflated sense of how much protein actually comes from meat sources, but there’s no real way around that.

As you get deeper into an ingredient list you’ll run into a lot of minerals/additives/chemicals that will likely be confusing. All ingredients in dog food must be “generally recognized as safe” or approved food additives in order to be in any pet food, however.

Looking for more detailed information and analysis on dog food ingredients? Check out our recent dog food analysis page!

Guaranteed Analysis

The guaranteed analysis of a pet food typically tells you the guaranteed minimum of protein and fat, and the maximum fiber and moisture. Manufacturers may include other measurements in their guaranteed analysis such as ash content, vitamin levels, omega fats content, and more.

pet food guaranteed analysis

The Guaranteed Analysis is given “as fed”, meaning exactly how it’s packaged into the bag. Since moisture levels vary so drastically, the can make comparing the nutrients of different pet foods to be very difficult, especially when comparing dry to wet.

Dry Matter Basis

To handle for the differences in moisture content, you have to do your own calculation to get things on a “dry matter” basis (note: all of our dog food reviews use dry matter basis for comparing foods). To calculate dry matter basis, the formula is “Guarenteed Analysis % / (100 – Moisture %). Let’s look at this in an example comparing a wet and dry dog food – Blue Buffalo Wet Chicken Recipe and Blue Buffalo Dry Chicken Recipe.

Dog FoodGuaranteed Analysis ProteinGuaranteed Analysis FatGuaranteed Analysis MoistureDry Matter ProteinDry Matter Fat
Blue Buffalo Wet Chicken Recipe8.5%5.5%78%38.6%25%
Blue Buffalo Dry Chicken Recipe24%14%10%26.6%15.5%

“As fed” it looks like the dry dog food has much more protein, but what happens when we account for the moisture content and convert everything to dry matter basis? In reality the wet dog food was much higher in protein and fat, it just happened to have a lot of moisture in the can because, well, it’s wet.

Moisture levels can be particularly important on their own when looking at wet pet food. Under AAFCO regulations, a wet pet food can have a maximum of 78% moisture content or else it must be named something like “in gravy”, “in sauce”, or “stew”. Keep in mind when compared a wet food with 75% moisture and 85% moisture that the food with 75% moisture contains 25% dry matter content, whereas the food with 85% moisture contains only 15% dry matter content.

A higher moisture food might be cheaper because it contains a lot more water and in this case, nearly half as much actual solid food!

Nutritional Adequacy Statement

Do you know if your pet’s food provides all nutrients needed for a healthy life? You may not have thought about it, but this is a regulated area of pet food as well. For a pet food to claim it provides “complete” nutrition or provides all nutritional needs, it must meet certain AAFCO guidelines.

nutritional adequacy statement on dog food
These statements are often listed very small at the bottom of the bag.

The AAFCO has established guidelines for what both cats and dogs need in their diet, and most manufacturers will conform to these profiles. It’s also possible for a pet food to go through an AAFCO feeding trial protocol to test and confirm it is indeed providing all necessary nutrients for a healthy pet.

The AAFCO also has different standards for different life stages. It’s possible for an adult dog food to only be suitable “for maintenance” whereas the requirements for a growing puppy or nursing dog would have higher requirements. A product can be approved for “all life stages” if it meets all requirements.

Sometimes a product may be specifically listed as “Senior formula” or “Large Breed Formula” or “German Shepard Recipe”, but these have no real meaning or standardization behind them.

Calories, Feeding and Quantity

Calories must be listed in by “kilocalories per kilogram” and “kilocalories per cup”. The pet food also needs to have feeding instructions which is typically a chart displaying how many cups per day depending on the weight of the animal.

pet food feeding chart

The net quantity of food must also be displayed on the bag as measured by weight. This means manufacturers can’t trick you by using different bag sizes to make it appear as if you’ll be buying more food than you are because you can always compare weight to weight across products.

Read Related Topic: Life’s Abundance Dog Food Review

Manufacturer Name and Address

Finally, the manufacturer’s name and address must be included on the packaging. The most important thing here is if the label says something like “Manufactured by Blue Buffalo”, then that means Blue Buffalo themselves made the food. If the label says “Manufactured for Blue Buffalo” or “Distributed by Blue Buffalo”, then that means Blue Buffalo did not make the food, they had an outside party make the food and they are just the responsible party selling it.

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