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NEW RULES FOR "LITE" PET FOODS
by David A. Dzanis, D.V.M., Ph.D., DACVN

As Americans become more health conscious with respect to food for their own consumption, they are reading food labels and choosing products more carefully. Many people are extending this scrutiny to food for their pets as well. Pet food labels are regulated by different rules than are foods for human consumption, but reading and understanding a pet food label will enable consumers to make proper food choices for their pets, too.

Pet food labeling is regulated at two levels. The Federal regulations, enforced by FDA's Center for Veterinary Medicine (CVM), establish standards applicable for all animal feeds: proper identification of product, net quantity statement, manufacturer's address, and proper listing of ingredients. Some States also enforce their own labeling regulations. Many of these follow the model pet food regulations established by the Association of American Feed Control Officials (AAFCO), which establishes other labeling requirements such as the guaranteed analysis, nutritional adequacy statement and calorie content statement. CVM works very closely with AAFCO on developing the model regulations.

Obesity in pets is probably the most common nutritional problem today. Thus, it is not surprising that more and more "lite" pet food products are now available. However, the new FDA regulations governing the use of these types of terms for human food products do not apply to pet foods. Thus, there have been problems with how some pet food manufacturers were using the term and how consumers were perceiving these claims. For example, even if one manufacturer's "lite" pet food was lower in calories than its regular product, the calorie contents of products vary widely. Thus, one company's "lite" product could actually be higher in calories than another's regular product. Also, some claims were made based on volume, not weight, so a pet food could be "lite" simply by "puffing up" the food with more air. Finally, calorie content statements as stipulated in the AAFCO model regulations were only voluntary, and in practice rarely appeared on pet food labels. These facts made it difficult for the pet owner to fully assess and compare the calorie content of products and determine whether a "lite" product was truly "lite."

In August, new AAFCO model regulations governing the use of descriptive terms such as "lite" and "low fat" were passed by the membership at its annual meeting in San Diego. These new rules represent several years of hard work by the AAFCO Pet Food Committee and input from the industry to develop a means to allow for non-misleading use of these terms on pet food labels. As a result of the new regulations, some firms will be required to modify either their labels or formulas for some products.

Terms such as "lite" and "low calorie" convey a very strong message to consumers. In FDA regulations for human foods, "lite" foods must be a set percentage lower in calories and fat compared to an industry average for each category of food (for example, snack foods, bakery products, breakfast cereals). Few people would expect a "lite" ice cream to be as low in calories as "lite" ketchup, but it is not unreasonable to expect a "lite" ice cream to be lower in calories than the average regular ice cream on the market. The comparison must be based on an equal amount of both products. In most cases, the amounts are based on equivalent weights. For example, all snack food claims are based on a 30-gram (approximately one-ounce) serving size, whether popcorn, pretzels, or cheese puffs. The use of smaller serving sizes or a comparison on volume was deemed inherently misleading. Thus, a product cannot be "lite" simply because the product is offered in one-half ounce pieces instead of one ounce. Instead, the serving size is "two pieces." Also, a cheese puff is not "lite" even if a cup of it contains less calories than a cup of pretzels.

Although the specifics are different, the rationale used for human foods were also employed in the new AAFCO regulations. Three different categories of pet foods, based on moisture content, were established (see Table 1). The criteria the product must meet is in terms of weight, not volume, and an AAFCO calorie content statement must also be on the label. The maximum calorie allowances for "lite" pet foods reflect a percentage reduction in calories relative to the average calories found for products on the market under each category. The percentage reduction compared to the average is 15 percent for dog foods, and 10 percent for cat foods. These percentages are less stringent than those required for human "lite" products (33 percent) to accommodate the different nature of pet foods. Also, unlike for human foods, where a "lite" claim refers to both calorie and fat reduction, a "lite" claim for a pet food only means it is lower in calories (see "lean," below).

For products that cannot meet the criteria to be called "lite," comparative claims (for example, "less" or "reduced" calories) are still allowed. However, "less" claims must include the percent reduction and the product of comparison. An example would be "Brand X Special Cat Food has 25 percent less calories than Brand X Original Formula." Again, these comparisons should be made on the basis of weight, not volume. Comparing products between categories (e.g., a canned vs. a dry food) is misleading. Any product bearing a "less" claim must make a valid AAFCO calorie content statement as well.

The fat-related claims mirror those for calories. The term "lean" to describe low fat is assumed equivalent to "lite" as an alternative to low calorie. Instead of a calorie content statement, products bearing fat-related claims must state a maximum fat content in addition to the required minimum guarantee. Table 2 shows the maximum fat contents allowed for various categories of pet food bearing a "lean" claim.

The new regulations won't become effective before January 1998, although some products may bear revised labels before that time. Regardless, simply feeding a pet a "lite" product will not address its problems with weight control all by itself. Proper portion control, elimination of snacks, and a sound exercise program are all important components to helping the pet achieve a healthy weight.


Table 1: "LIGHT," "LITE," "LOW CALORIE," ETC.


Moisture Category Maximum kcal ME / kg Maximum kcal ME / kg

(dog food) (cat food)


<20% 3100 3250

20% or more, but <65% 2500 2650

65% or more 900 950



Table 2: "LEAN," "LOW FAT," ETC.



Moisture Category Maximum Crude Fat (%) Maximum Crude Fat(%)

(dog food) (cat food)


<20% 9 10

20% or more, but <65% 7 8

65% or more 4 5


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Source: January/February 1997 FDA Veterinarian Newsletter
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