Are AAFCO Standards Appropriate for Raw Dog Food?
Many dog owners and veterinarians find assurance in foods that meet AAFCO nutrient standards. But are these standards appropriate for raw dog food?
Understanding AAFCO and Its Role
The American Association of Feed Control Officials (AAFCO) oversees nutritional adequacy statements on pet food labels. These statements aim to assure pet foods are “complete and balanced” diets. However, AAFCO itself does not regulate, test, approve, or certify pet foods. It is up to manufacturers to formulate their products according to AAFCO standards. In fact, the guaranteed analysis or compliance with AAFCO nutritional standards may never be verified by a regulatory authority.
Currently, pet foods feature one of three AAFCO-approved statements:
“Animal feeding tests using AAFCO procedures substantiate this product provides complete and balanced nutrition for all life stages of dogs and cats.”
This indicates the manufacturer conducted feeding trials. While these trials can test food effectiveness, their rigor is questionable. Only eight dogs are required, with just six completing the trial. The duration is short: 26 weeks for maintenance trials and only 10 weeks for growth trials.
Only four values are measured: hemoglobin, packed cell volume, serum alkaline phosphatase (SAP), and serum albumin. Comprehensive blood panels or urinalyses are not required. A veterinarian assesses the dogs before and after the trial, but subtle deficiencies or excesses are unlikely to be detected in such a short time.
David Dzanis of the FDA notes, “Especially in the maintenance trials, subtle chronic nutrient deficiencies or excesses can be overlooked.”
"This product is formulated to meet the nutritional levels established by the AAFCO Dog and Cat Food Nutrient Profiles for All Life Stages (or for growth).”
Instead of feeding trials, manufacturers may rely on chemical analyses and nutrient profiles. However, as noted in The Nutrient Requirements of Dogs by the National Research Council (NRC), nutrient availability in practical diets may differ due to interactions among dietary constituents and processing effects. Batch-to-batch variance further complicates the issue, and manufacturers are not required to test every batch or disclose ingredient variations.
Dr. Donald Strombach, DVM, PhD, states:
“Feeding a marginally adequate diet may result in no signs in a sedentary animal. However, with the addition of stress, that diet is nutritionally inadequate.”
“This product is intended for intermittent or supplemental feeding only.”
This label indicates the food does not meet AAFCO nutrient profiles. Many commercial raw foods fall into this category and must display this disclaimer. However, this does not inherently mean the food is nutritionally inadequate
The Myth of 100% Complete Nutrition
If raw foods are held to the same standards as kibble, adhering to AAFCO requirements may inadvertently undermine the principles of raw feeding.
Can a raw food labeled “for intermittent or supplemental feeding only” still be a good choice for pets? Conversely, can a raw food meet AAFCO standards without compromising raw feeding principles?
Explore More: Why Labels Say "For Intermittent or Supplemental Feeding"