PET Food Processing - December 2021 - 22

REGULATORY
would suggest having labels reviewed by a label consultant
before printing expenses are incurred. "
Be cautious on claims
August Konie, principal of food safety, quality and regulatory
affairs, BSM Assurance, Concord, Calif., said
claims are an area that requires special attention.
" Claims can get very wild and verbose, " Konie said.
" This is a common trouble spot. If you are going to say
something, have the documentation to back it up. "
Konie said all-natural claims often become an issue as
manufacturers could find their products are not as natural
as they believe, and such claims require an ingredient
list and documentation to back them up. Health claims
are another problem spot as manufacturers often try to
name specific diseases or ailments in their claims, which
is against regulations.
Using ingredients that are not approved for AAFCO
use is another area that can slow down the process.
When manufacturers use those ingredients, they must
be researched and proven as safe and approved for pet
food, Konie said.
Konie's biggest advice in terms of claims was to keep it
simple. He said manufacturers sometimes tend to fill any
extra space available on the bag.
" Advertise what you need to advertise, call out what
IN GENERAL,
PET FOOD AND
TREAT LABEL
REQUIREMENTS
INCLUDE:
you need to call out, but don't just fill bag space, " he said.
He said some of the best labels he has seen have oneword
claims. The bags give
mental images through pictures
without saying anything
extensive in words, and
the words they did use were
primarily nouns.
Zach Stephan, senior food
* Brand and product name
* Name of the animal species for
which the product is intended
* Quantity statement
* Guaranteed analysis
* Ingredient statement
* Nutritional adequacy statement
* Feeding directions
* Name and address of
manufacturer or distributor
scientist, Alphia, Bern, Kan.,
encouraged the use of soft
claims. For example, he recommended
stating a product
" helps clean your dog's
teeth, " instead of " cleans your
dog's teeth. "
Stephan also said it is important
to have more than
one set of eyes looking at the
labels and packaging at the
company level, and to also consult a third-party regulatory
expert who is more versed in the process.
A state-by-state effort
Since the label approval process is done at the state
agency level, Hays said, the length of time required
for approval completely depends on the specific state's
22 PET FOOD PROCESSING | December 2021 | www.petfoodprocessing.net
" Claims can get very
wild and verbose.
This is a common trouble
spot. If you are going
to say something, have
the documentation to
back it up. "
August Konie, BSM Assurance
processes and resources. The process can take several
months if packets are incomplete or if the submission is
made during an especially busy time, such as the annual
review period.
Madison Fink, pet food coordinator with the
Missouri Department of Agriculture, said problems she
sees in Missouri include using drug claims on pet food
bags, which is not permitted. The definition of a drug
involves the product being used in the cure and prevention
of disease.
Formatting of the calorie content section is another
area where companies in Missouri have trouble, and
there are very clear laws for how that section should be
formatted, Fink said. She also suggested using the official
feed term in the ingredient deck, as the use of unofficial
feed terms is another issue she has seen.
Fink said she has seen many smaller companies making
mistakes because they do not have the time or resources
dedicated to learning the regulations. This is
where collaboration with state regulators can be of assistance,
if manufacturers choose to reach out. She added
state officials can explain regulations and walk companies
through the basics as they get started.
Konie said the time it takes to receive feedback from
states after submission has varied during the pandemic,
as some states have officials in the office and others are
still working from home. Additionally, only a quarter of
states have electronic filing, and having electronic filing
can speed up the process.
Both Fink and Stephan noted there is a working
group in AAFCO of industry and regulatory members
coming together to help modernize labels. This Pet Food
Label Modernization project will likely lead to some significant
changes to labels in the future.
" AAFCO is working with industry on the information
developed so far, " Hays said. " We know it will be several
years before these regulations take effect, and consumers
will have the benefit of labeling on pet food that is easier
to understand. "
PFP
http://www.petfoodprocessing.net

PET Food Processing - December 2021

Table of Contents for the Digital Edition of PET Food Processing - December 2021

PET Food Processing - December 2021 - Intro
PET Food Processing - December 2021 - 1
PET Food Processing - December 2021 - 2
PET Food Processing - December 2021 - 3
PET Food Processing - December 2021 - 4
PET Food Processing - December 2021 - 5
PET Food Processing - December 2021 - 6
PET Food Processing - December 2021 - 7
PET Food Processing - December 2021 - 8
PET Food Processing - December 2021 - 9
PET Food Processing - December 2021 - 10
PET Food Processing - December 2021 - 11
PET Food Processing - December 2021 - 12
PET Food Processing - December 2021 - 13
PET Food Processing - December 2021 - 14
PET Food Processing - December 2021 - 15
PET Food Processing - December 2021 - 16
PET Food Processing - December 2021 - 17
PET Food Processing - December 2021 - 18
PET Food Processing - December 2021 - 19
PET Food Processing - December 2021 - 20
PET Food Processing - December 2021 - 21
PET Food Processing - December 2021 - 22
PET Food Processing - December 2021 - 23
PET Food Processing - December 2021 - 24
PET Food Processing - December 2021 - 25
PET Food Processing - December 2021 - 26
PET Food Processing - December 2021 - 27
PET Food Processing - December 2021 - 28
PET Food Processing - December 2021 - 29
PET Food Processing - December 2021 - 30
PET Food Processing - December 2021 - 31
PET Food Processing - December 2021 - 32
PET Food Processing - December 2021 - 33
PET Food Processing - December 2021 - 34
PET Food Processing - December 2021 - 35
PET Food Processing - December 2021 - 36
PET Food Processing - December 2021 - 37
PET Food Processing - December 2021 - 38
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PET Food Processing - December 2021 - 40
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PET Food Processing - December 2021 - 42
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https://digital.petfoodprocessing.net/sosland/pfp/pet-food-processing-december-2021
https://digital.petfoodprocessing.net/sosland/pfp/pet-food-processing-october-2021
https://digital.petfoodprocessing.net/sosland/pfp/pet-food-processing-september-2021
https://digital.petfoodprocessing.net/sosland/pfp/pet-food-processing-june-2021
https://digital.petfoodprocessing.net/sosland/pfp/pet-food-processing-march-2021
https://digital.petfoodprocessing.net/sosland/pfp/2020_12_01
https://digital.petfoodprocessing.net/sosland/pfp/2020_10_01
https://digital.petfoodprocessing.net/sosland/pfp/2020_09_01
https://digital.petfoodprocessing.net/sosland/pfp/2020_06_01
https://digital.petfoodprocessing.net/sosland/pfp/2020_03_01
https://digital.petfoodprocessing.net/sosland/pfp/2019_12_01
https://digital.petfoodprocessing.net/sosland/pfp/2019_10_01
https://digital.petfoodprocessing.net/sosland/pfp/2019_09_01
https://digital.petfoodprocessing.net/sosland/pfp/2019_06_01
https://digital.petfoodprocessing.net/sosland/pfp/2019_03_01
https://digital.petfoodprocessing.net/sosland/pfp/2018_12_01
https://digital.petfoodprocessing.net/sosland/pfp/2018_09_01
https://digital.petfoodprocessing.net/sosland/pfp/2018_06_01
https://digital.petfoodprocessing.net/sosland/pfp/2018_03_01
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