Written by: Louise Calderwood | November 15, 2023
A visit to the food aisle in a pet store can be a confusing experience for pet owners trying to make the best choices for their pet’s diets. Hundreds of options are available for all life stages, sizes and even breeds of dogs and cats. Ingredient choices of natural, vegan, vegetarian and human-grade further add to the difficulty of choosing a food.
The Association of American Feed Control Officials’ (AAFCO) Official Publication (OP) includes model regulations for marketing claims on pet food labels. Regulators have the legal right to question companies about their marketing claims to determine if they are truthful and non-misleading. But recently, it appears regulators are looking for the “easy” button to reduce their workload by creating additional AAFCO guidelines for pet food label claims, rather than following existing regulations. 
Guidelines for pet food-related claims that are scientifically proven to address issues, such as obesity, already exist in the AAFCO OP. Labels marketing ingredients with AAFCO approved guidelines, based solely on current consumer interest and without a foundation in science, will add to the confusion that already exists in choosing the best food for pets.
"AAFCO should not add to the confusion by engaging in the approval of unfounded marketing claims. Instead, regulators should do their jobs and contact companies asking for documentation in support of such label claims."
It has been a short five years since the Food and Drug Administration’s response to the perception that dogs where succumbing to dilated cardiomyopathy (DCM), a disease with a known genetic predisposition, causing alarm amongst some dog owners and harming ingredient companies and pet food manufacturers whose products were vilified with no scientific basis. AAFCO rightfully did not engage in the issue and manufacturers who chose to develop marketing claims based on protein sources were free to do so within the existing regulatory structure.
So why does AAFCO see the need to develop a “controlled copper” label claim following a spate of publicity, like the DCM debacle, based on weak science about copper-associated hepatopathy (CAH) in dogs?
The American Feed Industry Association believes that if manufacturers choose to market a dog food based on copper content, then the current AAFCO model regulations for pet food and specialty pet food clearly spell out the steps for them to take.
In early 2021, Sharon Center, DVM, co-authored an opinion piece in the Journal of the American Veterinary Medicine Association in which she said, “We have seen what we believe to be an increased incidence of copper-associated hepatopathy in dogs.” Dr. Center and her co-authors went on to suggest that the onset of the increase appeared to have coincided with a change in the type of copper used in premixes added to commercial dog foods. In the more than two years since Dr. Center’s self-proclaimed “believed observation,” not founded in science, there has been a dearth of studies confirming causation between diet, source of copper or the incidence of canine CAH.
"Developing an AAFCO approved “controlled copper” marketing claim is an irresponsible step by regulators in response to the opinion of a small group of veterinarians lacking a clear association between the source or amount of dietary copper and the incidence of CAH."
Developing an AAFCO-approved label claim addressing copper content in dog food will be just one more confusing label on a pet food shelf. There is no evidence that controlling copper in a dog’s diet will reduce the incidence of CAH or reduce the impact of the disease after it is diagnosed. The limits being proposed for a “controlled copper,” AAFCO-approved label claim are necessarily above the minimum allowable copper in dog diets, so it isn’t even clear what is being “controlled.”
Dogs that are truly suffering from CAH should be under the care of a veterinarian. The disease can only be diagnosed through histologic analysis of a liver biopsy sample and quantitative assessment of hepatic copper concentrations. Unlike pet obesity, which an owner can easily self-diagnose, the diagnosis and treatment of CAH is complex, requires veterinary expertise and is not clearly linked to diet. Without any changes to current AAFCO model regulations, companies that choose to include marketing statements about copper content in pet food are free to do so if the food meets the AAFCO minimum requirement for copper and the claim is truthful and not misleading. If consumers indeed are interested in the amount of copper in their dogs’ diets, then manufacturers can include the information on labels using existing regulatory pathways.
AAFCO has plenty of work to do addressing efficiencies in the animal food ingredient review and approval process, supporting consistent laboratory testing methods, training regulatory officials and addressing issues of industrywide importance. This is not the time to use the “easy” button.
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