9 Dec
Mike Davies BVetMed, CertVR, CertSAO, FRCVS shares some home truths about the manufacture of dietary products for dogs and cats – and the need for regulatory change to protect pet and human health.
Image: © Krakenimages.com / Adobe Stock
Pet owners are responsible for the dietary intake of their dog or cat, unless they are regular scavengers or catch and eat prey. If owners get it wrong, very serious consequences can occur, as nutrient deficiencies or excesses can lead to poor growth, developmental abnormalities, serious disease or even death.
Common nutrition-related diseases that the author sees include skeletal deformities (cleft palate, angular limb deformities, metabolic bone disease with spontaneous fractures, exostoses and pain due to hypervitaminosis A, and – probably – medial coronoid process fragmentation (Davies et al, 2017a]), chronic hypercalcaemia due to hypervitaminosis D (resulting in soft tissue calcification and deaths), skin lesions (due to dietary deficiencies, mimicking dietary allergies), pansteatitis, and gastrointestinal disorders including diarrhoea.
The European Pet Food Industry Federation (FEDIAF) claims: “The role of the pet food manufacturer is to provide safe, nutritious food for pets, compliant with the EU regulation.” The industry is strictly regulated by more than 50 pieces of legislation.
Legally, if a pet food is labelled as “complete”, it must provide all the energy and essential nutrients that the target species needs in the correct amounts, so owners should be able to rely on this declaration. However, studies have shown that foods labelled as complete often do not contain the ingredients that they are supposed to.
In one study of UK pet foods labelled as complete (Davies et al, 2017b) only 6% (6 out of 97) of wet and 38% (30 out of 80) of dry food were fully compliant with FEDIAF guidelines for minerals and trace elements. So, the vast majority (79%) failed to supply all the essential minerals and trace elements they were legally obliged to do; as an example, 20% (1 in 5) wet foods did not contain enough copper.
This problem is not just in the UK: all over the world, when scientists have analysed complete pet foods, they have found most do not comply with guidelines and/or do not contain the ingredients as declared on the label.
Many are deficient in essential nutrients (Dodd et al, 2021; Zafalon et al, 2020; Kazimierska et al, 2020; Burdett et al, 2018; Kritikos et al, 2018; Davies et al, 2017; Gosper et al, 2016; Hill et al, 2009; Heanes, 1990). Some foods contain excess, and sometimes above, the legal maximum and safe upper limits of nutrients (Kazimierska et al, 2020; Brunetto et al, 2019; Pereira et al, 2018; Davies et al, 2017b). Some foods claiming to contain only specified species proteins were contaminated with other species proteins (Pagani et al, 2018).
Clearly, some manufacturers of pet foods are flaunting the law and declaring brands to be complete when they are not. This is unfair on the companies that are doing everything they can to comply with FEDIAF; for example, by using fixed formulas (which reduces batch-to-batch variations in content) and by having their products analysed post-production to ensure compliance.
Trading Standards are responsible for policing the pet food industry, but it is under-resourced and pet food is not near the top of its priority list. The Advertising Standards Agency (ASA) is responsible for policing misleading claims in marketing (including pet food labels) and do respond efficiently to complaints.
The author reported one company making illegal claims (including direct health claims) a few years ago, and it was found in breach of the law and instructed to remove the claims from its labels; however, it was allowed to continue to sell its illegally labelled batch for a further 18 months and received no other penalty. Also, the VMD took no action other than asking the company to remove its illegal and unsubstantiated health claim.
Consumers have a right to believe that information contained on a pet food label is clear, accurate and not misleading. Legislation governing advertising standards are designed to ensure manufacturers only make claims that are true and can be substantiated, and that claims do not mislead consumers. Unfortunately, almost all of the information on current pet food labels cannot be relied upon to be transparent and accurate.
The word “complete” is meant to reassure pet owners that the food contains everything that their pets need and it is safe to feed long term. As aforementioned, because pet foods often do not comply with FEDIAF guidelines, many pets are being given foods that do not meet their minimum essential nutrient requirements and consumers cannot take this declaration at face value.
Some pet foods are labelled as “complementary”. The author’s experience is that pet owners do not know what this means and do not realise that such foods will not meet all their pets’ requirements. The author has met owners who feed complementary food as a sole ration – usually because it is cheaper. This word should be replaced with an alternative, clearer description, such as “incomplete” or “not complete”.
Furthermore, the feeding guides on complementary foods should provide a detailed explanation of the profile of food that needs to be provided with it so the combination does provide a complete and balanced ration. Conversely, it could carry words saying: “Do not feed this food exclusively to your pet – otherwise serious illness may result.”
The law allows a pet food manufacturer to make a claim that a food contains protein from a specific species; for example, “beef dinner”, as long as it contains at least 4% beef content. The rest could be mainly pork or poultry.
This is misleading consumers (Maine et al, 2015), and some, such as those with religious beliefs that mean they do not want to handle pork, would be horrified to find that their dog’s food labelled as “beef dinner” contained mainly pig protein (Maine et al, 2015).
Instances exist in which a product can contain 4% of several different species of proteins (for example, beef, lamb, chicken and rabbit), but can be sold with different labels declaring each species individually, or combinations such as chicken and lamb, when it is exactly the same food in each can. Consumers making choices between these variations are being hoodwinked into believing they are giving their pet variation in their food – when it is exactly the same.
Manufacturers do not have to declare the species from which protein(s) in their food are sourced, and they can use general terms like “meat and animal derivatives”. This is reasonable because most manufacturers buy their ingredients on the open market and, depending on availability and cost, they may have to use different species protein sources in every batch. It would be impractical and costly to have to print new labels for every batch; however, the end result is consumers have no idea what species or parts of an animal are in the food, because the term “meat” means any part of a carcase. Owners do not even realise that if a label states “chicken flavour”, it does not have to contain any chicken meat – it may just contain chicken flavouring.
The marketing image on the label may show a nice fillet of chicken or a human-style meaty stew, but do not be fooled. Sometimes what looks like meat or liver in a product is actually textured vegetable protein made to look like a meat. Again, this is all deceiving the consumer, who does not realise that what they are looking at is not as described or implied by the marketing on the label. There is nothing wrong with using technologies to visually humanise pet foods, but the consumer has a right to know when they are buying products that incorporate these tricks of the trade.
The rules on declaration of content need radical review. Wet pet foods have to declare the water content, which is helpful if you want to calculate content on a dry matter basis, but dry products do not, so you have to guess or get the accurate analysis from the manufacturer. No pet foods have to declare carbohydrate (nitrogen-free extract) content; this is clearly wrong and misleading by omission. In dry products, the main source of energy is carbohydrates, but because water content also does not have to be declared, it is impossible to calculate with any accuracy the actual content of these foods from the label.
Consumers and veterinary professionals should know that batches of food are allowed to vary from the label declaration, and for the main ingredients like protein and fat, they can vary in either direction by up to 3% from the typical analysis declaration. That means that a difference of up to 6% can exist between batches. For minor ingredients, tolerance (variation) of up to 12.5% is allowed, so a 25% difference between two batches can occur. This is allowed because of the practicalities and difficulties of getting precise amounts in manufacturing. The assumption is that, over a period of time, batch-to-batch variation will average out to the declared analysis.
A massive growth has occurred in the feeding of raw meat rations to dogs and cats.
It is well documented that raw meats can carry pathogenic microorganisms and many of these are zoonotic (Davies et al, 2019; Hellgren et al, 2019; van Bree et al, 2018; Nilsson, 2015; Nemser et al, 2014).
Under current legislation, manufacturers of raw meat-based foods are only obliged to test their products for Enterobacteriaceae and Salmonella, and yet, zoonotic infections that raw meats carry include many other pathogens, including Brucella, Campylobacter, Clostridia, Escherichia coli, Listeria, Mycobacteria, Salmonella, Yersinia, toxoplasmosis, norovirus, pseudorabies and avian influenza.
In the US, the Food and Drug Administration has advised pet owners against feeding raw foods because of the human risk due to Salmonella and Listeria monocytogenes, and products are regularly being recalled because screening reveals the presence of these infectious agents.
Recently, human health has been put at risk in the UK by the presence of bTB in both cats (O’Halloran et al, 2019; 2018) and dogs (Phipps et al, 2018) fed raw meats. About 100 cats were affected and some died, and the outbreak originated from a commercially produced raw wild venison product. In a previous outbreak of TB in cats, two owners contracted the disease from their pets (Gibbens, 2014; Roberts et al, 2014).
More seriously, in 2018, Public Health England reported an outbreak of Shiga toxin producing E coli (STEC) O157 PT 21/28 Stx2 in England, in which four patients developed haemolytic uraemic syndrome and one died. These people (three of whom were children) contracted the infection from contact with dogs fed on a raw meat based diet (n=3) and raw tripe (n=1; Public Health England, 2018).
The author is aware that some UK Trading Standards offices would like to close down raw pet food manufacturers because of repeat incidents of releasing products contaminated with pathogenic Salmonella or L monocytogenes (a recognised public health risk; Dhama et al, 2015).
Legally, companies should not be selling products that pose a risk to health, even though, like L monoctogenes, some of the known meat-borne zoonoses are not specifically required to be screened for under current legislation.
It may not be realistic to hope that raw meat pet foods could be banned, but it is quite clear to the author that the Government needs to introduce legislation to make manufacturers screen for more pathogens than they do now. Policing and random analysis of products in the market also must occur to remove risks to animal and human health, and consumers should be made aware of the serious health risks posed by feeding raw foods.
More than 75 dogs died in the US in 2005 after consuming pet food contaminated with aflatoxins, and hundreds developed severe liver problems. Although outbreaks are rare, mycotoxin toxicity is regularly suspected.
In the author’s opinion, legislation should be introduced to minimise risk by requiring pet food manufacturers to ensure cereal ingredients are not contaminated before they are used in pet food manufacture. In the US, minimising the risks posed by mycotoxins is embraced in the Preventive Controls for Animal Food rule under the Food Safety Modernization Act.
Current pet food label legislation is inadequate, does not provide all the information consumers need and are entitled to expect, and allows manufacturers to make true, but misleading, marketing statements that confuse consumers.
The majority of pet foods labelled as “complete” in the UK apparently are not, and some may result in clinical disease if fed exclusively to a pet. This aspect of the industry needs policing, with random sampling to check compliance with FEDIAF, and self-declaration alone should no longer be acceptable.
Further legislation is required to identify contaminated foods to minimise the risk of life-threatening infections or toxins. Pet owners now expect more transparency and want to know what is in the food they are giving to their pet. It is unfair that nobody is proactively policing this industry to protect consumer interests, and consumers have no way of differentiating between compliant and non-compliant manufacturers.
Much of the legislation in place is, in the author’s opinion, no longer fit for purpose and needs radical review.
For all the reasons stated, now would be a good time for the UK to upgrade its pet food regulations.