Two very common pet food ingredients have no official definition in U.S. pet food regulations; Pea Protein and Pea Fiber. What is ‘pea protein’ or ‘pea fiber’? With no definition to legally define the ingredient…who knows?
Within the past two or three years, pet food has seen a significant increase in the use of pea protein and pea fiber ingredients in dog foods and cat foods. We find these ingredients in many ‘Grain Free’ pet foods. Because of the known risks associated with grain ingredients – deadly mycotoxins with grains such as corn and soy, arsenic with rice – pet food consumers have sought out perceived safer/healthier ‘grain free’ pet foods. But are they really safer or healthier?
A little over a year ago, friend and pet food safety advocate Kim Kalendar provided TruthaboutPetFood.com readers with some health concerns of high levels of pea proteins in pet foods. Kim’s personal experience as the owner of an independent pet food store and her research of pea protein ingredient pet foods (linked to high levels of lectin) found many pets suffered with gastrointestinal issues when consuming these types of foods.
But there is more to be concerned about with pea protein and pea fiber ingredients. The concern is that neither of these very common pet food ingredients have an official definition. No definition means ingredient suppliers are held to no requirements and no standards with these ingredients. No official definition means the pet food consumer has no idea what a pea protein or pea fiber ingredient really consists of.
How can so many pet food manufacturers be allowed to use an ingredient that has no definition? Is that legal?
It depends on the state you live in.
AAFCO (American Association of Feed Control Officials) develops pet food/animal food ingredient definitions, but it is up to the individual state to accept and implement into law the pet food ingredient definitions developed by AAFCO. Some states automatically accept AAFCO definitions (and all model regulations developed by AAFCO) into law, others might take years to implement.
However, with the pet food ingredients pea protein and pea fiber…these ingredients haven’t even begun the AAFCO process to be officially defined never the less accepted by states into law as legal pet food ingredients. Here’s how it is supposed to go…
Pet food/animal food ingredient supplier develops a new ingredient;
Ingredient supplier or pet food manufacturer petitions AAFCO to begin the process to define the ingredient and in many cases establish nutrient parameters;
AAFCO Ingredient Definitions Committee develops the ingredient definition and members vote on its approval;
Once approved, the ingredient becomes ‘official’ when it is published in the AAFCO Official Publication;
States accept the AAFCO new ingredient definition into law;
Pet food companies begin to include newly approved ingredient into their formulas.
The entire process could take several years.
So again, why or how can these ingredients be used in so many pet foods when they are not ‘official’ pet food ingredients?
I was told (by a State Department of Agriculture representative) that most states “allow for enforcement discretion for unapproved ingredients.” (Sad words so common in pet food…enforcement discretion.) In other words, most states allow for pet foods to include ingredients that have no official definition (meaning who knows what is in the ingredient and nobody cares!). States that allow ‘enforcement discretion for unapproved ingredients’ are allowing pet food manufacturers to decide what they want to include in their pet foods – not insisting manufacturers abide by law.
This is so wrong – in so many ways. By states allowing ingredients that are not official, states are telling pet food manufacturers they (basically) don’t care about what goes into the pet food. Throw anything in there – call it a balanced diet – we’re good with that.
And the blame doesn’t stop with state pet food regulators…pet food manufacturers have no excuse either. Any pet food manufacturer should know what ingredients are ‘legal’ and should only use those ingredients. Pet food manufacturers should not – on a whim – jump to include a trend ingredient when that ingredient has not gone through the regulatory process (have an official definition).
I’ve heard through the pet food grape vine that some states are taking action – advising pet food manufacturers to remove the ingredients pea protein and pea fiber within 30 days or risk the product being removed from store shelves (by the State Department of Agriculture). I hope this information is true.
The pea protein and pea fiber ingredients need to go through the AAFCO process and become an officially defined pet food/animal food ingredient. Which I’m certain they will. But until then, no pet food manufacturer should put their own preferences of ingredients in front of the regulatory process. They are not legal official ingredients until they are legal official ingredients. Don’t use them until they are. Cart before the horse don’t you think?
Let’s hope that State Department of Agriculture Representatives in all states take action and demand pet food manufacturers remove ingredients that have no legal – official – definition. Thanks to those states that have already taken action!
If your pet food contains either the ingredient pea protein or pea fiber, you might want to call the company and ask why they are using an ingredient that has no official definition. I’ll be curious to see what they tell you – please forward me their responses.
And one last thing – the pet food ingredient ‘pea’ is a legal ingredient. My own dogs eat peas in their home prepared foods – and my cats eat them when they steal them from the dogs bowls.
Wishing you and your pet(s) the best,
Association for Truth in Pet Food
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
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