DOAG: ANIMAL FEED AND PET FOOD INDUSTRIES IN CONNECTICUT




July 11, 2018

ANIMAL FEED AND PET FOOD INDUSTRIES IN CONNECTICUT

Kate Ciarletta, Food Safety and Agricultural Commodities Unit, Bureau of Regulatory Services

Approximately 40 manufacturers of animal feed and pet food (which includes pet treats and specialty pet food products) are located in Connecticut.

Connecticut’s animal feed and pet food manufacturers vary in size with some selling only locally, mainly at farmers’ markets, while others distribute their products nationally— but all contribute to the state’s economy, and all are regulated by the Department of Agriculture (DoAg).

“Pet and other animal food must meet specific requirements designed to help ensure their safety,” said Agriculture Commissioner Steven K. Reviczky. “Review of these products is an important component of our Bureau of Regulatory Services and one we take seriously. Consumers should have confidence in the products they feed their animals.

All animal foods, including pet food and pet treats, are regulated in a similar fashion as human food. Livestock feed, pet foods, and pet treat manufacturing are regulated by DoAg’s Bureau of Regulatory Services to ensure healthy and wholesome food for livestock and pets.

The American Feed Industry Association (AFIA) issued a report1 in October of 2017 that the animal feed and pet food industry is an important driver of economic activity in the United States. Through purchases from and sales to many other industries, the animal feed and pet food manufacturing industry has a large impact on the local, state, and national economies. 

According to the 2016 U.S. Animal Feed and Pet Food Manufacturing Industry Economic Contribution Study, animal and pet food manufacturing creates a significant number of sales, jobs, and taxes.

 

United States

Connecticut

Total Sales

$297.1 billion

$414.2 million

Jobs

944,227

1,081

Taxes

$22.5 billion

$32.7 million


Manufacturing facility registration is a recent requirement for Connecticut animal feed and pet food manufacturers.  All firms are required to register but only animal feed and pet food manufacturers with gross annual sales that exceed $25,000 must pay a registration fee.

Every firm that sells animal feed, pet food, or pet treats in Connecticut must register their products with DoAg, regardless of the state of origin. 

The product registration process requires each company to provide a physical copy of the product label for each product they intend to sell, along with a completed product registration form and payment of the fee associated with each product registration.

The DoAg labeling requirements mirror the Association of American Feed Control Official (AAFCO) Official Publication labeling requirements. The labeling requirements are in place to ensure label consistency and no false claims.

All labels are reviewed for compliance. As an example, all pet treat labels must include at a minimum the following:

1. The brand name and product name appearing conspicuously on the front upper third of the label.

· Be aware of the AAFCO naming rules: 100% rule, 95% rule, 25% rule, 3% or the “with” rule, and flavor designation rule. Most pet treats fall under the 100% or 95% rule.

 2. Intended use: the word “snack” or “treat” appearing conspicuously on the front of the label and/or state “intended for intermittent or supplemental feeding only.”

· Treats are not required to display a nutritional adequacy statement or other purpose statements unless they are complete and balanced.

3. The animal species for which the treat is intended. (Dog, Cat, etc.)

4. The manufacturing company name and address or point of contact.

5. The net weight of the package appearing on the front lower third of the label.

6. An ingredient list, from largest to smallest by weight (listed under the title “Ingredients”).

· Ingredient names must be listed by the common or usual name.

· See the AAFCO Official Publication for more information on ingredients.

7. A guaranteed analysis for crude protein by % minimum, crude fat by % minimum, crude fiber by % maximum and moisture by % maximum (listed under the title “Guaranteed Analysis” and listed in the order above).

8. Feeding directions if required (only required if the treats are complete and balanced but they are recommended to have on the label).

9. Calorie content must be listed under the heading “Calorie Content” and shall be measured in terms of metabolizable energy (ME) on an “as-fed” basis. Must be expressed both as “kilocalories per kilogram (kcal/kg)” and kilocalorie per familiar household unit.

Labels may also include the following:

· Lot number: a distinct code for the company to identify the manufacturing or packaging date.

· Raw ingredients: if the pet food/ pet treats contain raw uncooked foods such as meats, eggs, milk, seafood etc., safe handling instructions to inform the consumer on the proper way to handle the raw product must be on the label. [Please visit the CT Food Safety Guidelines and Regulations document at http://www.ct.gov/doag/lib/doag/marketing_files/11._food_safety_3-27-2009.pdf for more details about potentially hazardous foods.]

In addition, label claims cannot be false or misleading.

· Natural claims, in the AAFCO Official Publication Chapter 4 titled “Guidelines for Natural Claims”: there are guidelines and explanations on how the term “natural” may be used in a non-misleading manner.

· Organic: pet food products labeled “100% organic,” “organic,” and “made with organic____” may not contain any ingredients produced with the use of sewage sludge, genetic engineering, or ionizing radiation.

· Human grade claims: the entire product needs to meet USDA and FDA standards for human grade food.

For more in depth information on pet food labeling, go to https://petfood.aafco.org. For more information on manufacturing animal feed, pet food, and pet treats as well as facility, and product registration forms visit www.ct.gov/doag.

1 http://www.afia.org/Files/180122%20Economic%20Contribution%20of%20Animal%20Feed-Food%20Industry%20(IFEEDER)_FINAL.pdf


The following decision tree shows DoAg’s regulations and requirements for manufacturing animal feed, pet food, and pet treats.






* “Potentially Hazardous Food”- any food or food ingredient that is capable of supporting the growth of infectious or toxic microorganisms. Ex: eggs, meat, milk, seafood, etc.

Please visit the CT Food Safety Guidelines and Regulations for more details about Potentially Hazardous Foods.

** CT Product Label Registration Form and CT Manufacturing Facility Registration Form

*** Visit these links to the FDA website for guidance on Food Safety Plans and Current Good Manufacturing Practices (CGMP):

https://www.fda.gov/downloads/Food/GuidanceRegulation/FSMA/UCM517391.pdf

https://www.fda.gov/downloads/AnimalVeterinary/GuidanceComplianceEnforcement/GuidanceforIndustry/UCM499200.pdf