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Commercial Pet Foods 163

Box 8-2. Product Claims.
VetBooks.ir A claim promotes the relationship between a product and a desired maximum calorie content requirements. In those cases, though, the

attribute or result. Claims are important because they help pet food product of comparison and the percentage reduction must be speci-
manufacturers differentiate their products from those of competitors, fied.Similar AAFCO rules are in place for “low”and “reduced”fat prod-
and in some cases, demonstrate product superiority. In the process, ucts.
companies spend thousands to millions of dollars substantiating
claims. Structure/Function Claims
Claims appear in several product sites and on promotional materi- Because nutrition has an effect on the structure or function of the
als.A claim may appear as part of a product name (e.g.,“light formu- body, claims describing a food’s role in maintaining health and well-
la”) or elsewhere as part of a product’s labeling. “Labeling” is a broad being are generally allowed provided they relate to recognized nutrient
term that includes the product’s packaging or anything in association effects. Acceptable structure/function claims include such things as,
with the product at the point-of-sale (e.g., banners, brochures) “Contains calcium for strong bones and teeth” and “Taurine is essen-
(Chapter 9). Print or television advertising is not “labeling” under the tial to the good health of your cat.” Claims such as “for healthy skin
law, but in many cases, websites are considered “labeling.” and glossy coat” are also generally considered acceptable.

CLAIM REGULATION Therapeutic Food Claims
In general, pet food labeling claims in the United States are regulated Therapeutic claims for veterinary medical foods are regulated at the
for legality, truthfulness, accuracy and fairness by the Center for discretion of FDA (Box 8-3). Generally, these claims are restricted to
Veterinary Medicine in the Food and Drug Administration (FDA) and by veterinarian-directed literature, but regulators may tolerate consumer
the individual states. In addition, the Federal Trade Commission has information if the product is distributed under a valid veter-
regulatory authority over media advertising (print, radio and television). inarian/client/patient relationship. Manufacturers who make therapeu-
Frequently, companies will choose to keep claims and/or advertising tic food claims formulate foods for the nutritional management of a
disputes out of the regulatory arena by mediating them with the condition or disease. Examples of therapeutic food claims include,
National Advertising Division of the Better Business Bureau, a volun- “Helps control the clinical signs associated with sodium and fluid
tary self-regulating industry body. When all else fails, these disputes retention,” “An aid in the dissolution of struvite uroliths” and “A nutri-
enter the judicial system for final resolution. The Lanham Act is often tional aid for dogs with dental stain, plaque or calculus.”
the basis for these legal actions.
Health Claims
TYPES OF CLAIMS Health claims state or imply a relationship between food and disease.
Several types of claims exist: 1) general, 2) nutritional adequacy, 3) Technically, the health claim regulations only apply to human foods.
descriptive, 4) structure/function, 5) therapeutic foods, 6) health and However, FDA has allowed some health-related information on pet
7) drug. food labels provided certain conditions are met. For example, FDA
allows “reduces urine pH to help maintain urinary tract health”on adult
General Claims maintenance cat products based on controlled studies to demonstrate
General claims describe unique product attributes such as composi- utility and long-term safety. Label claim wording must also meet FDA
tion or ingredients, flavors and varieties, palatability and digestibility. restrictions. A related claim on cat food labels is “low magnesium.”
These claims must be truthful and are often called “marketing”claims. Low-magnesium foods must contain less than 25 mg of magne-
Palatability claims are a frequently used type of general claim. sium/100 kcal of food and less than 0.12% magnesium on a dry mat-
Comparative claims have a lifespan of one year before they must be ter basis.
re-substantiated. “New” and “improved” claims are limited to six FDA has also allowed “hairball control” claims for products after
months production. review of formulations and nutrient profiles,and “plaque/tartar control”
claims for products provided the effect is achieved by mechanical
Nutritional Adequacy Claims means.
For all practical purposes, nutritional adequacy claims are primarily
regulated in the United States using the procedures and protocols Drug Claims
established by the Association of American Feed Control Officials Drug claims are highly regulated by the FDA under the authority of the
(AAFCO). To make a “complete and balanced” nutritional adequacy Federal Food, Drug and Cosmetic Act (FFDCA). Basically, any
claim, pet food manufacturers must either conduct a feeding test expressed or implied intent to cure, treat,prevent,mitigate or diagnose
(AAFCO protocol) or meet the minimum AAFCO nutrient profile disease is considered a drug claim. Such claims require pre-market
(Chapter 9). Lifestage claims are included as a subset of the nutrition- approval by the FDA, and require extensive resources to document
al adequacy claim. safety and efficacy. Such research takes years to conduct, but, if the
research leads to FDA approval, the product usually has market exclu-
Descriptive Claims sivity.A pet food whose labeling bears unapproved claims may be sub-
Descriptive claims must meet AAFCO requirements. Examples of ject to regulatory action as an adulterated drug.
descriptive claims include “light” or “low-calorie” foods. For example,
dry canine and feline foods bearing a “low-calorie” claim must contain David A. Dzanis, DVM, PhD, Dipl. ACVN
no more than 3,100 and 3,250 kcal/kg of food as fed, respectively. Dzanis Consulting & Collaborations
“Reduced” and “less calorie” pet foods do not have to meet specific Santa Clarita, CA, USA