New product development in North American pet food, treats and supplements was down 28% in 2020 when compared to the prior three-year average, according to Innova. Despite fewer products having been introduced to the market, however, there was no shortage of innovation in the pet category.
According to international taste and nutrition company Kerry, a review of more than 1,800 products introduced into the North American pet food market in 2020 revealed these four key trends: meaningful mealtime, primal proteins, the calming effect and meaty mix-ins.
For many of today’s pet owners, just serving up Fido’s food in a bowl is not enough. Consumers want their pet’s mealtime to move from mediocre to meaningful. And from meaty mix-ins to a bone broth in an aluminum can that allows pet owners to share a “brew” with their furry friend, pet food companies have been up to the task of meeting their consumers’ demands. Additionally, these manufacturers can build on this trend by using functional ingredients to support digestive health and boost immunity.
The bottom line is this: no matter the ingredients, pet food manufacturers must manage them.
According to Pat Tovey, director of technology and regulatory compliance at the Pet Food Institute (PFI), U.S. pet food makers use a variety of ingredients to create dog and cat food recipes that both offer complete and balanced nutrition and provide for consumer choice.
“In first-of-its-kind research, PFI partnered with the Institute for Feed Education and Research (IFEEDR) and the North American Renderers Association (NARA) to better understand ingredient usage in pet food. By looking through year-long sales, research found that pet food makers used 8.65 million tons of animal- and plant-based ingredients for dog and cat food, at a value of $6.9 billion,” he says.
The research also shows that farmers and ranchers purchase roughly $5.3 billion in materials and services from farm suppliers, who purchase roughly $4.1 billion in inputs from other industries. Additionally, pet food manufacturers use roughly 8.65 million tons of animal- and plant-based ingredients, with more than 500 ingredients used in dog and cat food.
Tovey says some people may not realize that pet food is one of the most highly regulated food products in the U.S. “This includes regulations at the federal level and at the state level,” he says. The FDA regulates both finished pet food products (including treats and chews) and their ingredients. Federal requirements include FSMA, which requires pet food makers identify and analyze possible hazards in the food manufacturing practice and implement controls to mitigate for critical incidents.
“These are called ‘preventive controls,’” Tovey says. “For example, this could include using heat treatment—cooking to a certain temperature—to control for salmonella. In a pet food maker’s food safety plan, they must identify hazards and then identify and implement programs to control them.”
Tim Lombardo, senior director at EAS Consulting Group, Food Consulting Services, adds that all ingredients used in the manufacture of pet foods must be safe as well as have an appropriate function in the pet food. Since 2016, a new FDA regulation was implemented specific to the manufacture of pet foods and their ingredients.
He says this regulation (21 CFR 507: Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Food for Animals) requires the following:
- Implement good manufacturing practices that include requirements for employees, facility design, equipment upkeep and maintenance
- Identify and evaluate biological, chemical and physical hazards that may be associated with the foods as well as implement procedures, referred to as preventive controls, to address those hazards
- Develop and implement a food safety plan; develop, in some cases, a recall plan.
- Comply with other FDA regulations such as the Foreign Supplier Verification Program and Sanitary Transportation Rule
Additional regulations are also in place to ensure minerals, vitamins, preservatives, flavors, and colors are safe for consumption by our pets, Lombardo says.
Beyond federal requirements, pet food also is regulated at the state level, Tovey says. “Nearly all states require products sold therein to be registered, and for their labels to adhere to strict requirements regarding product names and ingredients. As part of this process, an organization called the Association of American Feed Officials (AAFCO), consisting of state regulatory officials, develops a model bill and regulations for pet food that states can adopt into their respective state commercial feed laws. This includes setting definitions for pet food ingredients, as well as guidelines for marketing claims such as ‘human grade’ or ‘natural,’” he says.
Lombardo agrees. “It is important to be aware of and be compliant with pet food labeling requirements. Pet food labels are regulated at the federal level as well as at the state level. Many of these regulations are based on a model provided by AAFCO.”
Pet food is one of the most highly regulated food products in the U.S. During a regular FSMA inspection, manufacturers may be asked to share their food safety plan to demonstrate their adherence to food safety practices. | Photo courtesy of Getty Images/ArtCookStudio
When it comes to enforcing the standards, Lombardo says when a product is in question, the FDA’s first priority is to determine if a product recall and public notification is warranted. Beyond that, the FDA has the authority to conduct a number of actions: advisory, administrative, and/or enforcement. He says that advisory actions are in the form of a warning letter. “Warning letters are the FDA’s principal means of notifying an organization of violations. Firms receiving a warning letter must respond with a corrective action plan within 15 days.”
Administrative actions typically (but not always) starts with a facility inspection. “If food safety violations are determined, the organization may receive a FDA Form 483. Other administrative actions include FDA mandated recall, import refusal, suspension of a food facility’s registration, as well as disbarment and disqualification of the facility or company,” Lombardo says. Enforcement actions will involve legal actions to include product seizure, injunction order, and even criminal prosecution.
Tovey adds that from a regulatory perspective, it is commonly a state department of agriculture official who may pull a product from store shelves to verify accuracy of label claims, test for pathogens and ensure nutritional compliance. “In addition, pet food makers must have a written food safety plan documenting how they account for any known and foreseeable safety hazards in their manufacturing process. During a regular FSMA inspection pet food makers may be asked to share their food safety plan to demonstrate their adherence to food safety practices,” he says.
Beyond food safety, pet food makers will set various product specifications based on their formulations, target market or price point. These specifications may include factors such as a specific nutritional content, exact part of a plant- or animal-derived ingredient used, or physical quality standards, such as color or shape, Tovey says.
Pet food makers must have a written food safety plan that documents how they account for any known and foreseeable safety hazards in their manufacturing process. | Photo courtesy of Getty Images/Sanjagrujic
Ingredient verification, COAs
It is imperative for pet food makers to work with trusted and reliable ingredient suppliers, Tovey notes. As dog and cat food makers work with their ingredient suppliers, they may take additional steps to ensure ingredient safety and quality, including:
- Conducting regular ingredient supplier audits. Supplier audits are required under FSMA, but pet food makers may go a step further and increase frequency.
- Requiring that the ingredient supplier provide a Certificate of Analysis (COA) that confirms quality and safety checks.
- Testing incoming ingredients for safety and quality. This may mean sampling for safety hazards such as mycotoxins or confirming protein, fat, moisture and ash content.
Lombardo notes that the receiving company conducts the verification of ingredients. “As ingredients may be sourced either domestically or imported into the US, verification activities will vary,” he says. For domestically sourced ingredients, suppliers are often approved through questionnaires, review of food safety systems and facility audits. Ingredients are most commonly verified either through testing or by comparing the results listed on the COA to the specification requirements.
“For ingredients imported into the United States, another FDA regulation (Foreign Supplier Verification Program, or FSVP) details all of the regulatory requirements for ingredient verification. The entity identified as the importer of record must ensure compliance to FSVP. This make be a broker, distributor or the manufacturing company,” Lombardo says.
A COA is a document that attests that certain laboratory tests were performed on the ingredient and includes the result of testing that was requested by the manufacturer. “It is often a requirement that a COA accompanies the ingredient during shipment so that it can be reviewed before the product ever exchanges hands,” Tovey says.
Lombardo adds that the COA affirms that the ingredient meets the quality and food safety requirements. “The required tests depend on the ingredient but often include both food safety (pathogens of concern, foreign material, water activity) and quality (color, odor) attributes. The required tests for each ingredient are included on the product specification, which should be mutually agreed upon by both the suppling and receiving companies,” he says.
There are several different types of testing and instruments used for managing pet food ingredients to ensure quality and safety. Pet food manufacturers will test in a variety of ways to help control against known and foreseeable hazards that may occur during the manufacturing process.
“For example,” Tovey says, “pet food makers will sample and test incoming loads of grain ingredients for mycotoxins upon arrival at the manufacturing facility. Prior to receipt, the pet food maker can pull a representative sample from throughout the load for testing to make sure the product is safe, and not allow entry into the facility if the ingredient does not meet safety standards. Using accept/reject criteria such as this would meet the preventive control requirements of FSMA, since the company is taking steps to mitigate that identified hazard.”
Pet food makers also take seriously the possible presence of pathogens throughout the production line, such as salmonella, listeria or E. coli. Facilities may take random samplings of the production environment to ensure no salmonella or other pathogens are found and that the environment is not conducive to growth of these bacteria, test incoming ingredients and sample the finished product, as well, Tovey adds.
“Pet food makers may even go so far as to use magnets, metal detectors or density detectors to keep food safe,” Tovey says. (Read more here) As ingredients move between trains, trucks, production lines and packaging, it is possible that items such as small rocks or pieces of metal can somehow enter the product. Pet food makers are aware of this risk and work to keep food safe along the way by monitoring for any outside objects that do not belong.
Lombardo adds, “For safety, testing could include microbiological analysis for pathogens of concern. Chemical testing for mycotoxins and physical testing for foreign material may also be relevant. Specific to quality, microbiological testing could include spoilage organisms such as yeast and mold.”
Chemical testing could include moisture content. For physical testing, color, odor and flavor could all be important attributes.
Instruments for all these tests range from very complex, sensitive machines to visual comparisons against a standard. Some tests are on the factory floor while others, such as pathogen testing, requires a certified laboratory and trained microbiologists to conduct.
When asked about the biggest challenge when it comes to managing pet food ingredients, Lombardo says, “In my opinion, the biggest challenge to managing pet food ingredients is implementing a robust supplier quality and food safety program. Oftentimes, manufacturers will assume that the ingredient supplier is doing ‘all the right things, in accordance with the regulations.’ This is not always the case. And, if an issue with a pet food ingredient results in a product recall, the pet food manufacturer’s brand, being the most recognizable, takes a big hit with the public.”
Tovey adds that there are many challenges that pet food makers face when managing ingredients on a day-to-day basis, such as supply chain issues or ingredient shipments. “However,” he says, “the biggest and undoubtedly the most important challenge is caring for pets. The first and foremost commitment of Pet Food Institute members is to make safe pet food for America’s dogs and cats. It is through the careful food safety planning, working with trusted ingredient suppliers and strong regulatory framework that pet food makers work to meet this important requirement.”
For more information:
Pet Food Institute, www.petfoodinstitute.org
EAS Consulting, www.easconsulting.com
Read a Q&A with Northwest Natural's Amy Snell on setting quality standards for pet food ingredients.