New product development in North American pet food, treats and supplements was down 28% in 2020 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 consumer demand.

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.

Setting standards

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 state level. Many of these regulations are based on a model provided by AAFCO.”

Enforcement

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) start with a facility inspection. “If food safety violations are determined, the organization may receive an 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.