“Natural” is a descriptive term that sounds positive, even though misperceptions about the word abound in regards to pet food labeling and claims. In the past, the term was undefined in both state and federal feed control jurisdictions and was not seen in the marketplace. But in an effort to appeal to customers, marketers have increasingly used the term on pet food product labeling.
Presently, AAFCO’s definition of natural is:
a feed or feed ingredient derived solely from plant, animal or mined sources, either in its unprocessed state or having been subject to physical processing, heat processing, rendering, purification, extraction, hydrolysis, enzymolysis or fermentation, but not having been produced by or subject to a chemically synthetic process and not containing any additives or processing aids that are chemically synthetic except in amounts as might occur in good manufacturing practices.
In the majority of states, which have adopted the AAFCO Model Bill and Model Regulations, pet food labelers/guarantors must comply with this definition to display the term.
The U.S. Food and Drug Administration (FDA) has not yet defined natural in relation to pet food labeling. Instead, it relies on the federal requirement that labeling must not be false or misleading.
Breakdown of the Definition
· There is no requirement or statement that natural feeds or ingredients are safer than those produced by a chemically synthetic process.
· Natural is a liberal term that includes more ingredients than it excludes—most pet food ingredients are derived from “plant, animal or mined sources.”
· A feed ingredient can be subject to a number of commonly-used processes during the manufacturing process and still be deemed natural.
· A feed or feed ingredient can contain trace amounts of chemically synthetic compounds and still be considered natural.
The following ingredients do not fit the AAFCO definition of natural:
· Ingredients that are chemically synthesized, such as vitamin ingredients, mineral ingredients, preservatives and special-purpose food additives.
o Some examples include chelated minerals, mineral amino acid complexes, vitamin supplements, propylene glycol, calcium ascorbate and other preservatives, such as BHA and BHT, as well as artificial flavors and colors.
· A whole product can claim to be all-natural or 100% natural when every ingredient used to manufacture the product complies with the feed term.
o There should not be claims such as “all-natural with added. . .” because a product cannot be “all-natural” if it has synthetic ingredients.
· Natural may apply to a specific ingredient used to manufacture a product provided that only the specific ingredient is identified as natural.
o For example, if the label reads “contains natural chicken flavor,” a consumer understands that the manufacturer only claims that flavoring meets the definition of natural.
· Products in which synthesized ingredients play a role in manufacturing but otherwise comply with AAFCO’s definition can be called natural.
o Provided that the synthesized ingredients used are limited to synthetic vitamin, mineral and trace nutrients
o They must display the disclaimer “Natural with added vitamins, minerals and trace nutrients” (or similar).
o Synthesized ingredients other than vitamins, minerals and trace nutrients do not qualify under this exception.
o The phrase “Natural with added vitamins, minerals and trace nutrients” is a disclaimer—not a boast—that identifies the synthetic ingredients in an otherwise natural product.