Recently there has been a lot of talk geared towards discounting the Prey Model Raw style of feeding because it does not comply with AAFCO, the Association of American Feed Control or NRC (National Research Council) standards. This is sad and misleading for several reasons. Following these standards actually could be harming your companion and putting quality raw food companies out of business or targeted with unwarranted hate.
Nature is a self-serving, self-feeding (pun intended) system. Without human intervention, it thrives perfectly on its own. Animals are healthy on their natural diets.
Carnivores like our feline and canine friends eat varying degrees of herbivorous prey. While large wild cats and dogs eat larger game, the ancestors of our small domestic cats and dogs feasted and continue to feast on the small game including rodents, rabbits, small birds, insects and more.
In the wild ancestral dogs and cats hunt for their food, it’s not handed to them in a nice bowl at scheduled meals during the day. Some days one may hunt for hours and catch several mice, other days one may go to bed with nothing. Eating can be inconsistent and vary in prey and amount from day to day and week to week. Wolves, in fact, can go up to 1.5 weeks without a meal. Therefore the conclusion we derive from this is that animals don’t eat a balanced meal every day, twice a day.
Prey Model Raw is based on the average ratios of prey found in the wild. The ratios will vary of course depending on the animal, for example, a mouse is 85% meat 5% bone 4% liver And a rabbit is 84% meat 10% bone, 4% liver. But when you average these ratios it comes to approximately 80% meat 5% liver 5% other secreting organs and 10% bone. One of the added benefits of human intervention is that while our companions consumed 3-4 protein sources and often not on a daily basis, we humans can provide them with many more proteins to further provide a fulfilling and complete diet. Therefore the conclusion here is that with a wide variety of proteins, that model the ratios of prey eaten in the wild, we humans can provide a nutritionally complete diet.
So let's dive more into the AAFCO and NRC, who they are, what they mean and how it applies to species appropriate prey model raw diets.
The AAFCO is a group of state and federal government employees that work for a non-government association. These officials help to create laws that control the food animals eat. The food animals eat according to the AAFCO is considered “feed”. Animals eat “feed”, while humans eat “food” despite us pet owners calling it pet food. What is the difference? According to FDA Compliance Policies and AAFCO established model bills, “food” is not allowed to utilize euthanized animals or ingredients exposed or poisoned by pesticides whereas “feed” is allowed to be.
AAFCO Feed Statements and what they mean
1.) “Animal feeding tests using AAFCO procedures substantiate that this product provides complete and balanced nutrition for all life stages of dogs and cats.”
-This company ran a food trial to obtain this statement
2) “This product is formulated to meet the nutritional levels established by the AAFCO Dog and Cat Food Nutrient Profiles for All Life Stages (or for growth).”
-These manufacturers have decided not to test a product using food trials so their food is based on food that has already meet the nutritional values set by the AAFCO.
The National Research Council or NRC does caution with the use of statement 2. Depending on the ingredient, nutrient digestibility and bioavailability will vary. So while the nutrient values may be the same, it doesn't mean the animal will utilize the various ingredients properly.
Unfortunately, there also can be differences from each batch and since pet food producers are not required to test each and every batch, they also aren’t required to be reported on the label.
3) “This product is intended for intermittent or supplemental feeding only.”
-This label means the food doesn’t meet AAFCO standards
How Foods Meet AAFCO Standards?
There are two primary methods that allow pet feed companies to add one of three AAFCO feed statements to their package.
The Analytical Method
This method chemically tests the food. The ingredients don’t matter just the test results. If it contains the right proteins, carbs, moisture, etc, the food passes the test.
2) The Feeding Trial Method
This method involves food trials. In order for the food to pass this method, the following has to occur:
There must be eight animals included in the trails
Two are allowed to not finish the trial, so only six need to complete it
Any breed or gender can participate
The trial only needs to run for 26 weeks unless the trial is for growth then only 10 weeks is required
The animals are only fed the food being tested
They must have unlimited water
The animals must be pronounced healthy in pre- and post-trial veterinary exams
Four blood values (hemoglobin, PCV, alkaline phosphatase and albumin) are measured and the averages are compared to specified minimums.
Problem with these Guidelines
The guidelines don’t seem to complicate, but that is the exact issue. The bar is set so low that almost any food is going to be approved. A pet food company would actually have to try to fail this test.
There are a few issues that are notable.
An eight animal sample size is not a statistically significant number and when you account for two animals that can drop out that's even fewer animals that represent the whole populations of unique companion animals that will be fed this food.
With breed or sex being irrelevant (and who knows what other factors), how is this a proper study? Many factors should be accounted for in order to find potential correlations and correct data.
The trial length of 26 weeks, or for growth 10 weeks, is not nearly enough time to determine if food will cause illness, disease, deficiencies or toxicity, among other issues, for an animal that will eat this food potentially for its lifetime. This is obvious as well considering 90-95% of animals have a whole slew of illnesses on AAFCO labeled feeds.
While animals do get a basic entrance and exit exams and measured for four blood values, there are no tests run on urine, feces or other basic blood tests that Veterinarians routinely test for.
Feeding trials are actually fairly rare for pet food companies. This primarily is because it is time-consuming and expensive. Therefore the AAFCO does allow one of their feed statements to be added to a pet feed bag if :
The food meets the nutrient requirements of the nutrient profile
The food is similar to a food product that does
As you can see, again it would be hard for a pet feed to fail this test. The bar has been set extremely too low.
Misconceptions About the AAFCO
The AAFCO is not a government organization. Government officials may work for the organization but the organization itself is a non-government group
The AAFCO does not regulate pet food
The AAFCO does not test pet food
The AAFCO does not certify pet food
The AAFCO has no enforcement authority
Don’t believe us? Check out the AAFCO website (https://petfood.aafco.org/) It’s posted on their website!
Raw Pet Food And AAFCO
The AAFCO and raw pet food just don’t mix, unfortunately. First and foremost, the AAFCO fully admits that raw foods just aren’t feasible to be applied to their standards. As stated on their website “...the majority of complete pet food products are not raw. They have been heat-treated during manufacturing to prevent microbial contamination. Pet food manufacturing plants often have limits regarding the receiving, storing and use of ingredients that make most raw ingredients impractical.” By this simple fact, the AAFCO is irrelevant to raw food and raw food principles.
Why is the AAFCO standards not appropriate for raw food?
The AAFCO’s requirements were created for processed food like dry food and canned food to use industrial waste products. This doesn’t account for bioavailability of food ingredients from whole food or raw foods versus those of synthetic and biologically inappropriate ingredients.
AAFCO standards are based on what they call “commonly used ingredients.” These ingredients are cheap and nothing but industry waste. How are these ingredients appropriate to feeding a living, breathing companion animal?
Some examples of these commonly used ingredients include:
-Meat and bone meal
-Animal byproduct meal
-Chicken liver meal
-… and more
If these are the ingredients the AAFCO commonly uses, again how can this apply to raw food when a raw diet is comprised of fresh unprocessed meat, organs, and bone? Many raw feeders do not feed a commercial dry or canned food to AVOID these ingredients in favor of quality bioavailable ingredients that are species appropriate.
One Size Fits All
The AAFCO standards are a “one size fits all” but we know, just like humans, our companions are individuals. They have their own needs and requirements depend on numerous factors. A 10 lb obese dog with diabetes is not the same as a 10 lb dog that is highly active and pregnant.
“The amount of any needed nutrient falls in an optimal range rather than being a specific amount,” says Dr. Donald Strombach DVM, PhD.
What if you YOU decide your pet needs to lose weight and reduce their intake by 25%
What if YOU decide to add extra treats and snacks? Will they be getting everything they need nutrient wise, if the package said you need to feed this much, for this weight dog, no matter if it is active, pregnant or a couch potato?
Due to this, raw foods just don’t fit into these standards. For one, a raw food diet would have to go outside the prey model ratios to meet these requirements which would require increasing certain ingredients that may actually be very dangerous for our companions. This could mean increasing specific nutrients to toxic levels just to make the AAFCO nutrient claims. They may be required to add artificial vitamins and minerals. This not only goes against nature, PMR standards but also comes with its own list of nasty side effects.
Vitamin and Minerals
If extra whole food ingredients are not added to food then artificial vitamins and minerals are recommended to “fill the gaps” to meet AAFCO standards. There are several issues with this, however. One issue is that mineral requirements are based on the function they provide in overheated, processed diets such as that found in dry pet food. In raw food, the minerals aren’t heated and processed so the amount put in isn’t changed. You wouldn’t add a supplement because it’s already there in its entirety. But based on AAFCO guidelines each food must have certain supplements added.
Zinc has very low bioavailability when fed via dry pet food and the phytates (found in legumes, whole grains and nuts common in dry pet food) bind to zinc actually making it unable to be utilized by our companions.
There are no phytates in a PMR diet so we have little concern with zinc not being utilized in most cases. Zinc also works with calcium. If calcium is lower in the diet, so is the requirement for Zinc, with the opposite being true for diets higher in calcium. Therefore the requirement would be higher in dry pet food where zinc is not as available versus a raw diet where it is. So why should the same standard apply to both diets according to the AAFCO? Instead, you risk toxic levels being reached. Calcium, Iron and Magnesium also is bound to phytates making them less available just like zinc.
Grains such as those found in dry foods can also affect phosphorus. The more grain the more phosphorus that is required. In a PMR diet, you don’t include grains so following the AAFCO standard for phosphorus would be dangerous for your raw fed companion animal.
Protein is also affected. When in a dry commercial diet the high heating process alters proteins in a less usable form, also altering the availability of amino acids like lysine, cysteine, and methionine. In a raw diet, these ingredients are virtually unaltered. Therefore, following the same standards according to AAFCO is inappropriate.
Can’t you just add Artificial Vitamins and Minerals to make up for the “Gaps”?
Sure you CAN but should you? Firstly artificial vitamins and minerals go against the principles of a PMR diet. Just like human foods, unprocessed whole foods are the best source of nutrients.
Secondly, they can be very dangerous. Most whole foods have various components that make up the vitamin or mineral. For example vitamin C has eight, however, the artificial version only has one. The artificial versions are chemically and structurally different. They absorb, metabolize and have different bioactivity. DVM Ron Carsten explains these vitamins and minerals are added to make up for the nutrient loss during processing however these supplements add metabolic stress, compromised nutritional status, and tissue malnutrition furthermore, they have their own nasty side effects.
Speaking of vitamins and minerals - to meet AAFCO nutrient standards, vitamin and mineral premixes are added to food that meet these standards. While they may make a food complete and balanced, according to AAFCO standards, the premixes themselves are not regulated which means there is no regulation of quality or source nor utilization efficiency.
Is there more?
Unfortunately, in addition, the AAFCO has not determined maximum requirements for many nutrients thus, in turn, causing many manufacturers to over supplement after high cooking processing that destroys many nutrients, endangering the lives of our companions.
As stated by the AAFCO, they have “insufficient data to recommend minimum and maximum levels for the following minerals: calcium, iron, magnesium, zinc, manganese, selenium.”
What about the Complete and Balanced claim the AAFCO makes?
AAFCO assumed requirements were established for feed animals to get 100% of their nutrients EVERY SINGLE DAY. Why? Because this was established for animals that were being mass produced that didn’t live long and were meant for food after slaughter. Companion animals, however, live longer lives and are not mass produced.
Furthermore, these standards are not based on calorie needs. It doesn’t account for animals that have higher energy nor lower energy. What's the problem with that? Some companions will consume more vitamins and minerals than they need which can be very dangerous and cause illness and disease. Others may suffer deficiencies again causing a slew of issues.
This Complete and Balanced statement also does not correlate to the feeding guidelines on the pet food labels
Let’s look at a few dry foods for cats labeled with AAFCO statements
*Adult chicken recipes
Let’s look at a few dry foods for dog labeled with AAFCO statements
*Adult chicken recipes
Finally, the AAFCO doesn’t recognize certain nutrients that have been proven via scientific studies such as krill oil or probiotics. There is no AAFCO standards or even a comparison to the nutrients in whole prey which actually has been reported by the NRC already. Essentially this means, if the AAFCO doesn’t think a product has value, then it’s irrelevant - this includes raw food and whole food items. This makes no sense and is completely unscientific.
The energy source of the food has absolutely no reflection of the anatomy and physiology of an animal’s and their natural diet or makeup either.
The AAFCO is confusing to the Average Customer
The guaranteed analysis on pet food labels found of pet food packaging is listed on an “as fed basis” however for a pet owner to compare one food to another they must do extensive math to account for moisture in a diet and compare on a “dry matter” basis. A pet food that has 90% protein and 10% moisture is not the same as pet food with 90% protein and 7% moisture. On a dry matter basis, this is 100% protein and 96% protein respectively.
Additionally, while the AAFCO released new standards on a yearly basis, their standards are subject to change at any time as stated in their manual. So while you may be following their standards you may be feeding a product that is no longer valid tomorrow. So while the AAFCO claims their standards are “ final and valid” they also claim their standards “subject to change” all of which is a complete contradiction in itself.
While the pet feeds do not include any food statements like the AAFCO, the NRC is actually a better choice of standard than the AAFCO (if we were to use one).
What we like about the NRC is that they step the game up with their standards. Their standards are generally based off of calorie intake or energy needs. This can be adjusted based on activity level or stages such as growth, pregnancy, and maintenance. Not only that but growth standards are further broken down for pregnancy and nursing as well as the age of puppies and kittens.
While we like that the NRC requirements are based on the bioavailability and digestibility of nutrients that are unprocessed making this completely relevant to a PMR diet, this is unrealistic for commercial food since they are heavily processed and thus altered. This is one reason why it is NOT used for most pet foods since most pet foods are processed dry or canned products.
Problems with the NRC
While the NRC requirements are based on science and established research, unfortunately, the most recent edition was released in 2006 (as of writing this article it is 2019) and before that the previous editions (which were are not a combined cat and dog edition like it is today, but rather separate texts) were from 1985/1986.
Conflict of Interest
The NRC involves a conflict of interest. Despite saying it is essential for the committees to remain unbiased with no financial or other interest compounding their research, research studies were performed in 2006 by individuals in various positions that could be looked upon otherwise. The Board Members of Agriculture and Natural Resources (the people responsible for performing these studies) include people such as Gail L. Czarnecki-Maulden “senior research nutritionist at Nestle Purina PetCare. She also served on the AAFCO’s Canine and Feline Nutrition Experts Subcommittees. Gary F. Hartnell – “a Senior Fellow of the Monsanto Company. His job is to conduct research on GMO crops in livestock for regulatory, industry and consumer acceptance. Robbin S. Johnson – Although retired from Cargill (the largest privately held corporation in the United States in terms of revenue) is President of the Cargill Foundation. Mercedes Vazquez-Anon – “Director of animal nutrition research at Novus International, a leading developer of animal health and nutrition programs for the food animal industry.”
In 2006 the Center for Science in the Public Interest published a very concerning report finding “serious breaches” to conflict of interest on the part of The National Academy of Sciences (NAS) which is a United States nonprofit, non-governmental organization. They reported that 1⁄5 scientists had financial ties to companies that have a direct stake in the outcome of a study. 50% of the panel contained scientists who had identifiable biases that were NOT offset but those with differing points of view. And while the NAS provided biographies of its nominees, they leave out important information that otherwise would be considered a conflict of interest.
While the 1985/1986 standards were based on human grade ingredients, the 2006 requirements were not and were based more on common commercially available ingredients such as GMOs,
grains, meat meals as well as dead, diseased, dying and downed animals.
How are the AAFCO and NRC related?
The AAFCO has used some of the NRC’s recommendations (but not all) and while they have accepted some of these more scientific methods, what the AAFCO has accepted, the standards haven’t been reviewed since the 1990s.
Originally nutrient standards from the AAFCO were based on NRC requirements until 1995 when standards changed supporting a reduction in protein (which by the way is the most expensive ingredient in pet food) from 22% to 18%. What do you know about that?
The AAFCO is not a government organization. Government officials may work for the organization but the organization itself is a non-government group.
The AAFCO does not regulate pet food.
The AAFCO does not test pet food.
The AAFCO does not certify pet food.
The AAFCO has no enforcement authority.
We don’t like how the AAFCO is my way or no way. Any food that wants to be “balanced and complete” HAS to comply with AAFCO nutritional requirements.
While some standards are better than none, this doesn’t mean those single set of standards is the be all end all, nor does this mean it ultimately is correct and absolutely does not mean a one size fits all to all types of food fed to our companion animals. The AAFCO may work for dry and canned pet foods but it just isn’t compatible with a raw species prey model raw diet.
Unfortunately, all in all, there is no set standard. In the USA the AAFCO and NRC standards are not the same and internationally the FEDIAF is not the same either. The experts disagree. There is no expressed mandate for commercial pet foods to meet NRC, the actual science-based standard. So who do we trust, who is right? It would stand to figure that nature is the ultimate science. Animals are thriving in nature without human intervention. Nature doesn’t make mistakes and if it does nature doesn’t survive. Other things evolve into a new position and take its place and life continues to adapt. There are millions of animals thriving on the natural diet they were designed to eat. Standards created by organizations that only fit one model of feeding and are established, run and funded by those with conflicting interest just make no sense in the grand scheme of things. PMR doesn’t fit into the AAFCO food standards, but it doesn’t mean the diet is unhealthy for your animal and their wellbeing.