The Front of the Bag
One word in a product name decides whether a bag must hold 95% chicken, 3% chicken, or none at all. There is a rulebook behind the front of the package that almost no shopper has been told about.
I came to nutrition before I came to training. That was 2018, and the first thing I really understood about a bag of dog food is that the front of it does not tell the whole story. It is designed for somebody who picks it up, likes what they see, and never turns it over, which is exactly what I advise against, again and again.
I read labels for a living now, my own dogs’ and my clients’. Standing in the aisle I skip past anything that is not legally required to be printed, because the rest of it is advertising, right down to the color of the bag. That probably sounds cynical, and it did to me too until I learned how much of a label genuinely is regulated, and how carefully the regulated parts have been worded by people who had to agree on them. This is that habit, written out, so you can borrow it.
I am not a veterinarian and none of this is medical advice. What I can do is show you which parts of a label somebody is accountable for, so you know where to look and what you are safe to ignore.
Your chicken flavored dog food may not contain any chicken at all.
| On the front | Chicken |
|---|---|
| "Chicken Dog Food" | 95% |
| "Dog Food with Chicken" | 3% |
| "Chicken Flavor Dog Food" | none |
None of this is illegal. It is, however, shady.
Every one of those names is permitted, and the rules that permit them are published where anyone can read them. So this was a decision. Somebody sat in a room and worked out how little chicken they could put in a bag while still printing the word on the front, and they will keep making that decision for as long as it keeps working on us.
Do not be fooled by a clever name
Four rules decide what a food may be called, and each one commits the manufacturer to a different minimum. The difference between the top rule and the bottom one is 95% of the recipe.
The name of a pet food is a regulated claim. Not the photograph, not the adjectives, the name. Four rules govern which words a manufacturer may put in it and what those words then oblige them to include, and they sit in the model regulations published by the Association of American Feed Control Officials. AAFCOThe Association of American Feed Control Officials, the body that writes the model pet food regulations most US states adopt into their own law.Read more → writes the language and enforces none of it. A majority of states have adopted its Model Bill into their own law, and the states do the enforcing.
| The name | Minimum |
|---|---|
| "Chicken Dog Food"the ingredient stands alone | 95% |
| "Chicken Dinner", "Recipe", "Entree", "Formula", "Platter"a descriptor follows it | 25% |
| "Dog Food with Chicken"the word "with" appears | 3% |
| "Chicken Flavor Dog Food"the word "flavor" appears | no minimum |
Those percentages are measured with the water taken out, which sounds like bookkeeping and is not. Wet food is mostly water, so a rule written only on a dry-weight basis would let a tin of gravy call itself chicken. The regulations close that by setting a second figure for the product as it sits in the container. "Chicken Dog Food" has to be 70% chicken including its water. "Chicken Dinner" has to be 10%. In dry food the two numbers stay close together. In anything canned or pouched, the second one is doing the real work.
Two words buy the most trust for the least commitment. "With" drops a requirement from 95% to 3%, so "Dog Food with Salmon" has cleared a very low bar and still prints salmon in the same confident type as everything else on the package. "Flavor" removes the percentage requirement completely, leaving only the condition that a named ingredient is what provides the taste. Both words are chosen by people who know you read them as a promise about quantity.
Can you define: premium?
Neither can AAFCO. Their words: "a totally unregulated term in feed law." PremiumA marketing term on pet food packaging with no definition in feed law.Read more → pet food has no requirements that differ from any other pet food.
That is not a technicality. Premium is one of the most expensive words in the store, it appears on foods at every price point, and a manufacturer needs no more justification to print it than a designer needs to pick a color. Once you step outside the product name, the language on a package divides into two groups that look identical from a shopping cart: words somebody had to meet a written standard to use, and words that are there because they sell food.
| Word | Backed by | Doesn’t mean |
|---|---|---|
| "Natural" | AAFCOA definition in feed law. The FDA has never written one. | SaferAAFCO says the definition is not an expression of safety. |
| "Organic" | USDANational Organic Program. 95% organic, and the seal. | HealthierThe USDA says organic is not necessarily safer or more nutritious. |
| "Human grade" | AAFCOA defined feed term, and it applies to the whole product. | A better recipeThe standard covers handling and licensure, not the formula. |
| "Complete and balanced" | AAFCOThe nutritional adequacy statement. Required. | A dog ever ate itDifferent clause, same sentence. Section 03. |
| Calories per kg | RequiredOn every pet food. Before 2014, only on lean and lite ones. | What your dog needsA number to compare with, and nothing about your animal. |
| "By-product" | AAFCOAn ingredient definition: a secondary product of processing. | Low qualityAAFCO: it does not mean unsafe or lacking nutrition. |
| "Premium" | NobodyAAFCO: "a totally unregulated term in feed law." | AnythingAAFCO: no special requirements that differ from any other pet food. |
| "Holistic" | NobodyNo definition, no standard, nothing to apply for. | AnythingWSAVA: "of little practical value for nutritional assessment." |
The two regulated terms are narrower than they sound, and knowing exactly how narrow is the useful part. AAFCO defines natural by the absence of chemically synthetic processing, and says outright that the definition is not an expression of safety. It also permits synthetic vitamins, minerals and trace nutrients, which nearly every complete food contains, provided the label then reads "NaturalOn a pet food label, an AAFCO-defined term for ingredients from plant, animal or mined sources that have not been through a chemically synthetic process.Read more → with added vitamins, minerals and trace nutrients." That qualifier is how a bag says natural in large type and lists a column of chemical names on the back.
Organic is the stricter of the two, because it belongs to the USDA and not to the pet food industry. A product carrying the seal has met the same National Organic Program standards a human food would: at least 95% organic ingredients, verified. The USDA is just as plain about the limit of that. Organic foods are not necessarily safer, healthier or more nutritious. The seal certifies how something was produced, which is worth paying for or not depending on what you wanted it to prove.
Labels "may also include marketing images and phrases that are designed to promote product sales rather than relay nutritional information," and unregulated terms such as "holistic" or "premium" are "of little practical value for nutritional assessment."
WSAVA Global Nutrition Committee, Guidelines on Selecting Pet Foods, 2021AAFCO’s guidance on marketing claims sets a general standard and no list of approved words. Claims have to be supported by evidence and have to be truthful and not misleading. Ingredients may not be overemphasized to the exclusion of others, and the example AAFCO gives is a picture of apples on a package containing no apples. Anything claiming to treat a disease is a drug claim, and drug claims are not permitted on a food.
One AAFCO line deserves its own paragraph, because a great many packages imply the opposite. "AAFCO does not regulate, test, approve or certify pet food." It writes model language that states may adopt. There is no such thing as an AAFCO-approved food, and no process a company could go through to get one.
So read an unregulated word the way you read the photograph of the dog beside it. Somebody chose it, they chose it to move your hand toward that bag, and nobody made them earn it first.
Was this food ever fed to a dog?
Almost every food on a mainstream shelf says complete and balanced, so that phrase sorts nothing. Two things sitting in the same sentence do.
The nutritional adequacy statementThe required sentence on a pet food label saying whether the food is complete and balanced, which life stage it is for, and how that was established.Read more → is required, and it is usually set in the smallest type the printer could manage. Checking that it exists is close to pointless, because nearly every food sold as a dog’s main meal carries one. The rest of the sentence is where the information lives, and it is doing two jobs.
The first turns on two phrasings that look interchangeable. "Formulated to meet" means the recipe was checked against a nutrient profile on paper and found to add up. "Animal feeding tests using AAFCO procedures" means the food was fed to dogs under a defined protocol and the dogs were watched. Both are legal, both are common, and both sit on foods people feed happily for years. Only one of them ever involved a dog.
The second is the life stage, where the most generous-sounding phrase turns out to be a specification. Growth, maintenance, or all life stagesThe stage of life a pet food is formulated for: growth, adult maintenance, or all life stages.Read more →. A food built for all life stages has to meet the requirements of growth and reproduction, and those sit above what an adult dog asleep on your sofa needs.
There is one aisle where the mere presence of that statement still matters, and it is the fastest-growing one in the store. Toppers, mixers, freeze-dried bowls and raw grinds are often labeled for intermittent or supplemental feeding, and plenty of people serve them as meals. WSAVA’s guidance is that such foods make up no more than about a tenth of the diet, or be fed under veterinary supervision. The sentence saying so is printed on the package.
This is the last thing I check on a bag, and the reason I read the whole line instead of only the age bracket sitting inside it. All of it is in one paragraph, in the same tiny type.
How much are you actually feeding?
The feeding guide is a population average, and the law asks less of it than most people picture. The calorie statement is the figure that lets you compare two foods honestly.
Feeding directions are required on any food sold as complete and balanced, and the bar is lower than most people picture. AAFCO asks that the directions specify at least how much food to give per weight of animal per unit of time, for the life stage. That describes an average dog of a given weight. Your own dog’s body condition over the next month is what corrects it.
The calorie statement does more work than it looks like it does, and American labels are ahead of the rest of the world here. Calorie content is only required in the United States, and WSAVA tells owners elsewhere to phone the manufacturer for it. A percentage on a panel describes the food. A calorie figure describes what the dog receives. Lisa Freeman, a board-certified veterinary nutritionist at Tufts, makes the same point about the guaranteed analysisThe panel on a pet food label giving minimum percentages for protein and fat and maximum percentages for fiber and moisture.Read more →: comparing two foods per 1,000 calories tells you something real, and comparing them by percentage tells you much less than people assume.
WSAVA comes at it from the other side. Obesity in pets is rising across much of the world, and accurate calorie content is one of the things that prevents unintended overfeeding. The number that lets you feed a dog deliberately is printed on the bag. Most of us use the scoop.
I firmly believe in feeding based on calories and activity level. The bag is a guide. It is not a rule.
Kourtenay DolmosWho made it, and what do they know?
The manufacturer predicts more about a food than any single line on the label. The questions worth asking them are published, and they are answerable by phoning the number on the bag.
When I pick up a bag, the brand is the first thing I look at, and for years I assumed that was a bias I ought to correct. It turns out to be where the veterinary nutrition establishment starts too. WSAVA’s guidance on choosing a food opens with the company, on the reasoning that formulation, quality control and testing are what determine whether the food in the bag matches the food on the label. Their questions are these.
- 01Do they employ a qualified nutritionist?
Meaning a PhD in animal nutrition, or board certification by the American or European colleges. A nutritionist on staff carries more weight than a consultant, who may have limited influence over what is finally made.
- 02Who formulates the food, and what are their qualifications?
Recipe development requires knowledge of nutrition, raw materials and processing, and WSAVA notes plainly that it is not taught in veterinary school.
- 03What quality control runs on the ingredients and on the finished product?
Ingredient validation, nutrient analysis of the finished diet, toxicology, bacteriology, and shelf-life screening, before, during and after manufacture.
- 04Have they published research in peer-reviewed journals?
No manufacturer is required to run or fund nutritional research in order to sell food. Doing it anyway indicates something.
Two more sit in their guidance on reading the label, and both are answerable while you are still holding the bag. Does the company give you a phone number or email address, so somebody can be asked about a nutrient the label does not list? And who actually makes the food: "Made by" is the manufacturer, while "Made for" or "Distributed by" means a third party produced it, which you want to know before deciding whose quality control you are trusting.
WSAVA’s closing line is blunter than most veterinary guidance gets: if a manufacturer cannot or will not give you this information, be cautious about feeding their food.
So ask. And then be clear-eyed about what the answers can do for you, because this is where most advice about choosing a food stops.
The same people make Pro Plan and Dog Chow
Nestle lists Pro Plan and Dog Chow on the same page. Mars lists Royal Canin beside Pedigree. Every question in section 05 returns the same answer for both bags, because the same company is answering.
Those questions set a floor. They are asked about a company and answered by a company, and the largest manufacturers make food at every price point in the store, so the answers cannot tell two bags apart when the same corporation stands behind both of them.
Nestle’s own brand page lists Purina Pro Plan, Pro Plan Veterinary Diets, Purina ONE and Dog Chow together. Mars lists Pedigree, Iams, Eukanuba, Nutro and Cesar alongside Royal Canin, which Mars describes as its brand of therapeutic veterinary diets. Whatever answers those questions produce for Mars, they are the same answers for a bag of Royal Canin and a bag of Pedigree. It is Mars answering both times.
Ownership also moves under your feet while you are learning it. J.M. Smucker sold Kibbles ’n Bits, Gravy Train, 9Lives, Nature’s Recipe and Rachael Ray Nutrish to Post Holdings on 28 April 2023, keeping only Milk-Bone and Meow Mix. A rule of thumb about who owns what, learned three years ago, is already out of date.
If their standards were really that high the whole way through, Dog Chow would not exist. A company that knows exactly how to build a good food, and sells a cheaper one anyway, is telling you what it thinks you will settle for. Listen to that.
Kourtenay DolmosAll of which is why the ingredient panel still has work to do, and why the next piece is about nothing else. Asking about the company gets you as far as knowing somebody competent was in the building. Everything after that is on the back of the bag.
They are redesigning the bag right now
AAFCO approved a full redesign in July 2023 with a six-year runway, so two legally different versions of the same panel are sitting on the shelf together and neither is doing anything wrong.
Everything above describes a label that is currently being replaced. AAFCO’s membership approved new model regulations on 31 July 2023, and they appear in the 2024 Official Publication. The guaranteed analysis panel gives way to a Nutrition Facts box built to resemble human food labeling, showing calories from protein, fat, carbohydrate and total dietary fiber. The intended use statement moves. Ingredient names gain common names in parentheses, so the long chemical names for vitamins arrive with a translation. Handling and storage instructions get a standard set of icons.
The changeover is slow on purpose. AAFCO recommends that state feed programs use enforcement discretion for six years while manufacturers work through fiber testing methods, new equipment, label development and packaging supply, and it revisits that recommendation every year. What it means for you is that a bag redesigned last month and a bag designed in 2019 can sit beside each other in the same store, formatted completely differently, and both are perfectly legal.
One further change sits behind all of it and got almost no consumer coverage. The memorandum of understanding between AAFCO and the FDA, which for seventeen years set out who was responsible for defining what may legally go into animal feed, expired on 1 October 2024 and was not renewed.
Read these eight things, ignore the rest
The method is a single rule: read the panels the law requires, and let the rest of the package be advertising. There are eight required panels and they are all short.
This is the part worth committing to memory, because it is finite. AAFCO’s labeling requirements name eight things that have to appear on a pet food package. Eight. That is the whole list.
| Required | What it tells you |
|---|---|
| Product and brand name | The four naming rules, and a minimum percentage |
| Species | Whether it is dog food at all |
| Net quantity | How much you are buying |
| Guaranteed analysis | Minimums for protein and fat, maximums for fiber and moisture |
| Ingredient statement | Everything in the food, in order |
| Nutritional adequacy statement | Complete or not, which life stage, and how that was established |
| Feeding directions | Amount per body weight per day, on complete and balanced foods |
| Guarantor name and address | Who is accountable for all of the above |
Everything outside those eight was chosen by somebody whose job is to sell the food. The photograph, the adjectives, the word "holistic", the color of the bag. Here is the order I read the eight in. The two that get their own piece are the two that need the most explaining.
- 01The brand
Who made it, and whether they can answer the questions above.
- 02The ingredient list
Covered properly in the next piece, along with the tricks that make it read better than it is.
- 03The guaranteed analysis
Also next piece, with the arithmetic that makes two foods comparable.
- 04The feeding guide
A starting point you adjust from, not an instruction you obey.
- 05The nutritional adequacy statement
Complete or not, which life stage, and whether a dog was ever fed it.
Sources
- AAFCO, Reading Labels The four product naming rules with both water bases, the 3% floor under the 25% rule, the feeding-directions requirement, the eight required label elements, and the wording of the nutritional adequacy statement.
- WSAVA Global Nutrition Committee, Guidelines on Selecting Pet Foods Updated 10 March 2021. The manufacturer questions, the marketing-language quote, life stages, calorie content and obesity.
- AAFCO, Understanding Pet Food "AAFCO does not regulate, test, approve or certify pet food."
- AAFCO, Natural The full definition, the synthetic vitamin qualifier, the absence of an FDA definition, and the note that natural does not mean safer.
- AAFCO, Organic The USDA National Organic Program standard, the 95% threshold, and the USDA’s own statement that organic does not mean healthier.
- AAFCO, Frequently asked questions Premium as "a totally unregulated term in feed law", human grade as a term with AAFCO guidelines, and the history of the calorie statement.
- AAFCO, Standard for "Human Grade" Pet Food The standard behind the USDA AMS Process Verified Program. The whole-product rule, the 21 CFR 117 handling requirement, dual facility registration, the annual audit, and the type-size limit that binds websites too.
- AAFCO, Human Grade Pet & Specialty Pet Food Claim FAQ 6 September 2024. USDA AMS as the only authorized certifier, the one-year term, the PVP Official Listing, and AAFCO’s warning about businesses claiming to certify the term.
- AAFCO, Byproducts The definition, and AAFCO’s own line that byproducts are not unsafe and do not lack nutrition.
- AAFCO, Marketing and "romance" claims Claims must be supported and not misleading, there is no AAFCO approval process, and disease claims are drug claims.
- AAFCO, Membership approves new Model Pet Food and Specialty Pet Food Regulations Approval on 31 July 2023, the 2024 Official Publication, the Nutrition Facts box, and the six-year enforcement discretion period.
- AAFCO, Pet Food Label Modernization The program and its transition.
- AAFCO, AAFCO and FDA to end longstanding MOU Expiry on 1 October 2024, after seventeen years.
- Freeman LM, What is guaranteed about the Guaranteed Analysis? Tufts Petfoodology, 2020. Comparing foods per 1,000 calories rather than by percentage.
- Nestle, Petcare brands Purina Pro Plan, Pro Plan Veterinary Diets, Purina ONE and Dog Chow listed together by their parent company.
- Mars, Petcare Royal Canin, Pedigree, Iams, Eukanuba, Nutro and Cesar listed together by their parent company.
- The J.M. Smucker Co., Completes the divestiture of several pet food brands to Post Holdings 28 April 2023. Which brands changed hands and which were retained.
