The Food and Drug Administration, or FDA, is a name you may be familiar with if you know how our food is regulated. The FDA is in charge of ensuring that foods and medications are safe to consume. Having limited resources and being in charge of pet food regulation, they created a subsidiary group called the National Research Council, or NRC.

The Association of American Feed Control Officials, often known as AAFCO, became the exclusive authority on canine nutrition when the government decided to disband its committee in the middle of the 1980s. AAFCO used the NRC's material to create its guidelines.

The NRC is still utilized in the pet food industry despite not being connected to AAFCO. The National Research Council has created nutritional guidelines for dogs that kibble makers are supposed to adhere to in terms of 1000/kcal and metabolic weight. The NRC is a private organization that releases reports regarding a dog's nutritional needs based on the review of hundreds of research articles. 

The European Pet Food Industry Federation (FEDIAF), which oversees canine nutrition, has followed in the footsteps of AAFCO. In comparison to AAFCO, FEDIAF has openly acknowledged its affiliation with businesses that manufacture pet food.

In 1909, AAFCO was founded to address feedlot nutrition. Together with producers of feed ingredients and the United States Department of Agriculture, feed manufacturers founded the American Feed Manufacturers Association in 1909. The organization became the Association of Feed Control Officials or AAFCO.

AAFCO adopted the "complete and balanced" as part of its criteria in 1969. 

Pet food cannot be approved or banned by AAFCO. They don't have any laboratories or researchers. They aren't subject to legal enforcement. They simply set guidelines for labeling and feeding trial protocols. Manufacturers are not forced to adhere to these criteria but are supposed to if they advertise their product as "complete and balanced."

The trouble is that AAFCO has based its recommendations on the NRC guideline, which was initially published in 1953, and then modified in 1962, 1972, 1974, 1985, and  2006. However, because the NRC has not published new requirements since 2006, the data is old and does not reflect all of the current nutrition research

AAFCO has no regulatory authority. It is a private non-profit corporation that defines the ingredients used in animal feed and pet foods. It provides a forum for the collective of representatives from state agencies, federal agencies, industry, and anyone else with a common interest to express opinions, establish a uniform language that is then used within state laws or regulations, and deliberate on policies. AAFCO holds meetings semi-annually for discussions and training for its members and the industry.

There are three categories of active voting AAFCO members:

Officers that are authorized to execute state, federal, or local laws regulating animal feed production, labeling,  distribution, and sale.

Department heads or staff members of departments or laboratories charged with examining animal feed. 

Federal, state, or local agencies employ research workers investigating animal feed.

The Board of Directors (BOD) is composed of nine members with annual voting. The BOD establishes committees, task forces, working groups, and investigation teams of voting members assigned by the President. These groups are tasked with goals set by the BOD. The President of the BOD can request that advisors from the industry be on any of these groups. The advisors are called upon to field questions about animal nutrition, industry practices, or other relevant topics based on their expertise.

AAFCO was first established in 1909 for feedlot nutrition. In 1909, feed makers developed the American Feed Manufacturers Association with feedstuff manufacturers and the United States Department of Agriculture. During the meeting, the need to establish formal regulations became evident. This organization became known as the Association of Feed Control Officials, AAFCO. 

Establishing labeling requirements for dog and cat food. 

Creating nutrient profiles for dogs and cats based on the NRC recommendations.

Establishing feed trial protocols to be followed by pet food manufacturers.

Establish the requirements for using the phrase “complete and balanced”  on pet food labels.

The product must meet a standard vitamin and mineral requirement. 

This can be accomplished by using a blend of premeasured synthetic vitamins and minerals added to the food after all heat treatments have been completed.

The product contents must match closely with another approved product. 

What AAFCO cannot do is ban or approve pet foods. It simply sets and publishes the guidelines that pet food manufacturers are expected to follow. AAFCO does not have laboratories or researchers. Although the pet food manufacturers are not forced to adhere to these criteria, it is the expectation that they will if they intend to use the term “complete and balanced” on the food label.

Anyone can register for and attend an AAFCO midyear or annual meeting as an observer. Individuals interested in pet food products can apply to be selected as non-voting AAFCO committee advisors that the president of the BOD appoints.

AAFCO offers an online for personnel at pet food companies, researchers in the field of pet nutrition, AAFCO staff, and anyone interested or involved with defining animal feed and pet food ingredients. The three-module course covers the establishment of ingredient definition processes and how to establish communication with the U.S. Food and Drug Administration’s Center for Veterinary Medicine (CVM) and an AAFCO investigator.

Since it's not a law, not all companies that make commercial pet food follow AAFCO guidelines; for instance, a group of scientists in Chile looked at 33 foods for growing dogs. The researchers found that two commercially available dog food brands didn't have enough calcium, seven didn't have the right amount of calcium to phosphorus ratio, seven didn't have enough zinc, 12 didn't have enough iodine, and 13 didn't have enough potassium.

Only four of the 33 products had the right amount of protein, fats, minerals, and essential amino acids. That's an alarming number of dog foods, but unfortunately, not much can be done since dog foods aren't legally required to follow nutritional guidelines. That's precisely what they are, guidelines, not legal obligations. In fact, a commercial kibble can say in good faith that it meets AAFCO standards, even though it may or may not meet the minimum requirements. No set group of people checks each product to ensure the requirements have been met.

Another study tested 170 commercial dog foods, both dry and canned, and found that 94% of the “complete” canned foods and 62% of the “complete” dry foods did not meet AAFCO guidelines. 

If even the large pet food manufacturers aren’t following them, perhaps you should consider whether or not you should follow them and what you can do to create a higher-quality diet for your dog. 

NRC has a set of rules regarding fat guidelines, but that doesn't mean they cover everything. In 1985, Linoleic Acid was the only fatty acid considered essential by NRC. By 2006, they knew that good health depends on five essential fatty acids: linoleic acid (LA), alpha-linolenic acid (ALA), arachidonic acid (ARA), eicosapentaenoic acid (EPA), and docosahexaenoic acid (DHA).

However, conjugated linoleic acid (CLA) and gamma linoleic acid (GLA) are also important for good health. These haven't been suggested by the NRC or AAFCO yet, and the guidelines haven't been updated to reflect the latest research on the importance of these two fatty acids.

This could be because adding more essential fatty acids and updating guidelines costs more money. Even though the NRC recommends other fatty acids, AAFCO still only considers LA to be an essential fat. 

You may have noticed that many puppy foods list Omega-3s on the label since they contain fish oils. But fish oil quickly turns rancid, and the Omega-3s don't stay active for long. Even if DHA is listed on the label, that doesn't mean your puppy can process it efficiently or that it is bioavailable. They might even be gone before you even open the bag. Think about how long the food has been sitting on the shelf or how long it took to get there. Many of the nutrients could have been lost in that amount of time.

The American Association for the Advancement of Science's (AAAS) guidelines are based on "commonly used ingredients." These are specific feedlot ingredients of carbohydrate, fat, fiber, and protein sources chosen for their low cost. 

Vitamins and minerals almost always need to be added to these foods. They'd never pass AAFCO standards otherwise.

Some examples of these commonly used ingredients include:

Meat and bone meal				Animal byproduct meal

Due to the high temperatures, they were exposed to before and during the manufacturing process, these and other popular ingredients don't have as many nutrients as whole foods.

Heat damage makes fats poisonous. When components are heated, they react chemically, making compounds that are often poisonous and sometimes can cause cancer. AAFCO is aware of this problem, but they don't say anything about it.

Raw foods, on the other hand, do not contain these components. So, how can AAFCO guidelines be applied to raw dog food diets?

Whole foods in biologically appropriate raw diets have the proper nutrients and are well-balanced. They also match what your dog would naturally eat. Raw foods have elements like important phytonutrients that AAFCO completely ignores and elements your dog needs.

Pet food manufacturers are expected to obtain approval from AAFCO, whose standards are based on the NRC's Committee on Animal Nutrition.

To meet AAFCO guidelines, pet food should pass either a feeding trial or a standard requirement for vitamins and minerals. The cheapest way to meet this criterion is to add a mix of synthetic vitamins and minerals that have already been measured.

Another option is to add a lot of healthy foods, which would still provide enough nutrition after being processed. But ensuring the meals are enough would require expensive testing or feeding experiments. So, most companies add the standard premeasured mix of vitamins and minerals.

Unfortunately, this nutrient profile is missing several things, such as the percentage of carbohydrates. So, it's up to you, the consumer, to figure out how many carbs are in the commercial dog food you buy.

To determine carbohydrates, add the protein, ash, and fat content with the standard 10% for moisture content,  then subtract from 100. This will provide you with the approximate percentage of carbohydrates in the bag. 

If a prospective commercial dog food keeps six out of eight dogs alive for 26 weeks, one or more does not lose more than 15% of their body weight, and no blood values fall below the minimum, it passes the feeding test.

Remember that the chemical analysis is no longer relevant once the product has passed the feeding test.

Raw Diets Are More Bioavailable than Kibble: AAFCO Standards Don’t Apply

AAFCO guidelines were designed for kibble, so if raw food attempts to meet AAFCO guidelines, it could do more harm than good. 

AAFCO's current zinc requirement, for example, is based on zinc's low bioavailability in kibble: phytates in kibble bond with zinc, rendering zinc inaccessible to dogs. There are no phytates in meat-based raw diets, so this isn't an issue. 

Zinc also interacts with calcium. In calcium-deficient diets, less zinc is required, whereas calcium-rich diets require more zinc. What happens when zinc is readily bioavailable in a raw diet? Could the current levels lead to raw food makers putting too much zinc in their diets to meet AAFCO requirements? As with all micronutrients, an overdose could be dangerous to your dog.

Food ingredient ratios are critical, such as calcium and phosphorus, vitamin D and calcium, copper and zinc, vitamin E, and lipids. Phytates found in grains, fiber, and legumes bind to zinc, calcium, iron, and magnesium, reducing their availability to the body. 

The Association of American Feed Control Officials, often known as <a href="https://feedreal.com/glossary/aafco">AAFCO</a>, became the exclusive authority on canine nutrition when the government decided to disband its committee in the middle of the 1980s. AAFCO used the NRC's material to create its guidelines.

The NRC is still utilized in the pet food industry despite not being connected to AAFCO. The National Research Council has created nutritional guidelines for dogs that <a href="https://feedreal.com/glossary/kibble">kibble</a> makers are supposed to adhere to in terms of 1000/kcal and metabolic weight. The NRC is a private organization that releases reports regarding a dog's nutritional needs based on the review of hundreds of research articles. 

Since it's not a law, not all companies that make commercial pet food follow AAFCO guidelines; for instance, a group of scientists in Chile looked at 33 foods for growing dogs. The researchers found that two commercially available dog food brands didn't have enough <a href="https://feedreal.com/glossary/calcium">calcium</a>, seven didn't have the right amount of calcium to phosphorus ratio, seven didn't have enough <a href="https://feedreal.com/glossary/zinc">zinc</a>, 12 didn't have enough iodine, and 13 didn't have enough potassium.

Only four of the 33 products had the right amount of <a href="https://feedreal.com/glossary/catabolism">protein</a>, fats, minerals, and <a href="https://feedreal.com/glossary/essential-amino-acids">essential amino acids</a>. That's an alarming number of dog foods, but unfortunately, not much can be done since dog foods aren't legally required to follow nutritional guidelines. That's precisely what they are, guidelines, not legal obligations. In fact, a commercial kibble can say in good faith that it meets AAFCO standards, even though it may or may not meet the minimum requirements. No set group of people checks each product to ensure the requirements have been met.

NRC has a set of rules regarding fat guidelines, but that doesn't mean they cover everything. In 1985, <a href="https://feedreal.com/glossary/linoleic-acid">Linoleic Acid</a> was the only fatty acid considered essential by NRC. By 2006, they knew that good health depends on five essential <a href="https://feedreal.com/glossary/fatty-acids">fatty acids</a>: linoleic acid (LA), alpha-linolenic acid (ALA), arachidonic acid (ARA), eicosapentaenoic acid (<a href="https://feedreal.com/glossary/epa">EPA</a>), and docosahexaenoic acid (DHA).

You may have noticed that many puppy foods list Omega-3s on the label since they contain fish oils. But fish oil quickly turns rancid, and the Omega-3s don't stay active for long. Even if DHA is listed on the label, that doesn't mean your puppy can process it efficiently or that it is <a href="https://feedreal.com/glossary/bioavailable">bioavailable</a>. They might even be gone before you even open the bag. Think about how long the food has been sitting on the shelf or how long it took to get there. Many of the nutrients could have been lost in that amount of time.

Meat and <a href="https://feedreal.com/glossary/bone-meal">bone meal</a>				Animal byproduct meal

Fish meal						       <a href="https://feedreal.com/glossary/chicken-liver">Chicken liver</a> meal

Peanut hulls						<a href="https://feedreal.com/glossary/cellulase">Cellulose</a>

Unfortunately, this nutrient profile is missing several things, such as the percentage of <a href="https://feedreal.com/glossary/carbohydrates">carbohydrates</a>. So, it's up to you, the consumer, to figure out how many carbs are in the commercial dog food you buy.

AAFCO's current zinc requirement, for example, is based on zinc's low <a href="https://feedreal.com/glossary/bioavailable">bioavailability</a> in kibble: <a href="https://feedreal.com/glossary/phytates">phytates</a> in kibble bond with zinc, rendering zinc inaccessible to dogs. There are no phytates in meat-based raw diets, so this isn't an issue. 

Food ingredient ratios are critical, such as calcium and phosphorus, <a href="https://feedreal.com/glossary/vitamin-d">vitamin D</a> and calcium, copper and zinc, <a href="https://feedreal.com/glossary/vitamin-e">vitamin E</a>, and lipids. Phytates found in grains, fiber, and legumes bind to zinc, calcium, iron, and magnesium, reducing their availability to the body. 

The phosphorus levels in red meat greatly exceed those in carbohydrates. Using synthetic minerals to compensate for the difference can have severe consequences for your dog's health. 

The amount of protein listed on a label also doesn't show if the amino acids are balanced or if the protein is in a bioavailable state. High heat and processing can deplete amino acids like lysine, methionine, and cysteine.

AAFCO nutrient profiles were made because many of the essential nutrients in food react or break down when exposed to <a href="https://feedreal.com/glossary/extrusion">extrusion</a> and high heat. On the other hand, raw food isn't heated or processed the same way, so it can't be treated the same way.

How to Know if You’re Meeting Your Dog’s Requirements

If you offer your dog an AAFCO-guided "complete and balanced" dog food, you are essentially feeding the same food every day. There is no variety within the commercial diet. Imagine eating a cheeseburger from a fast-food restaurant every day. Obviously, you probably won't die right away if you eat this way, but your body won't be as healthy as it should be.

Even if you only eat one healthy food, your body won't get all the nutrients it needs to be healthy. This is where the importance of variety comes in. Your dog's body will have all the nutrients it needs if it eats various foods. So, you should switch the protein in your raw food bowl every three to four weeks.

When you feed your dog a raw diet that hasn't been changed in any way, you meet all of his nutritional needs without having to use excessive heat, mysterious ingredients, or unusual processing. This is how dogs have lived and grown throughout their history.

A biologically appropriate diet is the gold standard in nutrition. It lets the animal live up to its genetic potential in terms of health, longevity, physical activity, and reproduction. The more different an animal's food is from what it used to eat, the more likely it is to experience health problems.

We're not saying nutrient-level guidelines or criteria for commercially made dog food should be thrown out. We need rules to protect our dogs from harmful imbalances, deficiencies, or excesses of particular ingredients.  AAFCO guidelines might not work well for raw diets. A different set of guidelines needs to be made to account for the differences between kibble and raw food diets.

AAFCO and NRC: Why Were Standards Established?

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