What you need to know about the AAFCO Pet Food Label Modernization project

The The Association of American Feed Control Officials’ (AAFCO) new pet food label modernization regulations, already effective in 2024 with full implementation required by 2030, change how manufacturers present species, age, nutrient content, and nutritional adequacy on packaging. For clinicians, these changes mean owners will arrive with different-looking labels that can be misleading if interpreted without context. Purpose statements may mask all-life-stage formulations; guaranteed analyses will include per-cup measures reported on an as-fed basis; and fiber will be listed as total dietary fiber rather than crude fiber. Veterinary teams should prepare to interpret these new labels for clients. Vicky Ograin, MBA, RVT, VTS (Nutrition), explains what you need to know. Below is a transcript for the video above, lightly edited for clarity:

Vicky Ograin, MBA, RVT, VTS (Nutrition): Yeah, that goes to the lecture I gave at the conference where I talked about the pet food label modernization, the new regulations that are coming. They are already in effect; they went into effect in 2024 and we have until 2030 to get them fully implemented. That means we will see new packaging, and I think it is something we absolutely need to be aware of because it will confuse our pet parents.

Honestly, I think the intent was to make labels easier and maybe more transparent, and maybe they are more transparent. But there are nuances to the labels that I think will be confusing. I have had to go through multiple trainings to really wrap my head around it. The first point is if you see the new label, they are going to have what is called a purpose statement. It used to be on the front of the bag; it would tell you the species, like “dog food.” Now it will be the purpose statement, which is good, but you have to understand the regulations to know what it truly means.

The purpose statement is going to tell you the species and, in theory, the age. So it might say “complete puppy food.” That is very obvious: a complete and balanced food for puppies. But if it says “complete dog food,” that actually means all life stage. An all-life-stage food has to be most appropriate for the highest nutrient requirements in a dog or cat's life, which are gestation, lactation, and puppy or kitten growth. Adults might be okay, but for gestation and lactation it has to be higher in calories and fat. So if you have an overweight dog eating an all-life-stage food, that may not be appropriate. Giving them less of that food will not be a simple fix because you are then cutting both calories and nutrients that are important. You might be cutting protein, which is very important.

Another group I think about, more importantly, is seniors. If seniors have declining kidney function, an all-life-stage food could have higher levels of phosphorus, calcium, sodium, and extra fat that they may not need. For some seniors it might be okay, but for others not. So when I look at the purpose statement it tells me species and age, and then we need to decide as veterinary professionals what is appropriate for the pet in front of us. An all-life-stage food might be okay, but it might not be for that particular pet. An indoor, free-fed, inactive cat, for example, would not be appropriate on an all-life-stage food because they would become gargantuan from the extra calories. So I think the purpose statement will be helpful, but it will not be easy for owners to understand.

We still have the nutritional adequacy statement, the AAFCO statement, and that is not going away; it needs to complement the purpose statement. The AAFCO statement will now be part of what they are calling a pet nutrition facts box. That is one similarity to human food labels: you will see a nutrition facts box. But what is inside will not be the same as human nutrition facts because pets eat differently. Human labels are per serving and often reference a 2,000-calorie diet. Pet food labels have to reflect sole-source nutrition. So if you feed this pet one cup of food, this is how much protein the animal will get as a sole source. That difference will make comparing the two label styles confusing.

Previously the guaranteed analysis showed minimums and maximums — crude protein, crude fat, moisture, and crude fiber—and now they are adding carbohydrates. On the new label it will be easy to see the difference: the guaranteed analysis will still show percentages for the whole bag, but there will also be another column showing common household measures, such as per can, per cup, or per treat. For example, it might say that one cup of this kibble has 20 g of protein. Now you know that one cup contains 20 g of protein instead of interpreting the percentage of the whole bag.

The confusing part is that these numbers are on an as-fed basis. The entire product—all nutrients, meaning water, carbohydrates, fat, protein, vitamins, and minerals—are reported as fed. Dry food is much lower in water than canned food. A canned food could be 78% to 80% water, while a dry food is closer to 8% to 10% water. So a canned food’s protein per cup will look lower than a dry food per cup because of the water weight. If you remove the water (convert to dry-matter basis), the comparisons change drastically. We need to recognize that we cannot directly compare a dry food to a canned food using these per-cup as-fed numbers.

Another change is that fiber will be calculated differently. Previously labels showed crude fiber; under the new rules fiber will be reported as dietary fiber, or total dietary fiber. That means if the same company puts the same formula on a new label without formulation changes, the fiber number may look higher simply because the calculation changed. I have seen situations where owners call the manufacturer, convinced the formula changed because the fiber is higher, when in fact it is only a difference in how fiber is measured.

Finally, that pet nutrition facts box is where you will find the nutritional adequacy statement, and that needs to complement the purpose statement. If the purpose statement says “complete dog food,” the nutritional adequacy statement should say “all life stage.” Those are the key points I think we can look at and use to help pet parents decipher the new regulations compared to what they are used to seeing today.