Through October 1, 2024, FDA has partnered with AAFCO to provide scientific review of new proposed pet/animal food ingredients. Now, they both plan to approve new substances separately – each with their own separate system. Giving the appearance these two organizations are working against each other / competing with each other.
The FDA’s system is called the Animal Food Ingredient Consultation (AFIC) process. The FDA process will be similar to the previous AAFCO ingredient approval process, without any AAFCO involvement. Substance manufacturers will submit a proposed substance name, definition, and submit scientific evidence that the substance is safe. With animal feed ingredients, the manufacturer will also need to submit evidence that the ingredient will be safe for human consumption. Based on the FDA’s review, the substance will be approved or rejected. Pending and approved substances will be published on the FDA website, and will be open for public review and comment.
AAFCO’s proposed system for pet food/animal feed ingredient approval would be similar to their previous process, excluding any FDA involvement. The scientific evaluation of the ingredients will be conducted by Kansas State University, specifically KSU will manage the scientific evaluation process asking various experts (at their discretion) to perform the proposed ingredient analysis. Kansas State “will manage the process of soliciting subject matter experts”. The same paperwork is required by the ingredient manufacturer as required by the FDA; ingredient name, suggested definition, and scientific evidence on safety. BUT…AAFCO will charge a $50,000.00 fee for substance approvals (whether approved or denied).
So many concerns with no answers.
Neither FDA nor AAFCO has clarified whether the two separate ingredient approval processes will work together. Will States accept FDA ingredients into state law or will some states reject FDA ingredients and only allow AAFCO ingredients (a show of loyalty to their friends at AAFCO)? Will the FDA accept AAFCO approved ingredients? If the FDA does not accept AAFCO approved ingredients, the agency appears to take enforcement action against pet foods/animal feeds using AAFCO ingredients (non-FDA approved ingredients). “If the FDA identifies a concern regarding an unapproved feed additive, we intend to take appropriate action to ensure the safety of the feed supply, including notifying the public or taking enforcement action if necessary.”
Will the substance approval process overseen by Kansas State be subject to one that involves industry influence? Kansas State University has a long history of working with the pet food industry. In 2018 accepted by the Kansas State Veterinary School “the largest corporate gift in the college’s history” from Hill’s Pet Food. Will donations to the University influence substance approval?
Can a manufacturer reject an ingredient through the FDA process, then turn around and submit the same ingredient through the AAFCO process and get approval?
And then there is the issue of the financial interest of those who approve the substances (through AAFCO). AAFCO’s proposal states that they will approve approximately 15 substances a year, resulting in $750,000.00 in revenue. AAFCO does not explain how those funds will be disbursed; how much money goes to Kansas State, how much money is paid to each of the scientific review staff, and how much is paid to AAFCO. Financial incentives certainly raise concerns that substances will be approved without due diligence.
It’s hard to imagine that pet food/feed regulations could get any worse – but until both sides (FDA and AAFCO) start giving us more information, we’re left to believe that things are may worsen. The regulatory authorities involved with AAFCO and the FDA regulatory authorities working against each other will do nothing but cause future conflicts that we and our pets will pay for.
Wishing you and your pet(s) the best,
Susan Thixton
Pet Food Safety Advocate
Buyer Beware of Author, Co-Author Dinner PAWsible
TruthaboutPetFood.com
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