Inside the AAFCO San Diego Meeting: Regulatory Battles, Labeling Delays, and Transparency Concerns in the Pet Food Industry

By Susan Thixton
Pet Food Consumer Advocate

Executive Summary & Main Facts

The Association of American Feed Control Officials (AAFCO)—a private organization that writes the model laws regulating animal feed and pet food at the state level—recently convened its biannual public meeting in San Diego, California. While AAFCO itself holds no direct enforcement power, its definitions and regulatory frameworks are routinely adopted verbatim by state legislatures and departments of agriculture across the United States.

The San Diego gathering laid bare deep-seated tensions among regulators, industry representatives, and consumer advocates. Key takeaways from the multi-day sessions include:

• Ingredient Definitions: A contentious debate regarding the definition of "Meat and Bone Meal" (MBM) revealed that regulators and industry insiders openly acknowledge that certain protein meals are derived from low-grade, decomposing, or diseased animal tissues.
• Label Modernization Delays: Long-promised pet food label updates, originally mandated by Congress in 2007, face yet another stalling tactic. Industry representatives cited technical challenges regarding dietary fiber testing as a rationale for pushing back the already delayed 2030 implementation deadline.
• Misleading Packaging & Legal Risks: Legal experts at the conference warned manufacturers that misleading "ingredient imagery"—such as pictures of grilled steak or roasted chicken on packaging that does not reflect actual contents—will increasingly face civil litigation.
• Senior Pet Nutrition Gaps: Despite admissions from federal regulators that current dietary practices for senior pets risk inducing nutrient deficiencies, neither AAFCO nor the U.S. Food and Drug Administration (FDA) proposed concrete regulatory changes to protect older animals.

Chronology of the AAFCO San Diego Sessions

To understand how regulatory policy is shaped in the pet food sector, it is necessary to examine the chronological progression of the committee meetings that unfolded in San Diego.

1. The Ingredient Definitions Committee: Debating the Ash Content of MBM

The meetings kicked off with the Ingredient Definitions Committee, where a seemingly minor technical discussion quickly devolved into a revealing debate over semantics versus safety. The committee scrutinized a specific sentence within the long-standing definition of Meat and Bone Meal (MBM):

“The total ash content for the product should contain a minimum of 28% ash.”

Committee members and industry stakeholders debated whether to strike this minimum ash requirement entirely. During the floor discussions, participants acknowledged that if the ash minimum were removed, the legal boundaries distinguishing "Meat Meal" from "Meat and Bone Meal" would effectively vanish. This deregulation would allow suppliers to market generic or lower-grade meat meal under the MBM classification simply by adjusting formulation parameters.

2. Current Issues and Outreach Committee: Fiber Testing and Stalling Tactics

Later in the schedule, the Current Issues and Outreach Committee addressed vague plans for "consumer education" slated for late 2026 and early 2027, though no concrete curriculum or messaging details were provided.

The conversation then abruptly pivoted to a topic that arguably belonged within the Pet Food Committee: AAFCO’s ongoing Pet Food Label Modernization (PFLM) initiative, specifically the mandatory disclosure of dietary fiber percentages. Industry representatives raised sudden objections, arguing that laboratory testing for dietary fiber is inconsistent, expensive, and largely unreliable when applied to high-moisture matrices like canned, fresh, or raw pet foods.

For consumer advocates, this eleventh-hour roadblock was transparently tactical. Raising insurmountable testing hurdles is a well-worn mechanism used by industry stakeholders to delay compliance with regulatory mandates that have been stalled for nearly two decades.

3. The Pet Food Committee: Export Hurdles, Legal Warnings, and Senior Diets

The Pet Food Committee session addressed widespread state-level hesitation to incorporate AAFCO’s updated labeling rules into local statutes. Compounding these domestic delays, international manufacturers expressed concern that the new U.S. label formats would not be recognized or accepted in foreign export markets.

A highlight of this session was a presentation by Todd Harrison of the prominent food and drug law firm Venable. Harrison delivered a blunt assessment of modern pet food marketing, warning manufacturers that aesthetic choices on packaging and digital platforms—such as displaying pristine cuts of meat that bear little resemblance to the processed rendering meals inside the bag—expose companies to immediate legal vulnerability.

Finally, the Pet Food Committee heard an FDA report concerning senior pet nutrition. The federal representative acknowledged that older pets consume fewer calories due to lower activity levels, and that veterinarians routinely advise owners to restrict food portions. Crucially, the FDA admitted this practice frequently results in secondary nutrient deficiencies. Yet, despite identifying this widespread welfare risk, neither the FDA nor AAFCO proposed mandatory nutritional profiles for senior pet foods, leaving older animals vulnerable to chronic undernourishment.

Supporting Data: Ingredients, Quality, and Regulatory History

To contextualize the debates witnessed in San Diego, one must examine the baseline definitions and historical findings surrounding rendered ingredients.

Meat Meal vs. Meat and Bone Meal

The distinction between rendered protein meals is critical to pet food safety and quality:

• Meat and Bone Meal (MBM): Historically categorized as one of the lowest-quality rendered ingredients permitted in animal feed. Its legal definition specifies that it is derived from “mammal tissues, including bones, exclusive of any added blood, hair, hoof, horn, hide trimmings, manure, stomach and rumen contents, except in such amounts as may occur unavoidably in good processing practices.” The phrase "exclusive of added" is vital: it dictates that while incidental amounts of hair, hooves, and manure naturally present on livestock may be rendered along with the carcass, processors are legally barred from intentionally supplementing the batch with these unnutritious byproducts.
• Meat Meal (e.g., Beef Meal): Marketed aggressively by major brands as a premium source of muscle-supporting protein. For instance, major commercial manufacturers routinely assure consumers that beef meal provides vital amino acids for canine energy and development.

However, discussions at AAFCO starkly confirmed that both categories of ingredients frequently share the exact same origin points: dead, dying, diseased, or non-ambulatory livestock.

The Pentobarbital Connection

The inclusion of compromised animal carcasses in rendered pet food ingredients is not a theoretical concern; it is documented by federal authorities. According to the FDA’s Center for Veterinary Medicine (CVM) compliance data:

"There appear to be associations between rendered or hydrolyzed ingredients and the presence of pentobarbital in dog food. The ingredients Meat and Bone Meal (MBM), Beef and Bone Meal (BBM), Animal Fat (AF), and Animal Digest (AD) are rendered or hydrolyzed from animal sources that could include euthanized animals."

Pentobarbital, a barbiturate commonly used to euthanize livestock, horses, and household pets, has repeatedly turned up in commercial dog and cat foods containing rendered meals. The willingness of AAFCO committees to blur the lines between high-grade meat meals and lowest-tier rendered meals directly impacts the safety and purity of the nation’s pet food supply.

The 20-Year Label Modernization Saga

The timeline of pet food label reform highlights chronic institutional inertia:

• 2007: Congress passes the Food and Drug Administration Amendments Act (FDAAA), which includes provisions titled Ensuring the Safety of Pet Food. This legislation explicitly commands the FDA to update pet food labeling standards within two years—establishing a hard deadline of September 2009.
• 2009–2023: Rather than executing the congressional mandate directly, the FDA effectively outsourced the task to AAFCO. AAFCO deliberated for over a decade before finally ratifying the updated model regulations in July 2023.
• 2030: Despite completing the framework in 2023, implementation was deferred until the year 2030, granting the pet food industry a staggering 23-year grace period from the original congressional order. Now, even that delayed timeline is facing coordinated obstruction.

Official Responses and Stakeholder Perspectives

The dichotomy between regulatory bodies, industry advocacy groups, and consumer representatives was sharply defined throughout the San Diego proceedings.

• Regulators and AAFCO Leadership: State and federal officials maintain that their primary duty is establishing uniform, scientifically defensible guidelines that accommodate manufacturing realities. However, critics argue that AAFCO operates as an insular corporate-state partnership where public health concerns are systematically subordinated to industry convenience.
• The Pet Food Industry: Industry representatives consistently push back against tighter definitions, mandatory disclosures, and rigorous analytical testing requirements. By highlighting technical hurdles—such as moisture interference in fiber testing or international export friction—trade associations successfully shield manufacturers from immediate accountability.
• Legal Counsel: External legal experts, such as Todd Harrison, offer a pragmatic warning: while regulatory bodies like AAFCO may move at a glacial pace and tolerate lax enforcement, the civil litigation bar is rapidly waking up to consumer deception. Class-action lawsuits targeting misleading ingredient imagery on packaging represent a growing financial threat to brands that rely on visual fabrication rather than factual formulation.
• Consumer Advocates: Organizations such as the Association for Truth in Pet Food continue to press for absolute transparency. Advocates argue that open discussions admitting the utilization of decomposing animal tissues—coupled with administrative foot-dragging on senior nutrition and labeling updates—demonstrate a systemic failure to protect domestic animals and the consumers who love them.

Implications for Pet Owners and the Future of Regulation

The outcomes of the AAFCO San Diego meeting carry profound implications for the multi-billion-dollar pet food industry and millions of pet owners:

1. Continued Erosion of Consumer Trust: When regulatory committees openly discuss lowering ingredient standards and entertaining endless delays for basic nutritional disclosures, consumer confidence plummets. Pet owners are left to navigate an opaque marketplace where premium marketing imagery often masks low-grade rendering practices.
2. Prolonged Regulatory Paralysis: The 2030 implementation window for Pet Food Label Modernization is looking increasingly fragile. If state legislatures balk at adoption and manufacturers secure further exemptions, consumers may wait well into the next decade—or longer—for labels that accurately reflect what is inside the bag or can.
3. Unaddressed Nutritional Vulnerabilities: The failure of both the FDA and AAFCO to establish mandatory senior pet nutritional profiles means older pets will continue to be fed generic adult formulations improperly rationed by weight. This regulatory vacuum exposes senior animals to avoidable micronutrient deficiencies.
4. The Rise of Private Enforcement: With regulatory agencies bogged down by bureaucratic inertia and industry lobbying, legal accountability is shifting toward consumer class-action lawsuits. Manufacturers engaging in deceptive "ingredient imagery" may find themselves facing severe financial penalties in civil courts long before AAFCO updates its model acts.

The next biannual meeting of the Association of American Feed Control Officials is scheduled to take place this coming January in Orlando, Florida, where these contentious debates are certain to resume.