Inside the AAFCO San Diego Meeting: Regulatory Hurdles, Labeling Delays, and Continuing Controversies in the Pet Food Industry

By Susan Thixton
Pet Food Consumer Advocate

Introduction and Main Facts

The Association of American Feed Control Officials (AAFCO)—a private organization that shapes the laws regulating pet food and animal feed at the state level—recently convened its biannual in-person meeting in San Diego, California. While AAFCO itself does not possess direct regulatory enforcement powers, its membership of state and federal authorities (including the U.S. Food and Drug Administration) crafts the model bills and guidelines that govern the pet food industry across the United States.

The San Diego gathering laid bare ongoing friction between consumer advocates, regulatory agencies, and pet food manufacturers. Key developments from the sessions include:

• Rendered Ingredient Definitions: A contentious debate over the minimum ash content in "Meat and Bone Meal" exposed how regulatory definitions treat low-quality rendered animal components.
• Pet Food Label Modernization (PFLM) Delays: Acknowledgment that mandated dietary fiber disclosures face significant testing hurdles, threatening to push back implementation timelines originally promised by Congress nearly two decades ago.
• Misleading Packaging and Legal Exposure: Industry experts warned manufacturers that deceptive packaging imagery—such as photos of grilled steaks and roasted chicken—presents severe legal liabilities under current truth-in-advertising laws.
• Senior Pet Nutrition Deficits: FDA representatives acknowledged that veterinarians frequently instruct owners to underfeed senior pets due to lower activity levels, yet neither AAFCO nor the FDA has proposed binding nutritional profiles to prevent potential micronutrient deficiencies.

Chronology of the San Diego Sessions

The public gathering was structured around specialized committees addressing various segments of animal feed and pet food oversight. Below is the chronological breakdown of key committee proceedings from the San Diego conference.

1. Ingredient Definitions Committee

The conference began with high-stakes discussions within the Ingredient Definitions Committee. A particularly revealing debate centered on a single sentence within the regulatory definition of "Meat and Bone Meal" (MBM): “The total ash content for the product should contain a minimum of 28% ash.”

Committee participants debated whether to strike this minimum ash requirement entirely. Proponents of removing the sentence noted that, without the ash minimum, the legal distinction between "Meat Meal" and "Meat and Bone Meal" virtually disappears. Industry insiders openly discussed that removing the threshold would allow suppliers to market standard meat meal as meat and bone meal interchangeably.

2. Current Issues and Outreach Committee

Later in the schedule, the Current Issues and Outreach Committee touched briefly upon plans for "consumer education" scheduled for the fall and early 2027, though no concrete details regarding the curriculum or outreach strategy were disclosed.

The session quickly pivoted to a lengthy discussion regarding AAFCO’s Pet Food Label Modernization (PFLM) effort—specifically the new requirement to disclose dietary fiber percentages on packaging. Industry representatives raised alarms, stating that laboratory testing to accurately confirm dietary fiber is inconsistent, expensive, and fundamentally fails when applied to high-moisture foods such as canned, raw, and fresh diets. An industry representative subsequently petitioned the committee to delay the fiber disclosure mandate, revealing a coordinated effort to stall long-overdue labeling updates.

3. Pet Food Committee

The Pet Food Committee session expanded on the mounting obstacles facing label modernization. Delegates reported that multiple states are hesitant to codify the new AAFCO labeling rules into state statute, while manufacturers highlighted that updated domestic labels may fail to meet compliance standards in foreign export markets.

Additionally, Todd Harrison of the prominent food and drug law firm Venable delivered a presentation detailing the legal risks of "ingredient imagery." He cautioned manufacturers that utilizing appetizing photos of fresh ingredients—like roasted chicken or garden vegetables—when the product relies on processed meals or digests creates substantial exposure to false advertising litigation.

Finally, the Pet Food Committee heard an FDA report regarding senior pet diets. While acknowledging systemic feeding challenges in older animals, the agencies offered no regulatory remedies.

Supporting Data and Technical Context

To fully understand the implications of AAFCO’s San Diego discussions, it is necessary to examine the technical definitions, historical FDA findings, and legislative backdrops governing these regulatory debates.

The Rendered Ingredient Divide: Meat Meal vs. Meat and Bone Meal

The distinction between protein meals heavily influences pet food safety and nutritional quality.

• Meat and Bone Meal (MBM): Historically categorized as one of the lowest-quality rendered ingredients, MBM’s legal definition specifies it as the “rendered product 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 critical phrase—“exclusive of any added”—means that while manufacturers cannot intentionally supplement hair, hooves, or manure, whatever natural amounts were attached to the source animals at slaughter remain legally permissible within the batch.
• Contamination Risks: Decades of federal surveillance highlight the inherent risks of rendered animal meals. According to FDA findings housed in its Center for Veterinary Medicine (CVM) electronic reading room, pentobarbital—a barbiturate commonly used for euthanizing companion and farm animals—has repeatedly been detected in dog foods containing rendered ingredients. The FDA explicitly notes that ingredients like Meat and Bone Meal (MBM), Beef and Bone Meal (BBM), Animal Fat (AF), and Animal Digest (AD) are sourced from animal tissues that “could include euthanized animals.”
• Higher-Tier Meals: Conversely, isolated meat meals (such as Beef Meal) are marketed by major brands like Blue Buffalo as premium protein sources designed to support muscle development and daily energy, setting up a sharp contrast with lower-grade multi-species renders.

The 20-Year Delay on Pet Food Label Modernization

The regulatory paralysis surrounding pet food labels dates back to federal legislation passed nearly two decades ago:

• 2007 Congressional Mandate: Through the Ensuring the Safety of Pet Food act within the Food and Drug Administration Amendments Act (FDAAA) of 2007, Congress explicitly ordered the FDA to update pet food labeling standards within two years, setting a hard deadline of September 2009.
• The Hand-Off to AAFCO: Rather than enforcing direct federal rulemaking, the FDA deferred the task to AAFCO.
• The 2030 Implementation Horizon: AAFCO spent more than a decade deliberating before finally finalizing the label modernization rules in July 2023. However, compliance has been pushed out to an astonishing 2030 implementation date, giving the industry nearly a quarter-century of breathing room since Congress first demanded reform.

Official Responses and Stakeholder Perspectives

Regulatory Bodies (AAFCO and FDA)

Throughout the sessions, both AAFCO and FDA representatives maintained a posture of accommodation toward industry friction points.

• On ingredient standards, regulatory actors demonstrated a primary focus on linguistic compliance—polishing the exact wording of definitions—rather than addressing the underlying quality or safety of raw materials sourced from diseased or dying animals.
• Regarding senior pet nutrition, an FDA representative acknowledged a dangerous systemic flaw: veterinarians regularly instruct owners to restrict the volume of commercial pet food fed to aging, sedentary pets to prevent obesity. Because standard maintenance diets are formulated on a per-calorie basis, reducing portion sizes inadvertently starves the animal of essential vitamins and minerals. Despite admitting this creates a clear pathway to nutrient deficiencies, neither the FDA nor AAFCO proposed drafting specialized senior nutritional profiles. Instead, they opted to preserve the status quo, allowing manufacturers to market generic formulas for senior pets without enhanced nutritional guarantees.

Consumer Advocacy and Industry Legal Counsel

• Consumer Advocates: Organizations such as the Association for Truth in Pet Food argue that these committee dynamics confirm a captured regulatory ecosystem. Advocates assert that regulatory authorities prioritize protecting corporate profit margins and accommodating manufacturing supply-chain logistics over consumer transparency and animal welfare.
• Legal Experts: Industry-aligned legal counsel, such as Venable’s Todd Harrison, signaled that while regulators may turn a blind eye to formulation quality, private class-action attorneys and federal truth-in-advertising enforcers are increasingly targeting deceptive label graphics. Manufacturers relying on misleading package imagery are being formally advised that their marketing practices represent an escalating financial and legal liability.

Implications for Pet Owners and the Industry

The outcomes of the San Diego AAFCO meeting carry profound implications for the future of the commercial pet food market:

1. Continued Consumer Deception: By refusing to establish distinct nutritional profiles for senior animals—while simultaneously allowing vague, lower-tier rendered meals to masquerade as quality protein sources—regulators continue to greenlight marketing practices that obscure nutritional realities from everyday pet owners.
2. Prolonged Regulatory Gridlock: The ongoing delays surrounding Pet Food Label Modernization demonstrate that corporate lobbying and state-level hesitance can effectively derail federally mandated consumer protections for decades. Pet owners should not expect standardized, modernized label disclosures until at least 2030—if not later.
3. Shifting Legal Landscapes: While regulatory bodies offer minimal friction regarding ingredient quality, the commercial landscape is facing an accountability shift regarding packaging claims. As highlighted by legal authorities at the conference, the era of unpunished deceptive "ingredient imagery" on pet food bags and corporate websites is drawing to a close under the pressure of potential consumer litigation.

The next semi-annual AAFCO meeting is scheduled to take place this coming January in Orlando, Florida, where industry stakeholders and consumer watchdogs will resume the ongoing battle over animal feed legislation.