Your Comments to FDA are Needed – Truth about Pet Food


If you want law to be enforced in pet food, your comments are needed.

Background: In October of 2016, we (Association for Truth in Pet Food) filed an official request with FDA (Citizen Petition) asking the Agency to fully revoke their allowed use of pet food ingredients sourced from “diseased animals and animals that have died otherwise than by slaughter“. This material is officially a violation of federal law in human or animal food – the very laws FDA is supposed to enforce. But FDA allows this waste to be dumped into pet food anyway. Click Here to read the Citizen Petition.

Six months after we filed our Citizen Petition, we filed an Addendum with FDA asking the Agency to establish a feed/food standard of identity (label name) for all pet products. Because most pet foods are not food, they are feed (the same as cattle feed and chicken feed but for cats and dogs), we asked the FDA to require pet products to be termed/labeled with their proper name; Cat and Dog Feed if the product does not meet food regulations, Cat and Dog Food if the product meets the legal requirements of food. Click Here to read the Addendum.

On April 30, 2019 – 2 1/2 years later – the FDA finally responded with a “No” to everything we asked for. One of the most concerning statements FDA made in their response was: “we do not believe that the use of diseased animals or animals that died otherwise than by slaughter to make animal food poses a safety concern…” FDA fully intends to continue to allow pet food to use illegal ingredients with no warning or disclosure to pet owners. Another concerning statement made by FDA was regarding the proper labeling of pet products as feed or food. The FDA response stated they didn’t believe a feed/food labeling of pet products “would help consumers to know specifically how pet food differs from human food.” Actually, it would help significantly; labeling pet products by their true identity – feed or food – is a simple and transparent means to inform pet owners to what they are purchasing. Click Here to read the FDA response.

So…the legal system allows us to ask FDA to reconsider their “No” to enforcing law in pet food. The reconsideration process is to file the official request as a “Petition for Reconsideration” with FDA providing the Agency information on what we believe they did not originally consider in their response. On July 12, 2019 our Petition for Reconsideration was posted on the Regulations.gov website. Click Here to read the Petition for Reconsideration.

To the point of this post – the Petition for Reconsideration is open for your comments. If you believe that law should be enforced in pet food – please comment. If you believe pet owners should know if the product is a pet feed or pet food through clear labeling – please comment. Your comment can be as simple as ‘I fully support the Petition for Reconsideration’ or it can be detailed to why you believe pets should not be consuming ingredients sourced from diseased animals or decomposing animal carcasses and why you believe pet products should be properly labeled as food or feed (disclosing what they really are to all pet owners).

To comment, Click Here. The page that opens up looks like this:

Click on the blue box that says “Comment Now!“. The comment page allows you to type directly on Regulations.gov website or you can write a lengthier comment in a document and upload that to the website.

Note: your comment needs to be specific to only the issues we have asked the FDA to reconsider. Those issues are:

  • We are asking FDA to STOP allowing pet food ingredients to be sourced from diseased animals or animals that have died otherwise than by slaughter (such as euthanized animals or animals that died in the field).
  • We are asking FDA to modify current pet food ingredient definitions requiring all animal protein ingredients to be sourced from slaughtered animals.
  • We are asking FDA to require pet products to be labeled as food (Cat Food, Dog Food) ONLY if they meet the legal requirements of food. We are asking for all other products to be labeled as feed (Cat Feed, Dog Feed) providing pet owners with transparency and honestly labeled products.

This is your opportunity to become part of changing the future of pet food. In FDA’s final decision, the Agency is required to address each comment received. Please (please, please) provide FDA your comment on these issues.

Wishing you and your pet(s) the best,

Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
TruthaboutPetFood.com
Association for Truth in Pet Food

Become a member of our pet food consumer Association.
Association for Truth in Pet Food is a a stakeholder organization
representing the voice of pet food consumers at AAFCO and with FDA. Your
membership helps representatives attend meetings and voice consumer
concerns with regulatory authorities. Click Here to learn more.

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What’s in Your Pet’s Food?
Is your dog or cat eating risk ingredients?  Chinese imports? Petsumer
Report tells the ‘rest of the story’ on over 5,000 cat foods, dog foods,
and pet treats. 30 Day Satisfaction Guarantee. Click Here to preview Petsumer Report. www.PetsumerReport.com

The 2019 List
Susan’s List of trusted pet foods. Click Here to learn more.





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