Estimated 30% of All USA Pet Food Is Legally Adulterated

Based upon federal law, approximately 30% of pet food sold in the USA can be described as adulterated. The reason is that federal law states that pet food must be considered adulterated if any of the ingredients do not come from a slaughtered animal. It can be said with some certainty that many of the ingredients have come from non-slaughtered animals such as “non-slaughtered spent laying hens” and animals which have died in the field. The hens are ground down and rendered as a pet food ingredient called chicken/poultry by-product and chicken/poultry bi-product meal.

Unadultered pet food

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There appears to be a clash with respect to legal definitions of ingredients. This is because, as mentioned above, pet food has to be produced from slaughtered animals but the legal definition of the ingredients listed below does not require them to be sourced from a slaughtered animal:

  • Chicken/turkey/poultry bi-products
  • chicken/turkey/poultry bi-product meal
  • beef/lamb/meat meal
  • animal bi-product meal
  • meat and bone meal
  • animal fat
  • animal digest

Why is the pet food industry in such an apparently dire state? The reason given1 is because of a lack of enforcement of the law. The laws which govern the manufacture of pet food have been inadequately enforced for a very long time to the point where it is said1 that it is now impossible to rectify the situation. Things have become too entrenched. It is estimated that $19 million of adulterated pet food is sold every day in the USA1.

The federal law which states that pet food is to be considered as “adulterated” if it is sourced from a non-slaughtered animal is the Federal Food, Drug and Cosmetic Act. The relevant section is 342. The full technical description heading this section is as follows: 21 USC 342: adulterated food. From Title 21-FOOD AND DRUGS, CHAPTER 9-FEDERAL FOOD, DRUG, AND COSMETIC ACT, SUBCHAPTER IV-FOOD.

All 50 states do not enforce the above federal law1. Ironically, 14 of the states duplicate the law in which case they are failing to enforce both federal and their own state laws.

Here are some examples on a state-by-state basis:

In Florida, under section 580. 071 Adulteration, (h) “if it is, in whole or in part, the product of a diseased animal or of an animal that has died by a means other than slaughter”.

In the state of Missouri adulterated pet food is legally defined as “if it is, in whole or in part, the product of a diseased animal or of an animal which dies other than by slaughter”.

In Missouri every large pet food store contains pet foods that contain ingredients which have not been sourced from a slaughtered animal and one example is the pet food: Meow Mix Cat Food.

Meow Mix contains four ingredients which under the legal definition referred to above have been sourced from non-slaughtered animals and these are: chicken bi-product meal, animal fat, animal digest and turkey bi-product meal.

It does not end there, apparently. Section 343 of the law that I have referred to above in capitals refers to false or misleading labelling (“misbranding”). All 52 US states do not enforce this section of federal law and once again, ironically, 42 of those states have their own very similar laws regarding misleading labels. An example of a label being misleading is when an ingredient is described as “grilled chicken” when it is not. Under these circumstances the pet food should be considered adulterated because the label presents a level of quality which is not present in the pet food.

Susan Thixton had made enquiries of the legal departments of both the states of Florida and Missouri as to why they are not enforcing the law. Thus far, she has not received a response. I’ll leave it there because this is quite a technical subject and if you want to dig around a bit more and digest the facts (pardon the pun) in more detail, I would recommend that you visit Susan’s webpage which goes a stage further.

She asks consumers to take action and report violations of the law to the state authorities. And if the authorities fail to enforce the law they should place a warning on the labels stating as follows: WARNING: This pet food could contain ingredients that are in violation of federal and state law. Handle and store with care. That is Susan’s suggestion. She provides easy access to the authorities in all 52 states allowing people to send an email to them with their complaints and suggestions.

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Note: 1 – source Susan Thixton —

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