Pet food labels are highly regulated both on a federal and a state level, and again on an international level for those who ship across international borders. (such as New Life) The federal regulations in the USA are published in the Code of Federal Regulations (CFR), Title 21CFR
By law:
Ingredients must be listed in order of predominance by weight, on an "as formulated basis". The ingredient that makes up the highest percentage of the total weight as it goes into the product is listed first. The ingredients used must be GRAS ("Generally Recognized As Safe), approved food additives, or otherwise sanctioned for use in animal feeds (for example, defined by AAFCO). Ingredients must be declared by the correct AAFCO-defined name, where one exists, or the "common or usual" name
I posted the following last year in another discussion along this lines.
As far as regulations ...........
Most people have no idea what type of red tape, regulations, and inspections are involved when actually manufacturing pet food, it can be an absolute nightmare for a US based company that has to not only deal with federal regulations, but also each state individually.
In the USA this involves not only the FDA, but also the U.S. Department of Agriculture (USDA) Animal and Plant Health Inspection Service (APHIS), Veterinary Services (VS), and The Association of American Feed Control Officials. (AAFCO)
In many cases these regulations change on a frequent basis. It's gotten to the point that probably the less info one places on their label, the better, or you'll be updating your labels every 6 months. These changes cost $, for larger companies lots of $$$$ , and someone has to eat the cost of outdated labels, and yet another run of new updated labels.
As an example, most states allow Vitamin C to be listed on a pet food label, but all it takes is one overly anal state inspector to decide that it must be listed as ascorbic acid, and you are forced to either remove that listing from your label, or play by their new rules. Even if the vitamin C you are listing is the total content, most comprised from the raw ingredients themselves, not from some vitamin premix. One wrong word or term can equate to your product being disallowed in an entire state, and each state requires a permit just to get your product across their border, and like everything else, you have to pay for that privilege.
And that's just what takes place within the USA, now factor in all of the other various countries that some fish food products are exported to & things can become goofy stupid.
The USA & Canada couldn't give a rats behind with regards to things such as GMO products, but the UK requires additional labeling if the product contains .9% or greater GMO. A country such as Turkey doesn't allow any GMO products, not even if it's as little as .0001%. They use outdated testing equipment that simply tests positive, or negative, and if it's positive your shipment will be refused at their border.
I seriously doubt that fish food will ever come under the same type of scrutiny as dog/cat food, but it doesn't get any free passes either. Having said all that as clockwork suggested the way things currently are there are a number of ways that one can bend the rules & manipulate a fish food label, and some manufacturers do take advantage of these loop holes.
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After doing this as long as I have, I can open the lid of a fish food container, take a deep wiff, and have a pretty good idea how much starch vs marine protein is in the food. I've been known to perform taste tests as well.
As far as the "proprietary blend" comment, well hell yeah, only a moron would list all of the various percentages of each & every raw ingredient used in their food. You're talking about an industry where billions of dollars are at stake, and every one is attempting to get (and keep) their piece of the ever shrinking pie. And yes I do know things that I cannot share on a public forum, or anywhere else. I can also state that I have seen a nutritional analysis of NLS that was performed by a 3rd party non-biased accredited institution overseen by those who are considered experts in this field. This information was published in document that the owner of New Life was not even aware of for several yrs, at the time this institution asked if New Life would supply some food for a study they were performing on a species of wild fish, and Pablo gave them some food. That's where his part in the feed trial began & end.
BTW - I'm the original skeptic.
