Answers: Who Are AAFCO and the NRC?

Updated: Wednesday, May 15, 2019 12:44 PM

Published: Saturday, February 16, 2013 03:38 PM

Written by Lyn Thomson, BVSc DipHom

I see lots of references to the AAFCO nutrient requirements on cat food products. I also have seen nutritional requirements put out by the NRC and they seem to be different. What is the role of these two organizations and why are their recommendations different?

Most pet food labels mention the Association of American Feed Control Officials, or AAFCO, nutritional adequacy statement. It is considered to be one of the most important aspects of a dog or cat food label, but it is worth remembering that it is an industry standard and not a scientific standard.

The recommendations of the National Research Council, or NRC, were historically used as the basis for nutritional adequacy. The NRC provides expert advice based on sound scientific evidence.

However, the industry watch dog AAFCO has modified the NRC nutrient profiles for the purpose of practicality.¹ In other words, AAFCO believes that an organisation with close ties to the pet food manufacturing industry is qualified to alter the nutrient profiles created by the NRC scientists.

AAFCO permits a pet food manufacturer to claim that its product is 100% complete and balanced if it has complied with AAFCO's feeding trial protocols or nutrient profiles.² AAFCO's feeding trials last six months and are conducted on a minimum of eight animals, six of whom must complete the trial. As many nutritionists would point out, sustainability for six months does not translate into complete and balanced nutrition for a liftetime. The high levels of carbohydrate in "100% complete and balanced" diets for obligate carnivores is proof that these claims may meet an industry standard, but not a scientific standard.

The following is a brief history of the challenges in defining nutrient profiles for cats and dogs. The National Research Council of the National Academies of Sciences, Engineering and Medicine and the Association of American Feed Control Officials are the two most influential bodies when it comes to feeding domestic cats and dogs.

Since the 1940s, the NRC has released reports on the nutrient requirements of cats and dogs, based on available literature and research. The reports have been updated as new research has come to light. The NRC receives no direct funding for the reports, and is dependent on sponsorship to fund them.³

AAFCO was formed in 1909 to establish a framework for uniform regulation of the feed industry. Although not a government agency, it operates within the guidelines of federal and state legislation, including laws administered by the Food and Drug Administration, or FDA, and the United States Department of Agriculture, the USDA.⁴

While companion animals are the ultimate beneficiary of the NRC guidelines, the pet food industry is the key user of the reports. There is currently a legitimate and real concern about how to maintain the high standard and objectivity of the NRC guidelines in the face of the potential tensions of the pet food manufacturing industry.

The NRC guidelines assume that availability and digestibility of nutrients is uncompromised. Unfortunately, due to the nature of the raw materials used in the commercial production of pet food, this assumption does not hold true. As a result, pet food manufacturers concluded that the NRC recommendations could not be used in a manufacturing environment. To resolve this, in the early 1990s, AAFCO formed the Canine and Feline Nutrition Expert Subcommittees. These subcommittees comprised representatives from the pet food industry and academia, and were chaired by a representative of the FDA. They provided industry, and industry regulators, with a vehicle for translating the NRC recommendations into a set of practical guidelines which better suited the pet food industry. These guidelines made life easier for the manufacturer. AAFCO has accepted some of the NRC's recommendations, but certainly not all. These guidelines have not been reviewed since the 1990s.⁵

In 2006 the NRC published an update of recommendations for cats and dogs.⁶ The 2006 document represents a substantial improvement from previous guidelines, but has become an expensive document to produce, severely limiting its outreach. It would appear that AAFCO has not taken note of the most recent nutritional research.

To summarise, AAFCO provides some basic nutritional guidelines, a rough framework to build upon. The guidelines are very much concerned with the practicalities of making pet food from a vast array of low-quality ingredients. They are minimum, not optimal requirements. AAFCO acknowledge the NRC guidelines, but does not uphold them. In the words of Quinton Rogers, DVM, PhD, one of the AAFCO panel experts:

"Although the AAFCO profiles are better than nothing, they provide false securities. I don't know of any studies showing their adequacies or inadequacies." ⁷

Based on available nutritional science, it is best to take the AAFCO profiles as a starting point. These profiles are well-established minimal nutritional requirements for cats and dogs. Meeting a minimum requirement is important for the pet food industry. However, optimising our pets' nutrition is essential for improving their health and wellbeing.

I feel it is important to recognise food as not only having a nutrient profile, but also a form and function appropriate to the species being fed. The literature contains numerous references to the food habits of feral carnivores. Therefore, the appropriate nutrient profile is readily available.⁸ It is important to meet a minimum nutrient profile using bio-appropriate food, minimally processed and fed in a physical form that meets a pet's behavioural needs and enriches their lives.

Note: Feline Nutrition provides feline health and nutrition information as a public service. Diagnosis and treatment of specific conditions should always be in consultation with your own veterinarian. Feline Nutrition disclaims all warranties and liability related to the veterinary advice and information provided on this site.

Dr. Lyn Thomson trained at the University of Bristol in England and is studying with the Australasian College of Nutritional and Environmental Medicine. A dedicated and experienced advocate of bio-appropriate nutrition, Lyn practices in Auckland, New Zealand. HerRaw Essentialsstores have grown to seven retail locations, providing a variety of raw diet products for cats and dogs.

1. "Selecting Nutritious Pet Foods," US Food and Drug Administration (FDA), Nov 1997.

2. "Selecting Nutritious Pet Foods"

3. RF Butterwick, JW Erdman Jr, RC Hill, AJ Lewis and CT Whittemore, "Challenges in Developing Nutrient Guidelines for Companion Animals," British Journal of Nutrition, no. 106, Oct 12, 2011, S24-S31.

4. Butterwick, et al, "Challenges."

5. Butterwick, et al, "Challenges."

6. Butterwick, et al, "Challenges."

7. CA Smith, "Changes and Challenges in Feline Nutrition," Journal of the American Veterinary Medical Association 203, no. 10, November 15, 1993, 1395-1400.

8. SM Landry, "Food Habits of Feral Carnivores: A Review of Stomach Content Analysis," Journal of American Animal Hospital Association 15, no. 6, 1979, 775-782.