Many dog owners and veterinarians find assurance in a food which meets AAFCO nutrient standards. But are the current standards appropriate for raw dog food?

One of the purposes of the American Association of Feed Control Officials (AAFCO) is to oversee nutritional adequacy statements on pet food labels. Although AAFCO statements are intended to assure the available pet foods are “complete and balanced” diets, AAFCO doesn’t regulate, test, approve or certify pet foods. It’s the pet food manufacturers’ responsibility to manufacture the pet food according to AAFCO standards. In fact, the guaranteed analysis of the food and whether or not it truly meets AAFCO nutritional standards may never be verified by a regulatory authority.

Currently, all pet foods carry one of three statements, as approved by AAFCO:

“Animal feeding tests using AAFCO procedures substantiate this product provides complete and balanced nutrition for all life stages of dogs and cats.”

This means the company chose to conduct feeding trials on their food. This could be an excellent way to test a food if the trials were statistically significant. But at present only eight dogs are required to be in an AAFCO feeding trial and only six have to complete it for that trial to qualify. Additionally, trials are run for only a short period of time: 26 weeks (unless the trial is for growth, then it is only 10 weeks).

Only four values are examined in an AAFCO feeding trial: hemoglobin, packed cell volume, serum alkaline phosphatase (SAP) and serum albumin. There is no requirement for a full blood chemistry panel, no complete blood count and no urinalysis. The dog is examined by a veterinarian before and after the trial for clinical signs of nutritional disease, but unless a food is blatantly formulated wrong, it’s unlikely that within this brief period of time the dog will develop clinical signs of a problem.

According to David Dzanis of the FDA, “Especially in the maintenance trials, subtle chronic nutrient deficiencies or excesses can be overlooked.”

“This product is formulated to meet the nutritional levels established by the AAFCO Dog and Cat Food Nutrient Profiles for All Life Stages (or for growth).”

Rather than doing expensive feeding trials, manufacturers may choose to formulate their food to meet AAFCO nutritional panels. But can chemical analyses and nutrient profiles determine if a food provides excellent nutrition for a dog? According to the National Research Council‘s The Nutrient Requirements of Dogs (NRC Guidelines) “…caution is advised in the use of these requirements without demonstration of nutrient availability, because in some cases requirements have been established on the basis of studies in which nutrients were supplied by highly purified ingredients where digestibility and availability were not compromised by the interaction of dietary constituents and effects of processing.

Practical diets formulated from commonly used ingredients are not free of such interactions and effects, and therefore may provide less available nutrients than the amounts measured by chemical analysis. For this reason, such diets formulated to the chemically assayed nutrient levels…may prove inadequate in meeting the nutritional needs of dogs.”

There is often variance from batch to batch yet manufacturers aren’t required to test every batch. They can also vary their ingredients to some degree and aren’t required to report it on the label.

“No one knows how to precisely formulate a diet with optimal amounts of nutrients …The amount of any needed nutrient falls in an optimal range rather than being a specific amount” says Dr. Donald Strombach DVM, PhD (Home-Prepared Dog & Cat Diets: The Healthful Alternative): “Feeding a marginally adequate diet may result in no signs in a sedentary animal. However, with the addition of stress, that diet is nutritionally inadequate.”

David Dzanis from the FDA writes, “Unequivocal proof of a product’s nutritional adequacy for all animals under all conditions can never be achieved.”

“This product is intended for intermittent or supplemental feeding only.”

This means the food does not meet AAFCO nutrient profiles. Interestingly, some commercial raw foods fall under this category and are forced to display this qualification on their label. Can a food labeled this way still be a good choice for our pets?

Alternatively, can a raw food meet AAFCO standards and still adhere to the principles of raw feeding?

The Myth of 100% Complete Nutrition

If raw foods are required to meet the same standards as kibble, AAFCO standards may actually cause raw food manufacturers to do more harm than good.

Currently AAFCO’s requirement for zinc, for example, is based on the low bioavailability of zinc in kibble: phytates in kibble bind with zinc, making zinc unavailable to the dog. With meat based raw foods, there are no phytates so this isn’t an issue. Zinc also interacts with calcium. Less zinc is needed in diets lower in calcium while more zinc is needed in diets high in calcium. If one uses NRC Guidelines, a 33 pound dog would require 52.5 mg zinc for 3500 kcal, but AAFCO would require 120 mg for the same size dog. That’s understandable if most of the zinc isn’t bioavailable, but what happens when the zinc is easily bioavailable, as it would be in a raw diet? Could the current levels cause raw manufacturers to put too much zinc in their diets in order to meet AAFCO standards? As with all micronutrients, an overdose could be harmful.

The ratios of food ingredients, such as calcium and phosphorus, vitamin D and calcium, copper and zinc, vitamin E and fats, are important. Phytates in grains and fiber and legumes bind with zinc, calcium, iron, and magnesium and make these critical minerals less available to the body. According to the NRC Guidelines, “If the Ca:P ratio exceeds 2:1 or the diet contains significant amounts of phytate, (phosphorus) absorption will decrease.”

Foods with grains therefore need to add more phosphorus to meet the requirements of a dog than a meat based raw diet would. Requiring both to have the same amount of phosphorus doesn’t make sense and is potentially harmful. The amount of protein on a label also doesn’t tell you if the amino acids are in balance with one another or if the protein is in a usable form. High heat and processing can reduce the availability of amino acids, especially lysine, methionine and cysteine.

Many of the required nutrients (and there are over 40) are reactive or labile under the conditions of extrusion and high heat, so AAFCO nutrient profiles have been established to try to make up for this. Raw food however, doesn’t undergo the same heat and processing.

Added Vitamins

What about vitamins? Why don’t raw food companies just add vitamins so they can meet AAFCO nutritional standards? Many nutritionists are against chemically synthesized vitamins and for good reasons. A natural, whole food vitamin is different from a chemically synthesized vitamin and these differences will affect how the synthetic vitamin is absorbed and utilized by the body.

The vitamin C complex in whole foods contains over eight components whereas synthetic vitamin C has only one ingredient: ascorbic acid. Vitamin E may be d-alpha or dl-alpha. Only one is found in nature, the other is the mirror image. Synthetic alpha- tocopherols, besides differing chemically in structure, vary in absorption, metabolism, and bioactivity. Ron Carsten DVM MS states (The Benefits of Whole Food Nutrition in Veterinary Medicine,Whole Food Nutrition Journal): “Synthetic vitamins and other substances are added (to kibble) in an effort to compensate for this nutrient loss. However, these additives create ongoing metabolic stresses that, coupled with the limited ingredient selection and processing of foods, leads to situations in which cellular nutritional status can be compromised, causing tissue malnutrition.” Synthetic vitamins may even be harmful.

Certainly excesses can be harmful.

Dr. Richard Patton (Ruined By Excess, Perfected By Lack: The Paradox Of Pet Nutrition) adds, “The topic of vitamins (and trace minerals) is actually larger than degree of bioavailability. As an example, how do all the wild canids throughout the eons of history manage to thrive and reproduce without ever consuming the first molecule of micronutrient from a commercial source? …All live well without any vitamins added to their diet. Insight to this situation is gained from research done by pioneer vitamin investigators of the 1920s and 1930s. They could not produce a vitamin deficiency unless feeding a diet high in soluble carbohydrate.”

This leads to the theory that dry kibble, due to its high (35-45%) soluble carbohydrate, alters gut microflora, thus necessitating vitamin supplementation.” Even though there is no requirement for carbohydrates in dogs, most commercially produced kibble contains a high percentage of carbohydrates. Should AAFCO mandate a maximum level of carbohydrates? Since an excess of carbohydrates can be harmful, I believe a maximum level is highly desirable.

A Double Standard

I’m not saying that we should do away with standards or requirements for nutrient levels in commercially produced dog foods. We need standards to protect our pets from harmful imbalances, insufficiencies or excesses. When it comes to raw foods however, AAFCO standards may not be a good fit nor do they ensure true nutritional excellence for our dogs.

Dr. Doug Kneuven, DVM adds: “100% complete [nutrition] assumes 100% complete knowledge of food and nutrition, biology, genetics, chemistry and physics. It is a common myth that the minimum and maximum amount of essential nutrients needed for “normal” dogs is known. Most is not known, we are just trying to avoid toxicities and deficiencies. There should be different nutritional standards for raw and processed foods.”

Personally, I don’t want synthetic ingredients in my dogs’ food. When it comes to synthetic vitamins, I don’t want to worry about formulation errors, which have been deadly in numerous cases. I want my dogs to consume fresh food with meat protein and whole food complexes without the harmful consequences of high heat and storage.

As a veterinarian, I would love to believe there was a standard that would guarantee perfect nutrition for our dogs and ensure health and longevity. But I don’t have much faith that current AAFCO standards meet these criteria when it comes to raw foods.

Like most vets, I was taught that “complete and balanced” was the standard to look for in pet foods, but I’ve come to realize that nutrition is much more complicated than that. Raw is different; raw is real food.