AAFCO vs. A Raw Food Diet

What Is AAFCO?

The Association of American Feed Control Officials (AAFCO) is an independent organization that has been guiding state, federal and international feed regulators with ingredient definitions, label standards and laboratory standards for more than 110 years, while supporting the health and safety of people and animals. This means they set standard guidelines for the pet & livestock feed industry in the USA.

Where Did AAFCO Come From?

During World War II, food was scarce, hard to transport, & variety was severely lacking. So, the scientists came up with Recommended Daily Allowances. These allowances identified the minimum nutrients that the soldiers would need to survive. The scientists created meal plans & foods from this information so they could easily send it to the soldiers to keep them alive. However, the food was made to sustain life–not keep people healthy. It was a short-term solution.

After Recommended Daily Allowances were set, the National Research Committee (NRC) did more research. They looked at whole foods & started to set minimums, maximums, & even recommended values for an assortment of nutrients.

Although establish in 1906 AAFCO originally used the guidelines from the NRC. It wasn't until 1969 that AAFCO adopted the term "complete & balanced" for pet food. They realized the processed foods that they were dealing with was very different from the whole foods of the NRC. In 1990, AAFCO started setting standard "guidelines" for high heat processed animal feeds. Like the Recommended Daily Allowances, AAFCO mostly has only minimums of nutrients listed. They have a few maximums but make no recommendations as far as ideal or optimal levels of nutrients in food.

Why AAFCO Standards Cannot Apply to Raw Diets

AAFCO guidelines may actually cause raw food manufacturers to do more harm than good if raw foods are compelled to satisfy the same criteria as kibble. The current AAFCO guidelines are based on the ultra-heat processed kibble that is commercially available. The bioavailability of the nutrients significantly differs between processed and raw food.

AAFCO's current mineral recommendations are based on kibble diets containing phytates found in grains, fiber, and legumes. Phytates bind with zinc, calcium, iron, and magnesium, reducing their availability to the body. Raw diets do not have the same levels of phytates, so the minerals are more bioavailable. If the current AAFCO guidelines are applied to raw diets, there is a potential for mineral toxicities.

The heat processing used for manufacturing kibble also alters the nutrients, which is why most kibble contains artificial vitamins and minerals. Raw food is unprocessed, so all nutrients remain bioavailable to the dog. Synthetic supplementation is not required to meet the nutritional needs of the dog.

What Does “Complete & Balanced” Mean?

The majority of pet food labels claim that the product is a complete and balanced diet, so it is assumed that the formula will meet the nutritional requirements for the maintenance of the dog in the life stage for which it is intended. However, investigations into brands with complete and balanced claims have revealed that many products fail to contain all recommended nutrients.

For a pet food label to display the nutritional adequacy claim of “complete and balanced,” a feeding trial conducted according to the American Association of Feed Control Officials (AAFCO) protocols must be conducted in-house by the food manufacturer, or the food must meet the minimum AAFCO nutrient profile for the life stage listed on the package.

If labeled “complete,” the food must have all the nutrients AAFCO considers "necessary" for a dog's health. The term "balanced" refers to the presence of nutrients in AAFCO-approved quantities.

National Research Council provided minimum nutrient requirements for healthy dogs and cats in bulletins published in 1985, 1986, and 2006. AAFCO then extrapolated the NRC information to commercially available pet foods and published Nutrition Profiles for Dog Foods in 1993 and

Nutrient Profiles for Cat Foods in 1994. Although the AAFCO nutrition profiles are republished annually, the NRC has not published new recommendations since 2006. Hence, the data is old and does not reflect all of the current nutrition research.

-Feedreal.com

How To Meet AAFCO Guidelines?

To meet AAFCO guidelines, pet food must pass a feeding trial or a standard vitamin and mineral requirement. Supplementing a processed diet with an adequate blend of premeasured synthetic vitamins and minerals is the cheapest way to meet this criterion.

A successful food trial keeps a minimum of six out of eight dogs alive for 26 weeks, with one or more of them not losing more than 15% of their body weight and no blood values falling below the stipulated minimum. Additional requirements for pet food to pass as "complete and balanced" include:

All trials must be conducted in-house.
'Growth food' testing must be conducted for ten weeks
Two dogs can be removed from the trial, and data does not have to be included regarding these two dogs.
Hemoglobin, packed cell volume, serum alkaline phosphates (for kidney health), and albumin (for liver health) must fall between the recommended low and high values.

Once a product has passed a food trial, the manufacturer is not required to do further analysis.

Can Raw be Complete and Balanced Dog Food?

Pet foods have historically been formulated based on nutrient content rather than ingredients, given that animals have specific nutrient requirements. The bioavailability of fresh food has been shown to be much higher than that of ultra-processed food. Nutrients within the fresh food are more readily digested and absorbed. During kibble production, vitamins are destroyed, and minerals are altered, making it necessary for the manufacturers to add synthetic counterparts to the end product to meet the AAFCO guidelines.

Many online programs are available for the dog parent to calculate a complete and balanced diet utilizing spreadsheets and other tools. But with most formulas, dog parents must include non-whole food supplements to create the perfect formula. Once they find the correct ingredient combination, many dog owners will feed the same recipe for the rest of the dog’s life.

While meeting NRC or AAFCO guidelines is not necessarily harmful, there are complications with trying to meet them using fresh food. Commercial pet food companies benefit from these standards as more dog parents make their dogs’ food. When asked, “Does your dog’s food meet AAFCO standards?” dog parents can inform those questioning them that the diet is biologically appropriate and balanced to meet their dog’s nutritional needs. Every dog has different needs, and the owner must meet those needs through a species-appropriate diet rather than a one-size-fits-all bag of kibble!