By Carolyn Kennedy
Everyone is looking for the next best thing when it comes to pet food. Many companies have tried to introduce new ingredients. Often, the new ingredients in pet foods mirror the trending ingredients in human food. There has been an influx of CBD and hemp treats in pet foods, with claims that these products can support many health-related issues in our beloved 4-legged friends.
However, new ingredients are not always approved ingredients, and as a pet food company, it always pays out in dividends to do the research regarding new ingredients before you start the NPD process. The Association of American Feed Control Officials (AAFCO), as well as FDA CVM, approves new ingredients for feed, and if the ingredient is not approved by AAFCO for use in the specific species such as dogs or cats, it is likely you will not be able to use this ingredient in your products.
Each new ingredient goes through a diligent process, evaluating the safety of the ingredient, determining maximum levels and settling on a distinct ingredient definition. Getting an ingredient approved through AAFCO, and for it to be listed as on official ingredient in the yearly AAFCO Official publication, can be a lengthy process. If there is an ingredient of interest to you, the best place to start is by obtaining all the information regarding the ingredient you wish to use and then submitting your dossier to the appropriate AAFCO investigator. The ingredient file is quite robust, and should contain many different studies, including but not limited to safety assessments outlining target animal safety, toxicity, known impurities, environmental safety, carcinogenicity and many other elements.
Ingredient files that are prepared correctly, with all the information, have a much better chance of being added to the next AAFCO meeting to discuss, and hopefully a tentative ingredient definition can be created. Tentative definitions are moved to official definitions following further review.
Important key attributes of new ingredients are that they are consistent batch to batch, should not be a combination of other ingredients, and their intended use should not be to mitigate or treat a disease, but rather to provide nutrition, color, taste or aroma for the intended species. Ingredients can have technical effects in the finished product too (1).
Another route of obtaining clearance for a new ingredient is to go through GRAS certification for the proposed ingredient in the intended species through FDA. If GRAS certification is obtained, FDA can provide a letter of no objection that can be used if questioned regarding the safety and appropriate use of the new ingredient. Filing a feed additive petition (FAP) through FDA is also possible.
Whether you are submitting a new ingredient to AAFCO, trying to obtain GRAS certification, or filing a feed additive petition, the one constant is always – time. Each of these options can take a few years, if not longer, depending on required testing, documentation, and the caseload of FDA or AAFCO at the time.
So, if your NPD for 2021 focuses on CBD, Kombucha, sprouted greens or Chaga mushrooms in pet food, it might be best to start with a consultant who can talk through the required elements, processes, timeline and feasibility of having any one of these trending human food ingredients approved for use in pet food. In fact, if and when these ingredients are approved, the human food industry may have moved on to newer ingredients!
- Pennsylvania Department of Agriculture. Submitting New Ingredients Definitions to AAFCO firstname.lastname@example.org for investigator assistance
Posted in Issue of the Month.