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The Association of American Feed Control Officials (AAFCO) is a private organization, not a government agency. It’s funded primarily by giant pet food companies and trade associations with strong pull to shape the rules that govern packaging and labeling. Membership in AAFCO can be pricey, and therefore the majority of the members are associated with giant pet food companies (with large budgets) who mass produce highly processed foods.  Smaller, fresh pet food companies are represented at AAFCO through NGPFMA (Next Generation Pet Food Manufacturers Association) but their numbers are miniscule compared to the power and influence of the giant corporations and so understandably the guidelines favor highly processed brands.  (See examples below)

AAFCO’s Role in Ingredient Definitions:  

Until 2025, AAFCO defined all pet food ingredients and these definitions were considered confidential and proprietary (not available to the public).  In 2025, the FDA published the feed ingredient terms so they are no longer a secret (see pet food labels for more information on feed ingredients). 

AAFCO’s Role in Label Regulations:  

AAFCO publishes guidelines for regulating pet food labels (including claims) in what they call the “Model Bill” which is NOT federal law but is an example of the guidelines that states MAY incorporate into their laws.  While most states adopt the AAFCO Model Bill as written, states are free to modify the guidelines or define their own.  This presents a challenge for companies distributing products in multiple states, since the regulations could vary.  However, most states will approve labels that comply with the AAFCO Model Bill.

AAFCO Representation:

Until recently, AAFCO meetings were not open to the public.  NGPFMA participates in the AAFCO meetings and represents fresh pet food companies who are required to adhere to the AAFCO guidelines, even those that favor highly processed foods.  While it may be frustrating to hear a response that says simply “because we have to” the reality is that non-compliance with regulations results in products being pulled off the shelf.  

Examples of Product Name Driven by AAFCO:

Have you wondered why some products change their names even when there is no other recognizable change on the label?  This may be due to changes in regulations that suddenly make the product name non-compliant with new AAFCO regulations.  For example:

  • “Low Copper” claims are no longer permitted, even when the copper level is lower than the AAFCO guidelines.  When AAFCO removed the maximum allowed level of copper, they also removed any claim of “low copper” or “controlled copper” unless it was sold as a “prescription-only” product (requiring a prescription by a licensed veterinarian) or as a treat.  While fresh food was represented by NGPFMA at AAFCO meetings, this decision clearly favored large corporations producing prescription-only products.
  • “Low Glycemic” claims are no longer allowed, with AAFCO’s reason being that since there is no guideline establishing any glycemic level, the term “low” cannot be used unless sold as a prescription-only product or a treat.  They even prohibit calculated glycemic load from being on the label (or on a company’s website).   Companies with any reference to “low glycemic” have been forced to rename the product(s) and remove “glycemic load” from their label. 
  • “Low Carb” claims are not allowed since there is no AAFCO guideline establishing minimum or maximum carbohydrate levels.  While it is generally accepted that carbohydrate levels below 15% are considered relatively low, a company may not claim low carb even if the levels are in the low single digits.  All fiber contains carbohydrates (while not all carbs contain fiber) so meeting fiber levels requires some level of carbohydrates.  Most dry kibble contains high levels of carbohydrates, some as high as 70-80%, but manufacturers of those products do not want to publish their levels.  And since those companies represent the majority of AAFCO members, AAFCO’s decision was to ban the term.
  • Ingredients in the Name: Ingredients cannot be included in the name unless the product includes a minimum % of that ingredient.  But there are ways around this that allow the manufacturers to make you think there is more of that ingredient than what is really included.  For example, a product that claims “Made With” must only have 20% of that ingredient in the product.  So a product claiming “Made With Real Chicken” makes you think all chicken in that product is “real chicken” while the majority of the chicken ingredients may be rendered or highly processed ingredients made from chicken waste products. The term also gives the impression that “chicken” is a majority of the product’s ingredients when that is not the case.   (see Processing and Chicken articles)

There are many examples of how AAFCO’s influence dictates what may or may not be on the label, or even how the product is named.  Some regulations protect the consumer while others protect the manufacturer from having to disclose what is really in the product.  The only way for the pet parent to know what’s really in the product is to contact the manufacturer and ask the really tough questions – and purchase products from manufacturers that you can trust.

Click here to find out more about differences between ingredients and how hard it is for the consumer to know the difference.