On May 2, members of a panel from Pet Food Institute (PFI) on pet food regulation reached an unanimity vote: It’s time for things to change.
PFI President and CEO Dana Brooks joined EnviroFlight President Liz Koutsos, Ph.D. and George Collings, Ph.D. to discuss the current state of pet food regulation – its “patchwork” nature as well as any challenges involved with getting products approved to sell across states that impose various requirements – as well as what can be done in order to take pet food regulation forward in its entirety.
Collings wants consumers to have access to reliable information, which is often impossible when the industry must navigate between state, federal and congressional regulations as well as association ones competing for dominance. “Consumers expect companies playing by equal rules,” she stated.
One of the primary obstacles lies in that regulations can differ depending on where consumers reside.
“You cannot manufacture pet food for one state,” explained Brooks. “This is now a global economy; no longer regional.”
18 Months of Reflections
Over the past 18 months, Brooks and PFI have engaged in an intensive period of considerations, from non-disclosure agreements and meetings with industry stakeholders to discussions with key players at an federal level and discussions regarding desired changes at this time.
“Life sometimes gives us those crucial turning points where it becomes apparent that change must happen,” Brooks stated. During COVID-19 shutdown, my colleagues at PFI and I learned about the challenges facing member companies with supply chain management, label review processes, and competition for ingredients due to renewable diesel production growth. We needed a way to adapt and modernize — encouraging innovation if necessary — while operating through current regulatory systems; every potential solution offered provided uniformity and transparency was ultimately undermined by lack of consistent interference by individual states.”
As it happens, industry appears to share this view.
“Since our conversation started, many examples have come forward of veterinarian diets being pulled from certain states due to misinterpretations; and then being met with outrage from veterinary communities,” explained Brooks. Additionally, getting novel ingredients such as black soldier fly larvae reviewed and approved proved challenging; all states must agree upon ingredients and labels in order to prevent interstate commerce disruptions.
“PFI members were the driving force in making this project a priority, she noted. After taking into consideration some strategic considerations such as, whether this should be seen as a priority at PFI and industry levels and whether we were willing to cut resources elsewhere so this project could become one, it was unanimously decided: Yes!” Not just partial support but total dedication was shown from start to finish by everyone involved.
Modernizing pet food regulation: An Ambitious Goal
Public support is necessary for any plan to succeed, yet that doesn’t guarantee an easy path forward.
Brooks acknowledged there are certain aspects to our current structure that require negotiations and negotiations within it, such as how to transition from state registrations to one federal oversight office, when is an appropriate time of transitioning, ensuring no harm between now and when implementation takes place, etc. No doubt there will be more discussions within states, AAFCO, the FDA, as well as members of Congress who support such changes internally and on Capitol Hill.
Brooks identified one of the major obstacles as being states, who have held considerable authority over dog and cat food distribution and licensing pet food products to be sold across many states. But she hopes they’ll see how efficient final solutions will be and recognize their benefits to everyone involved.
“We have exhausted every other option for how we work within the current system,” stated Brooks. “There really is only one answer available here – one federalized system.”
Brooks makes clear that this issue only impacts dog and cat food. The current animal feed system won’t change; state inspections such as Food Safety Modernization Act (FSMA) inspections will remain their responsibility; any agreements made between FDA and states will remain intact.
“We’re willing to go through a transition period,” Brooks stated. “This won’t happen overnight; two to four years at best should do it. As things shift, my hope is that all parties involved can become more focused, innovative and stronger in another area.”
Brooks believes launching such a large project with confidence was instrumental, and noted that his taskforce, active for 18 months now, had the ability to explore possible solutions without incurring criticism from industry members or being subsumed into larger discussions about potential solutions – helping formulate an actionable plan which has now been presented for consideration.
“[This is] such an enormous project and we must all work towards its realization together in confidence over 18 months, never leaking information,” Brooks noted. “[It is] something big we need to address; therefore we should dedicate substantial energy and focus on how this should be presented.]”
As the group began slowly disseminating information, industry members expressed disappointment over not being involved from the outset – something Brooks understands well.
“I had to say, ‘Now is the appropriate time,’ she remarked. “Because we needed to work through these problems together and come up with solutions. Plus, larger rooms present greater challenges.” That has been difficult to explain to some of my industry colleagues, so now is your opportunity. Let me hear your questions or voice any concerns – we want to know everything so we don’t make any errors when making decisions about our service delivery. If you are an ingredient supplier and are confused by what this means for your company, reach out. Likewise, feed industry members needing clarification should come speak with us as well as state regulators as this change won’t occur overnight – in the meantime we need to work together.