The language of labelling: part four

Additives and supplementary ingredients

We all want the best for our dogs, and part of that means understanding what ingredients are in their food. To that end, we need to be aware of what marketing designs are permitted – and used. Because one thing is certain: this language has nothing to do with our dogs. It’s aimed at us.

As one study puts it:

“Human perception of pet foods is usually determined by descriptive sensory analysis. (…) Pet foods can also be prepared to be more appealing to pet owners if the chosen aromas and flavours are commonly associated with human food[1].”

In looking at the guidelines for labelling, I’ve made some surprising (and increasingly unsurprising) discoveries. It is so important to understand what’s under the bonnet, what isn’t immediately clear to us: opaque labelling makes it hard for dog owners to understand what’s truly on offer.

We’ve already looked in these posts at flavour, ingredient hierarchy and the overarching “mixing bowl principle”. Now let’s turn to additives. What are they, when are they added – and could they be a cause for concern?

Perception vs Reality

For most of us, the phrase “with added vitamins and minerals” sounds reassuring. It implies safety, reinforcement and nutritional balance. The truth is more complex, however. An “additive” can be any one of a wide range of substances authorised for animal feed, from micronutrients to colourants, flavourings, preservatives, stabilisers or digestive enhancers. Some are to achieve nutritional balance; others merely keep the product shelf-stable. In short, the word “additives” covers a lot of ground.

Many vitamins and minerals listed as ingredients are added in the form of synthetic chemicals and other supplements, because they are missing from the processed material that becomes manufactured pet food.[1]  The destruction caused by extrusion needs to be rebuilt with additives.

Declarations: mandatory or voluntary?

Only those additives with a legal maximum level are required to be declared on the label; any others are declared at the discretion of the producer (“voluntarily”). Hence pet foods may contain flavourings, colourants or processing aids that never appear on the label at all – if the manufacturer is so inclined.

Additives that manufacturers are required to label are preceded by the word “Additives” followed by either the categories or functional groups of the additives used along with the name and/or identification number and the amount added.

Alternatively, the manufacturer may derogate from this option and simply write “antioxidants.” If it opts to do so, it must inform the purchaser of full details of each additive upon request. Interestingly, however, manufacturers need not inform the public of their right to this information where the derogation is used.

Functional Groups

Additives belonging to several functional groups, like antioxidants, flavourings and colourants,  may be declared only by one group name. The additive can then be declared only under its principal functional group (which group is the manufacturer’s decision). The information is not routinely disclosed on the label or otherwise made available to consumers, for reasons of recipe confidentiality.

Basically, the system is designed to provide legal compliance while protecting recipe details. But the manufacturer’s freedom to protect their commercial data blurs the lines of consumer transparency.

Blurring purpose

If a single additive has multiple roles (for example where vitamin C acts as both nutrient and preservative), the manufacturer only has a requirement to declare it under its principal functional group (the manufacturer may also decide which function is principal: there are no rules on this). When declared this way, just the name of the additive is sufficient.

This choice obscures the additive’s full role, yet the information is not disclosed on the label, because it is treated as protected commercial data.

Why: If an inexpensive ingredient (like a preservative or thickener) also has an incidental nutritional role (perhaps because it contains a trace mineral) and the manufacturer only declares its principal function (e.g., “Technological Additive”), there is no requirement to disclose its nutritional contribution. This enables manufacturers to change suppliers or swap out ingredients without having to update the primary nutrient declarations or reveal how they have achieved minimum nutrient levels.

Blurring identity

Additives belonging to the groups preservatives, antioxidants, flavourings and colourants may be declared only by their generic group name (“antioxidants,” for example) with no specific identification number (e.g., E320).

If the manufacturer uses this generic group name, they are legally required to provide the specific name, identification number and added quantity upon the consumer’s request.

Why: Even if the principal function of a substance is to extend shelf life, listing it as a preservative might sound less beneficial than declaring it as an antioxidant, even though that may not be its principal purpose. This gives the manufacturer leeway to “control the narrative”.

Treats

Complementary feeds – the industry term for treats and extras – can legally contain much higher additive levels than complete feeds: up to 100 times the authorised limit. If a complementary food exceeds the permitted maximum of an additive for ‘complete’ feed, the manufacturer must state a maximum intake level of that complementary product. That means the onus is on us, the owners, to be extra alert with those labels!

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The Code

“Additives of the functional groups preservatives, antioxidants, flavourings and colourants with a maximum legal level or which exceed the recommended maximum level can optionally be declared by only the respective functional group.”
“If an additive is declared voluntarily under the additives heading, at least its name shall be indicated; for flavouring compounds, at least the functional group.”
(FEDIAF Code of Good Labelling Practice for Pet Food, 2019)

From the Consumer Guide (Annex 12)

“Additives may be declared individually or by functional group. Declarations such as ‘antioxidants’ or ‘preservatives’ are permitted. The function of an additive may also be indicated, for example ‘with added vitamins and minerals.’”

Why it matters

Understanding how additives are declared (or not declared) explains why and how two similar-looking foods can differ widely in composition.

A product claiming “no artificial preservatives” may still contain naturally derived antioxidants that serve the same function; another that reads “with added vitamins and minerals” may list none of them individually. Because selective disclosure blurs the boundary between regulation and marketing, the “information” is incomplete.

That gap leaves owners unable to judge either quality or purpose of additives with confidence.

Trying to make sense of the small print, one piece at a time.

 

References

[1] Not Fit for a Dog: The truth about manufactured dog and cat food

 

Important Considerations:

  • Always consult your veterinarian before making any significant dietary changes, particularly where there are pre-existing health conditions or dietary restrictions.
  • If you are feeding commercial food, check the label for ingredients before giving more. Excessive intake of any foods can have adverse effects.
  • Ensure (where possible) that you use high-quality, organic products specifically formulated for pets (or better still, human grade ingredients) to avoid any potential adverse effects.
  • Introduce new foods gradually to avoid adverse effects such as gastrointestinal upset or diarrhoea.
  • I provide nutritional information purely as a helpful guide. Nutritional information on ingredients is obtained from the US Department of Agriculture’s FoodData Central site (https://fdc.nal.usda.gov/index.html) and any nutritional information provided in recipes is based on an online calculator: calories and other information will vary based on brands, ingredients and other factors.
  • Check nutrient levels and recommendations for your dog’s weight, age and activity. For example this nutritional guideline produced by FEDIAF.
  • I am not a professional canine nutritionist, but supporting research is cited.
  • The recipes shared were created by me and tested in my kitchen – and tasted and approved by our doggy friends!