The language of labelling: Part three
The ingredient hierarchy and the ‘Mixing Bowl’ principle
We all want the best for our dogs, and part of that means knowing what they’re eating, 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.
Hence my question in the Language of Labelling posts:
Does labelling operate in a space between what’s permitted and what is likely to be believed?
This is one of a series of posts on the language of labelling, setting out various elements of our pet food labels and what they (can) mean. Last time we looked at flavour claims. This time, it’s ingredient hierarchy and the mixing bowl principle.
The Mixing Bowl Principle
Seeing duck or chicken atop a list of ingredients feels reassuring. The assumption is simple and understandable: if meat protein takes the lead, it must surely make up the lion’s share of the food. A claim like “80% duck” is a powerful marketing image that may be interpreted by consumers as a proxy for nutritional dominance.
However, contrary to potential impressions, the food your dog receives isn’t 80% duck. The order of ingredients doesn’t to reflect the makeup of the food in the bag we buy; they are in descending order of wet weight (i.e. raw and before processing, including moisture content).
This is based on the ‘Mixing Bowl Principle’, which states: “Feed materials declaration is based on the weight/percentage at the time of their use in the preparation of the pet food.”.
“First ingredient” vs. processing reality
Given its high moisture content, fresh meat will most likely top most lists. However, as much of that water is lost during processing, the proportion of meat in the finished product will be far lower after processing than at its original wet weight.
To clarify: the USDA FoodData Central (FDC) database gives the following percentages for water in common proteins:
- Salmon, raw 65.8%[2]
- Chicken thigh, meat only, raw: 71.9%[3]
- Beef, ground, 80% lean meat / 20% fat, raw: 63.3%[4]
- Duck, wild, meat and skin, raw: 66.5%[5]
Most pet food, especially dry kibble, is cooked or extruded at high temperatures. During this process:
Fresh meat (often 70–80% water) loses much of its moisture, shrinking in weight
Meat meal (already dried and concentrated) retains more of its mass
Dry plant ingredients like cereals, legumes or protein concentrates retain most of their weight
So even if fresh duck is the first ingredient on the label by weight before cooking, it may end up contributing far less than the low-moisture ingredients (meat meal, cereals, legumes or plant protein concentrates) that retain most of their weight. This raises the relative post-processing position of those dry ingredients to a higher percentage in real terms than their position on the label suggests. In wet foods (moisture content of 60 % or more), the distortion of ingredient order is understandably less pronounced.
Example
A kibble might list “fresh duck” first, followed by “pea protein” and “maize flour.” Before cooking, the water in the duck gives it the weight advantage. After processing, the concentrated pea protein and maize flour may make up more of the finished food’s bulk or protein content. The list remains compliant, because the order reflects the weights before cooking – but is that the impression it gives?
Why does it matter?
The ingredient list tells you what went into the mixing bowl, not necessarily what goes into the food bowl we offer our dogs. Fresh meat at the top can still be a good sign – but remember that it’s there by pre-cooking weight, and that its position (and certainly any stated percentage) may not reflect its true share post processing.
Trying to make sense of the small print, one piece at a time.
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And here, for completeness’ sake, are the relevant rules:
From the Consumer Guide
From Annex 12: Pet Food Labelling – A Guide for Customers:
“The list of ingredients gives the composition of the pet food. Ingredients are listed in descending order by weight before cooking. This means that the ingredient which is present in the largest amount before cooking will be listed first. As some ingredients contain a lot of water, their position in the list does not always reflect the proportion in the finished product.”
The Code
“Feed materials shall be listed in descending order by weight in the compound feed before processing. The indication of the percentage by weight is voluntary except where required under Regulation (EC) No 767/2009.”
(FEDIAF Code of Good Labelling Practice for Pet Food, 2019)
The FEDIAF Code mirrors the Regulation but expands on it, clarifying that the ingredient list reflects the recipe at the time of preparation, not the finished product, and that indication of percentages is largely voluntary anyway.
This explanatory concept is borrowed from Art. 18(1) of Reg. 1169/2011 (human food), which states that ingredients are listed “in descending order of weight, as recorded at the time of their use in the manufacture of the food.”
That “at the time of their use” wording is the conceptual source “adapted” by FEDIAF as its basis for the “mixing bowl principle.”
The Regulation
(Regulation (EC) No 767/2009, Article 17 (1)(e))
- In addition to the requirements provided for in Article 15, the labelling of compound feed shall also include the following:
(e) a list of the feed materials of which the feed is composed, bearing the heading ‘composition’ and indicating the name of each feed material in accordance with weight calculated on the moisture content in the compound feed; that list may include the percentage by weight.
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References:
[1] Samant SS, Crandall PG, Jarma Arroyo SE, Seo HS. Dry Pet Food Flavor Enhancers and Their Impact on Palatability: A Review. Foods. 2021 Oct 27;10(11):2599. doi: 10.3390/foods10112599. PMID: 34828880; PMCID: PMC8622411.
[2] https://fdc.nal.usda.gov/food-details/2684441/nutrients
[3] https://fdc.nal.usda.gov/food-details/2646171/nutrients
[4] https://fdc.nal.usda.gov/food-details/2514744/nutrients
[5] https://fdc.nal.usda.gov/food-details/174468/nutrients
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!