The language of labelling

Part One

We all want the best for our dogs, and part of that means knowing what they’re eating, understanding the ingredients in their food and how they’re prepared. And, perhaps just as importantly, being aware of what marketing tactics are permitted in the pet food industry – and how they’re employed.

Industry practices and the vagaries of labelling make it nigh on impossible for dog owners to navigate the market and understand the true nutritional content of what’s on offer. Packaging prioritises marketing appeal over clarity – we are lured by a blur of competing claims tempting us from a dazzling array of bags, one more brightly coloured than the next. We deliberate and cogitate, with our dog’s best interests at heart. But how can we make a decision if we don’t have all the facts?

The core issue is that the labelling system is designed to satisfy compliance and protect recipe details, not to provide a transparent tool for the consumer. Consumer guides are available, although the ‘official’ versions I found appear to have been written through the lens of the manufacturer, rather than a general consumer: the ‘person having ordinary skill’, the ‘reasonable person’, who has no deep knowledge of industry practices. Even those of us armed with knowledge can never know the full content of a commercial food.

I’ve been looking carefully at the guidelines because (a) I am still feeding my dogs some commercial products and (b) I’m interested in canine dietary requirements and how to meet them. Before delving into this, I had assumed – being mindful of rules on human food – that pet food sold in the EU or UK would be quite tightly regulated. But pet food labelling is a very different story: regulations are more relaxed, with some notable gaps.

There were some quite startling discoveries along the way, things unknown even to more experienced dog owners that I spoke with. Some of our natural and understandable assumptions – inferred as they were from brand, price, marketing language and labelling – were misplaced. But interestingly, and perhaps unsurprisingly, our assumptions were largely similar. Hmmm.

Code of good practice

In Europe, the Code of Good Labelling Practice for Pet Food was drawn up by the FEDIAF (the “voice of the European pet food industry”) in accordance with Regulation (EC) No. 767/2009[1]. That overarching regulation, intended to harmonise the approach across Member States, provides for the establishment of a (self-regulatory) code to “improve the appropriateness of labelling and in particular to include provisions on voluntary labelling aspects and claims”. When does self-regulatory mean marking your own homework?

There isn’t a great deal about the consumer or understanding, in any event. Regulation 767/2009 states that “Codes should lay down provisions that would enable the purchaser to make informed choices. They should also give the person responsible for the labelling important guidance on different elements of the labelling.” Another hmmm.

Pet food labels shall not mislead, confuse, exaggerate or deceive either directly or indirectly or by implication.[2]

A pet food label rarely – if ever – presents the full picture of what’s inside: producers may opt to declare ingredients either individually or by category; substances used in processing may not appear on the label if they are no longer deemed to have a “technological function”; others may be listed only by functional class (e.g. antioxidants, colourants, preservatives), without naming the actual compound; quantitative ingredient declarations aren’t always mandatory; and manufacturers are permitted to balance “consumer transparency” with protection of proprietary formulas. At their own discretion.

Perception

There’s a distinction between perception – “the law is protecting us (and our animals)” – and reality: “the law gives an industry discretion on how much it tells us.”

The text of Article 17 on Labelling and Presentation governing the description of the feed and preventing misleading  –  perhaps the umbrella article for all other parts of the code – says this:

“The labelling and presentation of feed shall not mislead the user, in particular:

 > (a) as to the intended use or characteristics of the feed, in particular the nature, method of manufacture or production, or properties of the feed;

 > (b) by attributing to the feed effects or characteristics it does not possess…”

 

The language of labelling needs close reading. It’s important that we understand not just its vocabulary and rules, but particularly its potential and permitted omissions.

This is the first in a series of short articles on the language of labelling. Of “complete”, not “complementary” foods. Because the rules for complementary foods are different (and far less stringent).

Next: Duck flavour. No duck.

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

*****

References:

[1] REGULATION (EC) No 767/2009 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 13 July 2009 on the placing on the market and use of feed, amending European Parliament and Council Regulation (EC) No 1831/2003 and repealing Council Directive 79/373/EEC, Commission Directive 80/511/EEC, Council Directives 82/471/EEC, 83/228/EEC, 93/74/EEC, 93/113/EC and 96/25/EC and Commission Decision 2004/217/EC

[2] REGULATION (EC) No 767/2009 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 13 July 2009 on the placing on the market and use of feed. Article 14 (1)

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!