DRAFT

Organic Pet Food

Tom Hutcheson

Associate Policy Director

October 12, 2004

 

Background 

OTA, in consultation with member pet food companies, formulated its guiding principle several years ago:  pet foods should meet human food standards, with the exception that synthetic forms of nutrients required for various species should be allowed, whether or not they were specifically allowed for human foods.  This was seen as analogous to the allowance given in the livestock standard in Sections 205.603(d)(1) and (2).

One difficulty with proceeding at the time stemmed from the conventional pet food industry “made with” label claim standard of only 3% (i.e., “made with real beef” means there must be a minimum of 3% real beef in the pet food).  When a proposal for organic pet food to meet the NOP rule was floated to the American Association of Feed Control Officials in 2001 by Mark Keating of the NOP, the pet food industry was unwilling to allow a “made with” claim of 70%.  Even so, USDA Undersecretary Bill Hawks wrote a letter on March 20, 2002, stating that the NOP had the authority to create standards for organic pet foods.

NOP’s 2002 statement on the scope of the Program proposed that if a product was able to be certified under the Final Rule, it would be allowed to be certified.  The 2004 statement on NOP scope removed this provision, casting doubt on the various pet food lines that had been developed, or that were being developed at that time.  OTA understands that although the official statement of NOP thought on the scope of the program has been rescinded, NOP still believes that until specific standards have been set for pet foods, the fact that a pet food meets the Final Rule is insufficient evidence that it may be certified as having been organically produced.

NOP has recommended to OTA that OTA propose a standard for organic pet foods.  After an internal process, an OTA task force drafted the proposal for a rule change below, with certain caveats, including debating the potential value of a new pet food section in the rule.  Please note that the recommendation below is not yet an official proposal from OTA.

Please note that while OTA is comfortable moving forward with this process, OTA continues to believe that products compliant with the rule should be allowed to be certified.

Industry Background

The following data is from Nutrition Business Journal estimates based on OTA’s 2004 Manufacturer Survey, annual Nutrition Business Journal surveys of manufacturers, SPINS, and other sources.  Sales of organic pet food grew significantly in 2003, up 64.5% from 2002. Organic pet food only accounted for 0.09% of total pet food consumer sales and this category represents good potential for penetration growth.

Total and Organic Pet Food Consumer Sales and Penetration, 2002-2003

According to OTA’s 2004 Manufacturer Survey respondents, organic pet food categories are forecasted to experience modest average annual sales growth of 17% during the 2004-2008 time period, roughly comparable to the many much-more-developed food categories.

With $14 million in last year’s sales and strong recent growth, organic pet food is a significant sector within the organic industry and deserves to enjoy the same regulatory oversight as organic food and animal feed.  This rulemaking will create a stable regulatory environment and a firm foundation for consumer confidence.

Recommendation and proposed changes

OTA member pet food producers unanimously agree that organic pet foods should be produced and labeled in accordance with human food standards, with the consideration that certain additional nutrients should be allowed, including vitamins, minerals, and amino acids that meet the nutritional requirements of various pet species, including those appropriate for the pets’ stages of life.

OTA recommends the following changes in the NOP Final Rule:

Add a new § 205.300(e):  “Pet foods produced in accordance with the requirements in this part must meet the requirements of 205.301(a), (b), (c), (d), and (f).”

Add to the list under § 205.605:  “Vitamins, trace minerals, and essential amino acids for pet foods in accordance with AAFCO nutrient profiles.”

Thank you very much for your consideration.