AAFCO, FEDIAF, and NRC Nutrient Guidelines

There are three different nutrient guidelines NRC, FEDIAF, and AAFCO.  Before comparing them, it’s important to discuss the history, the guidelines themselves, how they were developed and updated, and criticisms of the guidelines.

Before the Guidelines

The first dog food was developed in the 1860s by an American electrician James Spratt living in London.  Ken L. Ration came around after World War 1 with canned horse meat as horses were no longer needed for the war. Commericial Dog food truly took off in the 1930s.

One thing most people forget or fail to acknowledge is that dogs and cats were dying from various health issues. Part of the problem comes from the fact that people remember the family dog that lived into old age; they do not remember as well the dog that only lived for 5 or 6 years. This is not done on purpose. It is just part of the way memory works. So, whenever you hear someone say dogs used to live much longer, know that part of this comes from an error in our memories. A good comparison would be how people can remember their favorite elementary school teacher while they forget most of them.

It is not like dogs were living into ripe old age. It is not like they did not have health problems. We don’t truly know how many dogs were dying from cancer, heart disease, or many other ailments. Many people would like to suggest that dogs were living much longer and that they were much healthier. When this isn’t truly the case.

The guidelines were first developed in the 1960s. Now, these guidelines were in large part based on research for other animals. The second edition was published in 1974. More and more research was explicitly conducted on dogs and cats in the time between the second and third NRC guidelines. The third editions were published in 1985 and 1986. The next and latest update was in 2006. I think we can all agree that it is well past time for a new update.

Criticisms of the Guidelines

Many people criticize the guidelines for various reasons. I feel like some of the criticisms are warranted, while others come from a misunderstanding.

“Although the AAFCO Profiles are better than nothing, they provide false security. I don’t know of any studies showing their adequacies or inadequacies.”– Dr. Quinton Rogers

This quote has been floating around. It has been used in many blogs, books, and groups. The quote is from Dr. Quinton Rogers. He was one of the early pioneers of dog and cat nutritional requirements. He helped develop the NRC Guidelines and was on the panel to develop some of the earlier AAFCO Nutrients Panels.

To truly understand the quote’s reasoning, you would have to read a paper that he wrote with Dr. James G. Morris. Assessment of the Nutritional Adequacy of Pet Foods through the Life Cycle. As we all know, short quotes without proper context can easily be misunderstood. The paper helps give the quote proper context.

What I think he was talking about wasn’t that the profiles are wrong, but that feeding trials were the only way to substantiate the claim of complete and balanced. The reason being that there wasn’t good information on digestibility, and the interaction, and influences of specific ingredients, that there was a wide variance in nutritional data about raw ingredients. There are the effects of different processing methods. That means the only way to see if a diet is actually “working” is to conduct feeding trials.

It should be noted that to this day, many companies do not conduct feeding trials.

Now in an ideal world, all companies would conduct feeding trials. However, most foods are relatively similar. So, I am slightly more forgiving if they do not conduct feeding trials.

However, there are many new foods coming out with entirely novel ingredients such as crickets, soldier fly larva, lab-grown meats, and yeast. There are Ketogenic diets, there are Vegan diets. For these ingredients and diets, I think it is even more imperative that they conduct at the very least AAFCO feeding trials. However, ideally, the tests would go beyond AAFCO feeding trials. 

Side Note

As I said before, Crickets are not approved; some of the other ingredients included are not approved for use in animal foods. While I do not have a problem with them being included in treats, we should be more cautious if they are a major part of their diet.
The industry is still dealing with the fallout from DCM. Is it really the best idea to go down a completely uncharted path with these ingredients and diets?

Now even a 26-week feeding trial is ultimately inadequate. The tests required aren’t going to necessarily show if the diet is deficient long term. For example vitamin a can only be detected after it has depleted the stores in the liver. The only way to truly measure a diet’s effects is with lifelong studies and even generational studies.

Think of the epigenetic effects of the Dutch Hunger Winter. While the effects may not be as pronounced with minor nutritional deficiencies they could still have an impact.

However, Life long and generational studies would be extremely expensive and not exactly practical.

The quote from Dr. Rogers comes from 1993. Yet it is still used today 28 years later. Some of the people who reference the quote probably don’t realize it is from 1993.

With that being said, the AAFCO, NRC, and FEDIAF guidelines have all changed since then. Technology has improved exponentially, and more research has been conducted. The ability to measure ingredients’ digestibility and the analysis of ingredients is far better than 30 years ago. It is far better than it was even ten years ago. However, you never know how all of the ingredients are going to work together until they are actually tested. That is why feeding trials are still the ideal way to test to make sure that the diet is “working.”

We don’t Eat a Complete and Balanced Diet

One argument against feeding a complete and balanced diet is that we don’t eat like that ourselves, or we don’t feed children in that way.

This argument is kind of laughable as if the human diet is anything that we should aspire to for our pets. We all know that many of our diets are terrible. We know how common many health issues are in humans. This also ignores the fact that human diets are still different based on culture and geography.

Asditionally many of the foods we eat are fortified or enriched with essential vitamins and minerals such as folate, niacin, riboflavin, thiamin, vitamin A, vitamin B6, vitamin B12, vitamin D and vitamin E, calcium, iodine, iron, selenium and zinc. 

87 countries have legislation to mandate fortification of at least one industrially milled cereal grain.In

In the US see 21 CFR § 130 through 21 CFR § 169 to see which foods are required to be fortified and which foods are optional. For example Margrine is required to be fortified with Vitamin A.

Many people also take multivitamins. If many of the foods we eat were not fortified it is likely that many more people would suffer from nutritional deficiencies.

Many people do however, acknowledge that they feed their dog or cat better than they feed themselves.

If you wanted to compare it to the diet of many elite athletes, or the diet of those undergoing certain treatments where the diet is carefully formulated, or what we should probably eat like, the argument would carry more weight.

But to the argument itself. Our Dogs and Cats live nowhere near as long as we do. Our Puppies and Kittens have a significantly shorter growth period. So, any nutritional imbalance over a set period of time is likely to have a greater on them than it would on us.

Development of the AAFCO NRC FEDIAF Guidelines

One thing to be aware of is the NRC Guidelines were developed using purified ingredients. The reason being that digestibility and availability is uncompromised. This does not apply to pet foods, as uninhibited or near perfect availability, or digestibility can’t be assumed with typical pet food ingredients. It also shouldn’t be fully assumed for human-grade ingredients used in raw or gently cooked foods.  

Both FEDIAF and AAFCO are based on the NRC Guidelines.

This is why if you look at the AAFCO or FEDIAF guidelines, they are often higher than the NRC. They are higher to account for complex interactions and less bioavailability of various nutrients.

One major difference between the FEDIAF and AAFCO guidelines is that FEDIAF has standards for 95 kcal ME/kg^0.75 and 110 kcal ME/kg^0.75 for dogs or 75 kcal ME/kg^0.67 or 100 kcal ME/kg^0.67 for cats.

I personally prefer FEDIAF approach especially considering The fact that certain breeds require fewer calories to maintain a healthy body weight.

All three guidelines are designed to broadly meet the needs of most dogs and cats. It may be theoretically impossible to meet the needs of every individual dog or cat.  Every dog and cat is different. They have different energy requirements, activity levels, and lifestyles.

Raw Fed Dogs Need Less Due to Greater Bioavailability”

One argument that I have seen is that dogs require less when eating raw food due to the increased bioavailability of various nutrients.

People often cite that the poop is smaller as evidence. One issue that is commonly overlooked is the difference in fiber content.

Now, this may be true of some specific nutrients; the question is which ones, and to what extent.

However, if we grant the premise, it would probably only apply to the AAFCO or FEDIAF guidelines, which were modified for the reasons explained above.

The issue that you run into if you decide to follow the NRC guidelines is they were last updated in 2006. There has been more research since 2006, and the AAFCO and FEDIAF guidelines are updated more frequently to adjust based on new science and understanding.

So by relying on 2006 NRC guidelines, you are basing some nutrient data off of information that should have been updated by now.

The NRC guidelines are also slightly more complicated. The footnotes and text are ulitmately as important as the actual tables themselves.

“The proposed minimal concentrations and amounts of vitamins are the total bioavailable forms of the vitamins present in the diet (contributed by natural ingredients and vitamin premixes) at the point of consumption. Because the natural forms of some vitamins have low bioavailability, the proposed amount will generally be adequate when the majority of that vitamin is from a vitamin premix. However, when a vitamin is contributed mainly by food ingredients, the minimal concentration in the tables should be modified to account for bioavailability by using a suitable factor.”(NRC 2006)

For example, while the NRC recommended allowance for taurine is .4g/kg, if you look to the footnotes you will see:

“The recommended allowance of taurine for highly digestible purified diets is 0.4 g kg diet, whereas the allowances for dry expanded and canned diets are 1.0 and 1.7 g/ kg diet, respectively.” (NRC 2006)

This is the same as the AAFCO guidelines for dry food, but lower for wet food.

“The quantity of tyrosine required to maximize black hair color may be about 1.5-2.0 times this quantity.” (NRC 2006)

If you only look at the tables, you miss essential information.

Nutrient Guidelines for Raw Food

Now truly developing separate guidelines for raw foods or gently cooked foods may be a lesson in futility or an impossibility. One reason is there are variations between one cow or rabbit and the next just as there is a difference between a grass-finished cow and a grain-fed cow.

It would be impossible to control each and every specific Amino Acid, Vitamin, Mineral, Fat. Scientific research requires control to be in place, so you don’t misidentify what is causing something. This is why they used purified ingredients. With raw food, you would have to go off of the average composition data for each ingredient. You couldn’t have proper controls in place. This can give you a relative baseline, but you would have a much lower confidence interval than if you used purified ingredients.

Why it is important to follow the Guidelines.

Now, none of this means that the guidelines are perfect or 100% accurate. They are a starting point. They will never truly be perfect. Science and information are constantly evolving. We are always learning.

Some of the research is fairly old, some of it may rest on some shaky research, some of the studies may not be 100% accurate, but that doesn’t mean we should ignore them. It means we need to continue to improve and refine them.

Many dogs and cats suffered and had to be put down to gain that information. Their lives were sacrificed to gain that information. They suffered so that we could better understand their unique nutritional needs. When we ignore the guidelines, then we are ignoring their sacrifice.

If you consider Pascals Wager, there is little risk in ensuring the foods meet the minimums. There is an increased cost in time and money, but on the opposite side of the equation, there are the risks of causing minor or major nutritional imbalances over time.

Nutritional imbalances/deficiencies don’t necessarily show up on blood work.  Many of them don’t manifest signs until well after the damage is done. For example changes in blood levels of vitamin A only become visible after the liver stores are depleted. Prior to this, only a liver biopsy can reflect the actual supply level. We all want our pets to live for as long as possible and meeting the minimums is the least we can do to ensure that.

For breeders this is even more important as minor nutritional imbalances or deficiencies could have epigenetic effects. I personally feel that the additional time and money is worth ensuring the diet meets the minimums. 

Now that doesn’t mean feeding a complete and balanced diet won’t at some point lead to a deficiency. That is why we preach about rotating not just foods but treats chews and food toppers as well.

In a paper published in 2018 on DCM in Golden Retriever the researchers found that the owners of 22 of the 24 dogs were feeding the same food for a minimum of 182 days (6 Months) a max of 3558 days (9.5 Years) with the median being 814.5 days (2.31 Years). One owner did not report the length of time while the other remaining owner said several years.

By rotating foods you are giving your dog a wider range of nutrient levels. Every dog and cat is ultimately different. The guidelines for the most part are minimums designed to meet the average dog. The average dog or cat however doesn’t exist. This is why we recommend not just rotating within a single brand but rotating brands as well. That way, your dog or cat gets a wider range of nutrient levels. No food is truly going to be adequate when fed month after month year after year. Every brand has preferences when formulating their foods.

Another benefit of rotating brands is that in the event of a recall, you have other options that you know your dog or cat does well on and is also palatable.

The Researchers who helped develop the NRC guidelines each had decades of experience researching canine and feline nutrition. Some of them like Drs. Rogers and Morris were some of the pioneers in researching the nutritional needs of dogs and cats.

According to Scopus (which is by no means complete), Dr. Quinton Rogers published 301 papers and has been cited 6600 times. Dr. James G. Morris published 156 Papers and has been cited 3371. Dr. Ellen Kienzle has published 177 Papers and has been cited 2149. Dr. John Bauer has written 126 papers and has been cited 1815 times; these reflect some of the most frequently referenced authors in the field of pet dog and cat nutrition. These are just a few of the people that were involved in developing the NRC Guidelines.

Updating the Guidelines

The NRC guidelines were last updated in 2006, and before that, the last update was 20 years prior. The AAFCO and FEDIAF guidelines are updated more often, but neither is ultimately free from industry influence. 

If we want more research done to update the guidelines, if we want the NRC to update the guidelines more often, then we need to push our politicians to use our tax dollars to fund research and fund updating the guidelines.

As pet parents, we are a sizable majority. This is something we should all agree on no matter where you lie on the political spectrum.

There are foundations such as the Morris Animal Foundation, and they do fund some research. However, they don’t have the resources to fund the amount of research required.  

Unfortunately, Government funding of research is one of the first things on the chopping block every time there is a budget cut, and the number rarely ever increases especially when accounting for inflation.

Even more to the point, where funding is concerned our dogs and cats are one of the lowest on the totem pole. Livestock are a far higher priority, and thus research for dogs and cats receives significantly less funding. The amount of research for dogs and cats is dwarfed by the amount of research for cows or chickens. The FDA, State Feed Organizations, AAFCO at the end of the day are all far more concerned with them than our dogs and cats.

In an ideal world, the FDA would have a department dedicated specifically to our companion animals instead of lumping them in with livestock. Because ultimately, the goals for our companion animals are different than that of livestock.

This means pushing our politicians to fund research specific to our dogs and cats. It means creating a department explicitly dedicated to companion animals.  

While everyone wants to criticize the fact that pet food manufacturing companies are funding research, they are really the only ones funding research.

If we were to look at all the studies conducted on black soldier fly larvae, or crickets as new ingredients, I’m sure a portion – possibly a significant portion – was funded by the big kibble companies.

All Companies are ultimately the primary user(s) of the research, whereas our pets are the beneficiaries.

Research, unfortunately, suffers from a Free Rider problem where all companies benefit from the research conducted, but no one wants to fund the research. It is not like companies aren’t relying on the research funded by other companies.

Ultimately, if we want raw feeding to be more widely accepted, more research on raw foods needs to be conducted. Anecdotal evidence is not enough. We need to be pushing the raw food companies to actually start funding research. There is no reason why many of the raw food companies can’t fund research. Many of them have extremely large marketing budgets, some are VC funded. They could easily divert a small percentage of their marketing budget to funding research. The companies could even pool resources to fund research, as they would all benefit from the research. This is an extremely unlikely scenario.

If we want more research conducted, we ultimately need to be pushing both the government and companies to fund more research.

Now there is one thing that needs to be considered, and that is new research is likely to only slightly shift the guidelines. There is a cost in subjecting countless dogs to experimentation to further develop the guidelines. With that in mind, research should be very precise in what nutrient(s) need to be reanalyzed using modern technology. At the same time, that doesn’t mean we aren’t able to learn more, or that we can’t further refine the guidelines.

One researcher recently published a paper looking at copper in dog diets, Is it time to reconsider current guidelines for copper content in commercial dog foods?, arguing that it is time to reevaluate the recommended and maximum levels of copper. More research is looking at DCM, and it’s possible that taurine may eventually be listed as a requirement for canine breeds predisposed to developing DCM. More research is looking into the Atwater and Modified Atwater Factors which are used to determine metabolized energy of foods.

The guidelines are ultimately never going to be perfect. Every dog is different. Many factors need to be considered. For example, research shows a wide variation in the number of copies of the AMY2B gene, which influences amylase, and therefore the ability to digest carbs.

More research needs to be conducted for breeds and dogs that require fewer calories to maintain body weight. The implication being that they may require more nutrient dense foods.

Dogs Aren’t Living Longer is Nutrition to Blame?

Now, many people argue that our dogs aren’t living longer. They are suffering from many health conditions. While some of this is true, we don’t honestly know what the previous numbers were.

The whole blame cannot be placed on nutrition. While nutrition may play a role, there are many other factors. There is the amount of exercise a pet receives. Canine and Feline obesity is rising. There are environmental factors, genetic factors, issues of Genetic Diversity in many breeds. There is much more evidence that many diseases have a genetic factor. Its possible that the current guidelines are still causing minor nutritional imbalances that are having an epigenetic effect.

Spaying and Neutering may help lower the risk of certain types of cancers, it may have helped lower the number of dogs that end up in shelters, but it also has other effects such as obesity and bone and joint conditions, and it could have many more. Dogs weren’t spayed and neutered at the same rate even 30 years ago. Today estimates are at 85%.

There are the potential impacts of over vaccinations. Many vets have been raising the alarm about the effects of vaccines on the health of our dogs and cats. Not that vaccines are necessarily bad, but more so about the dosage and frequency. Ie a Great Dane and a French Bulldog receiving the same size dose. The fact that many of the vaccines have been shown to last far longer than when dogs and cats are required to be revaccinated. 

The lifetime golden retriever study has already provided valuable insights, and it’s only in its ninth year. It should provide more useful information in the years to come.

All of these factors need to be further investigated and addressed. Some of these factors may also have an epigenetic effect.

Many of the health conditions we are seeing are multifactorial. That means addressing one issue will not solve the problem. It requires addressing the other factors involved, whether it is genetic, obesity, environmental, etc.

Unfortunately, nutrition, exercise, obesity, Spay/Neuter are the only things under our direct control. 

Now one thing that should be done is we need to shift the conversation away from minimal or adequate to what is optimal. What are the ideal nutrient levels? What levels helps our pets thrive not just survive. What levels lower the risks of various health conditions? What levels help our pets live longer?

The Recommend allowances developed by the NRC are a step in that direction, but much more is needed. It should not take 20 years for the nutritional guidelines to be updated when there hasn’t been a significant increase in the life expectancy of our dogs and cats. This is a clear sign that more research is needed.

Now there’s another thing I want you to remember. I don’t want to get any messages saying that we are holding our position. We’re not holding anything. . . . We are advancing constantly and we’re not interested in holding onto anything except the enemy.

General Patton

We should not accept good enough. We should not be resting on the current standards.

We should always be seeking to further improve the health of our dogs and cats, and this means further refinement

We as pet parents, and our Veterinarians, need to shift away from reactive to proactive medicine. Instead of waiting until our dogs have arthritis, we can give them various supplements to possibly help delay the onset of arthritis. We all need to be more proactive instead of just reactive.

If we are to see improvements, we need to shift the conversation away from mere survival to thriving. The discussion around carbs often boils down to do dogs or cats need carbs to survive instead of can certain carbs be beneficial. We need to change from the minimum to prevent deficiencies to a better defined optimal level.

While we are limited in what we can do for our current dogs and cats, we do owe a duty to all future dogs and cats to improve their health so that they don’t have to suffer in the same ways our current pets do. That means we as a society need to be addressing the other factors that aren’t under our direct control.

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