ATLANTA — With a rise in pet ownership, human-grade pet food has become a hot topic in the industry. And it was no different at the International Production and Processing Expo (IPPE) this January. During IPPE, the American Feed Industry Association (AFIA) held its Pet Food Conference, in which Carolyn Kennedy, an independent consultant at EAS Consulting Group LLC, shared her insight on the human-grade sector of the market.
Kennedy currently works with pet food companies on product development and pet food formulation, providing nutritional support, organizing lab testing, analysis and procedures to ensure that new products meet the Association of American Feed Controls Officials’ (AFFCO) guidelines. According to her, the human-grade trend won’t be leaving any time soon.
Although Kennedy has seen a growing interest in human-grade pet food, she also acknowledged there are several challenges that deter some companies from entering this growing area.
The first among many challenges is finding a facility to process human-grade food. Kennedy explained there are many pet food facilities out there but finding a facility that can produce pet food and meets the US Food and Drug Administration’s (FDA) regulations for human food can be very difficult.
“There are pet food plants and human-grade plants that you could use all around the world. But you can only call it human-grade if it's an FDA human-grade-approved facility in the United States,” Kennedy said.
Before a company even begins to formulate a human-grade pet food, it must ensure every facility in which the food is processed, stored and even transported meets regulations set by the FDA and the state.
“The FDA listed out the requirements for human-grade pet food in its Code of Federal Regulations (CFR) Title 21 Part 117,” Kennedy added. “It’s the starting point and covers everything from storage and handling to everything involved in the facility, and then you have state requirements on top of that. Before you even start developing the formulation, if you were lucky enough to find a facility that can make your human-grade pet food, make sure that the facility has a copy of the license or permit stating that it complies with part Part 21 under CFR… Without that license, your project can't really go anywhere.”
Regulations don’t stop at the facilities, though. When it comes to developing the food and shopping for ingredients and ingredient suppliers, manufacturers need to prove all ingredients are human grade.
“You also need [a] letter and affidavit from each individual ingredient supplier… that states that each ingredient is human edible,” Kennedy added. “These letters have to [state] that you accept and guarantee the product is completely human grade.”
Kennedy added there is no middle ground in creating human-grade pet food; it’s either 100% human grade or its not human grade at all. But sourcing human-grade ingredients can also be extremely difficult, since the ingredients are meant for human consumption, meaning supply could easily become an issue. These ingredients also tend to come with a hefty price tag.
“The cost of the ingredients can be very high, and our food prices are going up,” Kennedy explained. “And if the pet food is human grade, then it stands to reason that those prices will be increasing. The supply [of ingredients] is also an issue… Supply of our food is getting very tricky right now, and that's the same for pet food as well. When you're trying to put human-grade ingredients into pet food, it only makes sense that supply will be difficult.”
Even after finding human-grade ingredients, formulating them into pet food can pose an issue, especially when it comes to palatability.
“…From a formulation perspective… palatability is very challenging,” Kennedy said. “I have my go-to palatability enhancers that I use in pet food products that I know just blow the flavor out of the park. I can put together the best formula, but if a dog sniffs it and doesn't eat it or a cat just walks away, nobody's ever going to buy that food. Getting the palatability right in human-grade pet food, when I can't use some of my tried-and-true tested palatability enhancers, is a challenge.”
Once the formulation works and processing begins, companies may think they’ve overcome all obstacles that come with human-grade pet food. That is, until the time comes for labeling and marketing. Kennedy claimed this step in creating human-grade pet food is where she witnesses the most mistakes.
“When it comes to labeling human-grade pet food, the product must be clearly labeled for its intended use,” she explained. “The labeling rules are exactly the same for pet food that is not human grade and pet food that is human grade. It all has to follow the AFFCO pet food labeling rules, and the statement of intended use must be clearly displayed on [the packaging].”
Though stating the intended use may seem simple enough, there are strict regulations about what can and what cannot be said on packaging.
“The statement of human grade can be no larger than the statement of intended use,” Kennedy added. “Another aspect of human-grade labeling is that every time you mention human grade on [the packaging]… the intended use statement has to go right after it. In the first example, ‘human-grade dog treats’ is fine, that could go on the front of the packaging. Then, in the first mention on each other area of the packaging, if you put ‘human-grade’ a lot larger than ‘dog treats’, that's where it doesn't work.”
Other packaging regulations become an issue when companies try to highlight certain ingredients as human grade. Kennedy added that some companies want to add “human-grade” before an ingredient, usually meat, but this creates a problem. Highlighting an ingredient as “human-grade” on packaging becomes misleading; consumers may believe only certain ingredients are human-grade. If there’s one ingredient that is not believed to be human grade, then the entire product is not human grade at all.
“You cannot have statements of quality in the ingredient list,” Kennedy explained. “The same as with any other pet food.”
With all the numerous regulations, the paperwork, the sourcing of ingredients and facilities, the testing, and research and development, many companies may ask why they should consider human-grade pet food as an option. The answer: increasing demand.
“In 2020, the global pet food market went up to almost $94 billion,” Kennedy said. “Dog food products made up about 60% of the total sales, and cat food and other pet [food made up] the other third…. The sales of refrigerated and frozen pet food, where a lot of these human-grade products lie… went up 29% [in 2020] from 2019… That tells me that a lot of people are looking to switch to this new category of pet food.”
On the other hand, some ingredient suppliers and processors in the pet food and treat space are skeptical of incorporating human-grade ingredients into pet diets based on another accelerating trend: sustainability. Sourcing human-grade ingredients could be seen as a contradictory move in advancing the industry’s sustainability, as it could cause imbalances in the already dynamic supply chain, lead to more food waste, and ostracize sustainable ingredient sources already leveraged by the industry, such as animal byproducts or upcycled ingredients.