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The Kennel

The Word “With” Is a Number

Four naming rules govern every pet food product name in America. Each one is a percentage, and the difference between them is enormous.

By D. Jackson II  · 

Two bags sit next to each other. One says Beef for Dogs. The other says Dog Food with Beef.

Those are not two ways of writing the same thing. They are two different regulatory categories with two different minimum beef contents, and the gap between them is not close.

The four rules

State pet food regulations, built on AAFCO model regulations, tie a product's name to how much of the named ingredient it has to contain. The thresholds are conventionally described as four rules.

The 95% rule. A name that is essentially just the ingredient — Beef for Dogs — requires that the named ingredient make up at least 95% of the total weight excluding water added for processing, and at least 70% including it.

The 25% rule, sometimes called the dinner rule. Adding a qualifying descriptor — dinner, entrée, platter, formula, recipe — drops the requirement. The named ingredient must be at least 25% of the product excluding added water, and at least 10% including it.

The 3% rule, the with rule. Dog Food with Beef requires only that beef be 3% of the product.

The flavor rule. Beef Flavor requires only that the flavor be detectable — no minimum percentage at all. Substantiation is about detectability, not quantity.

What that means at the shelf

Same word, four meanings, running from 95% to a trace.

A descriptor most shoppers read as marketing — dinner, entrée, recipe — is doing regulatory work. It is the difference between a product that is nearly all one ingredient and a product that is a quarter of it.

And with is the smallest word on most packages doing the largest amount of that work. Three percent.

Why a maker cannot simply choose

This runs in the other direction too, and that surprises people.

A product name is not a marketing decision made freely and then checked afterward. The formulation determines which names are legally available. A manufacturer whose product hits 95% cannot describe it in terms that invoke the 25% rule without misdescribing it, and one that reaches 30% cannot use the bare-ingredient name no matter how much it would prefer to.

State feed control officials review these names during product registration. That is the point in the process where a name that does not match a formulation gets stopped.

The quality claims are separate

Words like premium, super-premium, gourmet and holistic carry no required nutritional standard. A product using them is not required to contain anything different from one that does not.

Natural is different — it is defined. Under the AAFCO definition, feed or an ingredient must be derived solely from plant, animal or mined sources, unprocessed or having undergone processing, but not produced by or subject to a chemically synthetic process, and containing no chemically synthetic additives or processing aids.

Proven may not be used in a claim unless the claim is substantiated by scientific evidence.

Organic points outward — as defined, organic animal feed meets the production and handling requirements of the USDA's National Organic Program.

The practical reading

Read the product name first, and read every word of it, including the small ones. The name is the only part of a package where a specific number is legally implied.

The ingredient statement tells you what is present in descending order by weight. The guaranteed analysis gives minimums and maximums for a handful of nutrients. Neither tells you how much beef is in a food called Dog Food with Beef.

The word with does.

Naming rules as set out in the AAFCO model regulations for pet food and specialty pet food. AAFCO writes model regulations; individual states adopt and enforce them, and requirements vary by state. No brand names are used in this piece by design.