Understanding AAFCO’s Decision Against Voluntary ‘Controlled Copper’ Claim in Dog Food

copper storage disease in dogs

On May 30, 2024, the AAFCO Pet Food Committee (PFC) reviewed the findings and the proposed voluntary language from the original expert panel, the notes from the copper workgroup, and feedback from veterinarians, animal nutritionists, consumer groups, and the general public, but ultimately failed to reach a consensus and voted “no” on the proposed voluntary “Controlled Copper” claim language. AAFCO will continue to monitor new scientific literature as it becomes available and may consider the topic again in the future if additional data warrants another review.

AAFCO

Unfolding the Ongoing Crisis

This decision follows extensive research and discussions that began in February 2021, prompted by an article published in the Journal of the American Veterinary Medical Association (JAVMA). The article addressed concerns regarding the current AAFCO nutritional guidelines for copper in dog foods.

AAFCO assembled an expert panel to examine the veterinary literature and assess the feasibility of establishing a safe upper limit (SUL) or maximum tolerance for copper in dog food. The panel concluded that there was insufficient data to establish such a limit at this time but proposed voluntary language for a “Controlled Copper” claim.

A subsequent Copper Claim Workgroup further reviewed the proposed voluntary “Controlled Copper” claim language and additional guidelines for copper in dog food, addressing concerns and feedback raised by pet owners and veterinarians.

The proposed voluntary “Controlled Copper” claim would indicate that the dog food is nutritionally adequate for one or more life stages in accordance with AAFCO’s Model Regulations for Pet Food and Specialty Pet Food;
• contain a maximum of no more than 15 mg copper/kg DM and no more than 3.75 mg copper/1000 kcal of metabolizable energy;
• and bear a Guaranteed Analysis on its label in accordance with the model regulation guarantee for the maximum amount of copper in the dog food.

A claim “low copper,” “low in copper,” or words of similar designation is not allowed.

During the Meeting

During the May 30, 2024 meeting, the PFC convened to address this significant issue concerning copper concentrations in dog food. The primary focus was on this proposed regulation intended to manage and label copper levels in commercial dog foods. This discussion was prompted by the findings published in 2021, indicating an increase in copper concentrations in dog liver samples, attributed to higher copper content in dog food. An expert panel was formed to evaluate these findings, leading to the development of a draft model regulation aimed at creating a ‘controlled copper’ claim for dog food labels.

The proposed regulation  specific guidelines for dog food manufacturers to follow, as outline above, were if they wished to use the ‘controlled copper’ label, including substantiating the nutritional adequacy of their products, adhering to maximum copper content limits, and ensuring clear labeling in accordance with existing regulations.

Throughout the meeting, various experts and stakeholders shared their perspectives on the complexities and implications of this proposal. Despite the rigorous discussion and the collective effort to reach a consensus, the motion to accept the draft model regulation ultimately failed. This outcome means that the proposal will not advance at this time, leaving the issue unresolved unless revisited by the PFC in the future. There were concerns about the existing low copper prescription diets, and there appeared to be interest in amending the language to permit a low copper claim in these formulations.

The meeting highlighted the importance and challenges of regulating copper intake in pet foods, reflecting a broader commitment to pet nutrition and safety.

Meeting Highlights: A Summary of Key Points
During the meeting, Mr. Stan Cook (Vice-Chair, MO), remarked that, “this was one of the more complex and interesting issues in the pet food committee”. His observation was highly validating.

I couldn’t agree more with David A. Dzanis, DVM, Ph.D., DACVN, when he spoke up and said that we can appreciate the science, but we have to start somewhere, and this is a voluntary claim. I believe that every measure taken to regulate copper intake holds significance, and prompt action is essential.

"This was one of the more complex and interesting issues in the pet food committee”.

The AVMA did not support this measure.

While the FDA articulated their position clearly, they opted to abstain from voting. I found their remarks particularly insightful and well-considered.

I found it noteworthy that Dr. George Collings, (Pet Solutions Group, Consultant) highlighted the challenges associated with setting a maximum limit for copper as a nutritionist formulating for AAFCO. Despite extensive efforts, and the wide bioavailability of copper, a definitive conclusion was not reached. This is the reason behind the absence of a safe upper limit for the nutrient copper.

Additionally, I learned that FEDIAF standards are based on environmental factors rather than scientific data specific to pets. Therefore, adopting their suggested SUL would be based on an arbitrary figure.

These were just some of the key points I found most compelling.

“And dogs will continue to die from copper associated hepatopathy...”

Although the conclusion was disappointing, it was a well-fought effort. The motion failed, and the draft model regulation was not accepted. As it stands, the proposal will not progress unless the PFC revisits it, and the sense of disappointment was palpable. 

“And dogs will continue to die from copper associated hepatopathy,” wrote Cynthia Leveille-Webster, D.V.M., DACVIM (SAIM) as we left the virtual room. A distinguished veterinary internist specializing in Small Animal Internal Medicine (SAIM), a Diplomate of the American College of Veterinary Internal Medicine (DACVIM), Dr. Leveille-Webster brings an extensive wealth of knowledge and experience to the forefront of veterinary medicine.

Here’s hoping they reconsider picking it up as an interest, as it will not be moving forward.
I eagerly anticipate what the future holds as these developments hold promise for enhancing our understanding and management of this condition within the framework of evidence-based nutrition and scientific research.

Canine copper-associated hepatopathy (CuAH) is recognized with increasing frequency, while growing studies are demonstrating it is possible that a dietary ingredient, copper, plays a role due to several industry changes, which may give answers to those with an unknown etiology. Now, our story, once unique and rare, is not just an isolated case but rather a part of a growing recognition of CuAH.

Renowned veterinarians advocate their evidence to support recommendations to reexamine dietary copper for dogs and reconsider current guidelines for copper content in commercial dog foods.

The Copper Hepatopathy Working Group consists of diplomats of Board-certification in veterinary internal medicine, veterinary pathology, veterinary nutrition, and veterinary sports medicine and rehabilitation.

If you’d like, you can read our full story and the critical link between copper concentration in commercial maintenance dog food here: Preventing the Pitfalls: Copper-Associated Hepatopathy in Dogs

Source:

Relying on reputable sources in the veterinary industry provides a foundation of credibility and ensures accurate and trustworthy information for pet owners. For a comprehensive list please visit our Copper Storage Disease page.

This page is dedicated to a carefully curated collection providing up-to-date scientific resources and support to ensure you have access to the latest advancements and insights in the field. Our thoughtfully assembled array of research studies ensures you have access to the most recent breakthroughs and valuable insights in the field. As an integral part of this resource, we shed light on the crucial role played by the Association of American Feed Control Officials (AAFCO).

 Join our Group | Canine Copper-Associated Hepatopathy – An Evidence Based Approach

Synergistically Yours

Danielle & Sheepdog Riggs

forever in our hearts

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