If you’re interested in feeding your pets well, you probably hear a lot about balance. We refer to AAFCO on our products and in our newsletter because they are the governing body for animal feed in the United States. For this reason every dog food brand sold in America must meet AAFCO requirements. Some people take a hardline on balance stating that every meal for your pet MUST be balanced. Other people barely give any credence to balance at all.
Who is right? How appropriate are AAFCO guidelines? What about for fresh food? Most of the foods that fall under AAFCO’s jurisdiction are dried, processed and made complete with synthetic vitamins and inorganic minerals. Today we go in depth on balance and AAFCO. We refer to high-quality research and case studies on the longest lived dogs in history. Before that here is a new daily food recipe to make for your pup:
Also, if you already preordered The Dog’s Table, we’re giving you a recipe early! Collect it here: Spaghetti Squash and Bison recipe for senior dogs.
TLDR: AAFCO was created after the advent of kibble and is designed around synthetic vitamins used to fortify highly processed food. Since the bioavailabilty of many synthetic vitamins and inorganic forms of minerals is much lower than natural forms, it is our opinion that AAFCO guidelines are not applicable for whole food diets. Both research and anecdotal accounts of the longest-lived dogs in history support this opinion.
This newsletter is written for informational purposes only and does not constitute medical advice. Please consult a reputable healthcare practitioner before beginning any dietary regimens.
What‘s the deal with ‘balance’ anyway?
All animals need nutrients to live. Throughout history, these nutrients were obtained solely through food. Even domesticated animals can obtain all the nutrients they need from natural sources. Both dogs and people evolved to scavenge whatever was available, and can thrive on a variety of foods. This is why there is so much debate around diets for people. We can live on a carnivore diet, a vegan diet, or pretty much anything in between. When you have so many possible options, it’s hard to determine which one is best.
Dog nutrient requirements are not that much different than people, and can be summarized (in general) with a few bullet points. Here’s an excerpt from “The Dog’s Table:”
Dogs Need Micronutrients
Vitamins and minerals are essential nutrients that are needed in small amounts. Because there are many micronutrients, this section will highlight just the main differences between dogs’ and people’s needs. Also, we will discuss some harder-to-get micronutrients. The main differences in vitamin and mineral needs between dogs and humans can be summarized as follows:
Unlike people, dogs can synthesize vitamin C and don’t require it in their diets.
Dogs require vitamin D, while people can synthesize vitamin D through
exposure to sunlight.
Dogs have higher requirements of vitamin A, some B vitamins, and vitamin E.
Dogs have higher requirements of some minerals like zinc, copper, and calcium, while also requiring a calcium to phosphorus ratio lower than 2:1. (There is some debate about the appropriateness of this ratio.)
Just like people, dogs need iodine, which can be difficult to get (that’s why people use iodized salt—but in most instances, adding salt isn’t ideal for dog food).
These requirements can be met with a few basic additions:
Adding a bit of organ meat like liver can make up for most of the vitamin B requirements. Beef liver is particularly nutrient dense and also contains zinc, copper, vitamin A, and many other vitamins and minerals.
For vitamin E, we use roasted, unsalted sunflower seeds or wheat germ. Wheat germ oil and sunflower oil are also high in vitamin E, though we don’t typically use either.
We include calcium in our recipes by adding eggshells. The ratio of calcium to phosphorus isn’t typically a concern unless too much calcium is added.
Zinc and copper are abundant in beef, venison, bison, and oysters, so we feature these foods.
Vitamin D is high in fatty fish like salmon and moderate in eggs, and these foods appear in many of our recipes.
6. Sea kelp (Ascophyllum nodosum) is the main source of iodine in our recipes.
If you keep in mind these six points, you can start to formulate your own dog food. It’s really that simple.
Who is behind AAFCO?
AAFCO stands for American Association of Feed Control Officials. According to their website they are an independent organization that has been guiding federal and international feed regulators for over 110 years. They cover all domestic animal feed from birds, cattle, horses, dogs, cats, rabbits, fish and more. Importantly, AAFCO is NOT a government organization and most of it’s funding comes from non-federal sources.
Many critics allege close ties with the pet food industry that amounts to regulatory capture, where private industry influences regulators and thus rules. Pet food manufacturers hold positions on AAFCO committees, even those tasked with enforcement criteria.
According to AAFCO’s 2022 Annual Committee Report, “A committee advisor inquired about industry (representatives) participating in the Analytical Variation Workgroup. Being that this workgroup is within the Enforcement Issues Committee, all participants must be regulatory.” In other words, in 2022 an industry representative served on an AAFCO rule enforcement committee, which other members flagged as a violation of bylaws. This is particularly important because committees are where AAFCO policies are set.
Furthermore, because AAFCO is not a government organization, it is not subject to oversight. There is no formal body that can regulate or force change on the organization. This has led to some questionable results.
Listing wet ingredients along side dry ingredients: When a protein like chicken is weighed wet, it’s 5-10 times heavier than it’s dried form. This inflates the amount of chicken in the formulation when presented next to the next 6 ingredients that can be weighed dry. So even though kibble is mostly dough, they can legally write that chicken is the #1 ingredient. (The below image is Hill’s Science Diet from Chewy.)
Relying on crude nutrient analysis: Crude protein analysis is indeed very crude. Total Kjeldahl Nitrogen is used to estimate protein content based on the nitrogen content of a food (nitrogen is abundant in protein). However, many molecules that are not protein contain nitrogen as well, including urea (a waste product in urine), B vitamins, and histamine. In other words, crude protein means very little to help you make a decision on the quality of your dog’s food.
Separation from the FDA: In 2024 the FDA ceased to renew an MOU that partnered with AAFCO to review new animal food ingredients. This represents a significant change to policy as the partnership originally began in 2007.
There are many more issues with AAFCO, but we won’t bore you with any more of them here.
Is whole food nutrition really better?
Yes. And it’s not even close.
Real food contains vitamins and minerals in their natural form with co-factors that aid digestion in complex ways. Some of these interactions are known, but others are being discovered every year. For example, a relatively new discovery is that vitamin D and vitamin K work together to improve calcium misplacement (bone vs arteries).
Because some vitamins are unstable in natural form, they have to be made into different molecules when used as additives in food. The way the body digests these different forms of vitamins can have different levels of effect, digestibility, and toxicity. For example folic acid, the synthetic form of the B vitamin folate, has a maximal daily recommendation of 1 mg/day while folate does not. See our previous post on synthetic vitamins.
The macronutrients in whole food nutrition are superior as well. Protein from fresh sources is far better in quality, digestibility and generally lower in toxins than low-quality animal meal often used in kibble. For example, meat and bone meal is a common ingredient in many commercial formulations including Pedigree, but only has 10-35% digestible protein. Lean ground beef has approximately 60-75% digestible protein (dry matter). Furthermore, according to a study done in New Zealand on 94 different bone and meat meals, there is huge variance in the amount of digestible protein in different sources of meat and bone meal.
The amount and type of carbohydrates in whole-food diets are better for dogs health as well. As we often say, kibble is far too high in carbohydrates to be ideal. Even worse, the carbohydrates in kibble are typically heavily processed with heat and pressure, which increases glycemic load. A number of studies confirm that increasing levels of carbohydrates in dog food negatively impacts blood sugar metrics in dogs. High glucose levels are linked to chronic diseases like cancer and heart disease. See our post on carbohydrates for more.
Why AAFCO is not right for whole food diets
AAFCO was formed in the early 1990s well after the advent of kibble. Because the vast majority of dogs at that time (and still today) ate kibble and because AAFCO changes very slowly, their guidelines were made for kibble. We believe that AAFCO guidelines are wholly unsuitable for whole-food diets. Here’s why:
Micronutrient minimums assume the use of synthetic vitamins: As discussed above, some synthetic vitamins and inorganic minerals are inferior compared to nutrients from whole foods. We know this now after decades of research, but just 30 years ago this position was relegated to quacks. Studies show minerals from whole foods like selenium, zinc, copper and others are more digestible (bioavailable) than their inorganic counterparts. Folic acid is more toxic than folate. Yet, the AAFCO minimum for vitamin B9 is quoted in folic acid, the synthetic form, rather than folate, the natural form.
Research (Done by Waltham, a subsidiary of Mars) shows dogs fed unbalanced homemade food do not show signs of deficiency: Here’s the exact quote from the paper, “Although clinical signs of deficiency were not found in dogs fed the HPD (home prepared diet), a sufficient margin of safety above absolute physiological requirements is reflected in the AAFCO values.”
It’s important to note that the dogs in the study were fed homemade diets exclusively before and during the study period, so even though the study was only done for 30 days, the deficiencies had much longer time to appear.
The longest-lived dogs in history were all fed unbalanced homemade food: Bobi, once the longest lived dog (31, but later challenged), was known to have eaten a whole food diet that was not balanced to AAFCO standards. This is also true of Bluey, the current record holder for longest lived dog (29 years). She was reported to have eaten a high-protein diet of kangaroo, emu, rabbit and table scraps. Bramble, who lived to 27, ate a vegan diet consisting of foods like lentils, organic vegetables, and rice. None of these dogs’ owners gave balance or AAFCO a thought. Interestingly, none of these dogs lived in America…
We follow AAFCO because people have come to expect it, and for the products we sell it’s a legal requirement. Long term, we believe there will be new organizations that create more modern and appropriate guidelines for pets.
That’s it for this week.
All the best,
Joelle and R.A.