Re: Senate Enquiry – Safety of Pet Food
For the purposes of transparency, I will begin by declaring a commercial interest in the Australian pet food industry.
As a producer of animal nutrition products, the safety of pets and their human families is paramount.
This begins with the selection of quality raw materials, implementation of human-standard manufacturing processes and consideration of the environmental impacts of packaging materials, and continues through to the honest and transparent declarations on finished goods, to allow a truly informed choice at point of purchase by consumers.
Sadly, the current legislative environment provides an uninhibited pathway for manufacturers both large and small, to commercialise products with limited or no legal obligation to their customers regarding the origin, source, quality, volume, or synthetic attributes of raw materials included in pet foods. In addition, there is no obligation for labels to be accurate, honest, or simple to understand for ordinary pet parents.
As an ethical producer of animal nutrition – including voluntary compliance with AS5812:2017 and a commitment to listing individual ingredients by common names in a descending order by volume – we are immediately at a commercial disadvantage due to the costs associated with delivering higher standards across our enterprise. This can be directly attributed to the absence of strong regulatory controls and enforceable legislation to ensure all animal nutrition products meet the same stringent standards.
Veterinary Sector
Any substantive improvement the standards within the pet food industry must have the support of the Veterinary sector. As the first point of contact for pet owners seeking advice on animal wellness, the family Vet can significantly influence consumer decisions regarding pet food. One consistent standard will provide an opportunity for Vets to recommend a broader selection of options for pet parents, including those products free of carbohydrate-heavy ingredients and, in some cases, harmful synthetic additives that have prompted this Senate Enquiry.
Industry Representation
While it is difficult to remove all potential bias from an industry-driven body, the availability of non- partisan representation at a legislative level is a critical consideration in the advancement and improvement of outcomes in the animal nutrition sector.
With dry food manufacturers representing 90% of the industry, and the Pet Food Industry Association of Australia (PFIAA) membership reflecting the market, the PFIAA faces a potential conflict of interest. With office holders, key executive positions and committee chairs being routinely drawn from one sector of the pet food industry, the PFIAA faces a legitimate risk of being positioned as a lobby group for the dry pet food industry as opposed to delivering impartial, objective, and independent representation for all contributors to the space.
“Truly understanding one’s environment requires one to first understand English”
Summary
Ultimately, there is no single source of nutrition that will satisfy every consumer or pet parent. However, the absence of a single standard or minimum guarantee obligation on the part of pet food manufacturers has created an environment whereby consumers receive incomplete, inaccurate, or inappropriate nutritional information through unregulated product marketing claims. The objective should be to provide clear and concise information to empower consumers to make a choice based on a single standard across manufacturing and marketing.
Possible actions for consideration:
- The redefinition to ‘mandatory status’ of Australian Standard AS5812:2017 in lieu of the current voluntary status, to ensure a consistent minimum standard across all formats of animal nutrition.
- Marketing compliance legislation to compel manufacturers to nominate an internationally recognised nutritional standard when making claims of ‘complete and balanced’ on packaging.
- Use of common definitions or descriptors when listing ingredients to reflect internationally recognised standards (i.e. whole protein vs viscera / natural state vs rendered).
- Mandatory inclusion of carbohydrate volumes in the nutritional panel of pet food products and the source of these carbohydrates (plant, animal, synthetic).
- Review of the mandatory statement ‘Pet Food Only – Not for Human Consumption’ to instead read “PET FOOD PRODUCT – NOT INTENDED FOR HUMAN CONSUMPTION” where an enterprise manufactures products that meet human consumption standards, providing clear differentiation for consumers.
- Implementation of a ‘Declaration of Interest’ when non-manufacturing entities (Veterinary practices, Universities, Research bodies etc) are the recipient of funding (cash or in-kind) from industry participants likely to have a commercial interest in the content or outcome of the activities concerned.I sincerely thank you for the opportunity to contribute to the debate and would be pleased to contribute further as the enquiry proceeds.
