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Dog Food regulation in Australia for safety & dog nutrition 2018

The best aussie chicken breast dog treat in Austrarlia

The best aussie chicken breast dog treat in Austrarlia After recent dog deaths because of pathogens in commercial dog food (pellet) The Australian media is shining a spotlight on what the current dog food regulations are and if they are adequate.

I was recently called by the ABC (SA branch) for input into what possible amendments or regulations I thought could be used to safeguard dogs.

Here is my considered response (after the fact).

Dog food Government regulations, Australia 2012- 2017

In 2012 in response to dog deaths in Australia, a committee of dog food experts was formed and they wrote a paper called “Managing the safety of domestically produced pet meat, and imported and domestically produced pet food.” Ref 1

In their report they say: “In Australia different systems for achieving the safety of pet meat and pet food have evolved. Pet meat is understood to be ‘meat in a raw state that is intended as food for pets.’ Pet food is understood to be ‘food for dogs or cats including all types of dry, semi-moist, retorted, pasteurized and other food manufactured for consumption by domesticated dogs or cats but excluding pet meat.” Ref 1

“The main controls for pet meat safety includes the PISC Technical Report 88 – Amended 2009 ‘Standard for the Hygienic Production of Pet Meat’ and various state/territory legislation specific for pet meat (mostly aimed at ensuring that pet meat does not enter the human food chain).” Ref 1

The main controls for pet food safety include the new ‘Australian Standard for the Manufacturing & Marketing of Pet Food (AS5812:2011).

Please note if you want to read this you will need to purchase it!   That is how you keep information out of the general population. You will also understand that there is a strong bias towards minimising toxins in grain, Ironic given the scare campaign many dog food companies use against meat (when used in a noncommercial diet).

History of dog food manufacturing in Australia

Only a few years ago almost all of the pet food in Australia was imported from America from only a couple of parent companies. These companies acquired many smaller companies so that they could provide many brand choices that often used the same or similar ingredients.  Then maybe 10-15 years ago smart enterprises in Australia realized that dog food poisoning incidents could be used to their advantage in them creating a dog food company and brand in Australia.

One of the most successful was the Black Hawk brand. It should be noted that Black Hawk was considered very good by many people, but it was still perhaps 70% vegetables (nonmeat). It is also believed that the company originally had other companies manufacture their product – so their company was essentially masterful at marketing and advertising, and distribution, not so much at meat ingredients or manufacturing.

The company was only in existence for less than 10 years and grew from around $5M capitalization equivalent until 2015 when it was purchased New Zealand’s EBOS Group bought the company under the umbrella of Masterpet for (A$52 million). They still manufacture in Australia, but some people claim that the recipes or ingredients have changed, bringing it ‘back to the pack’.

“Buy Australian campaigns” were so successful that American Companies were forced to either buy the Australian companies or set up manufacturing operations on Australian soil. This means that the vast majority of dog food is still controlled by America, and often unless the specific brand says ONLY Australian ingredients, the ingredients might be from America or other countries.

The common contaminant issues of Australian dog food

“The PFIAA has also recently published on their website a ‘Reference List of Contaminants and Residues in Pet Food and Ingredients with Safety Risks’ to guide manufacturers/producers in complying with AS5812:2011 E ”   REF  1

Specific items for consideration may include some ingredients, cross-contamination from previous batches, toxins from grains, heavy metals, melamine, and related compounds and contaminants as a result of microbiological spoilage.

The specific ingredients are shown in a table in the appendix. It gives the max allowable amounts of toxins, for example, there can only be 0.05 mg/ Kg of DDT,  5 mg / Kg of Lead and 2.5 mg/ kg of Melamine.  The only microbial contamination specifically mentioned is Salmonella which must not be present in five random 25-gram samples that are tested.

The results of the dog food working committee 2012

Essentially the last major working committee in 2012 decided to take “no further action on standards”.

” In consideration of the nature and management of the pet food safety incidents, and the new industry developments to safeguard pet food safety, with the exception of thiamine deficiency from sulphite treated pet meat, the Working Group is of the opinion that there is no justification at this time for new official oversight. This view is supported on economic grounds by the findings in the September 2011 Australian Bureau of Agricultural and Resource Economics and Sciences (ABARES) Report ‘Pet Food Safety in Australia: Economic Assessment of Policy Options,’ a report which was commissioned by the Working Group. ” Ref  1

” Regarding the long standing problem of feeding fresh pet meat treated with sulphite preservatives to pets as part or all of their diet, it is scientifically accepted that sulphites destroy the essential vitamin thiamine in meat and many cats and dogs have become ill or died because of thiamine deficiency. Many pet meat producers operate on a small scale and are not represented by an industry body, and there is very little commercial incentive for pet meat producers to self-regulate on account of any standard that may address this issue. The Working Group is of the opinion that a regulatory gap exists in relation to thiamine deficiency and that additional controls could assist in preventing these incidents.” Ref 1

NOTE – thiamine is vitamin B1 (C12H17N4OS+) It is said to have only a Bioavailability: 3.7% to 5.3% – and depending on source (non meat) might be much less for dogs.

How Australian dog food standards work.

You should understand that about 97% of dog owners in Australia (and America) feed their dogs commercial dog food (either big corporate brands in the form of Pellets or wet food.

That 70- 80% of these foods are composed of  NON MEAT ingredients should shock everyone, but rarely does.  Mostly they are grain because the grain is cheap. It is a VERY secondary, and unnecessary ingredient. It is a filler, something for them to put vitamins and minerals into. Something to fill a stomach, not for nutrition.

If the working group was established to understand the dangers to dogs, then really it should have looked at how massive market dominant companies source cheap ingredients in America (where the aafco standards originated), created dog food very inferior to meat diets and it should regulate strictly how to store and transport dog food. Before and after it is bought. Maybe the commercial AS standard does some of this, but it doesn’t address the fundamental non species appropriate ingredients in ANY WAY.

The industry could self regulate testing on manufactured dog food, but that is how it currently is, and a corporations main reason for existing is profit motive. This usually means that a corporation only puts money into benefits it knows it can sell or cost cutting measures. Extra testing in-house is very unlikely to result in drastically safer food. Unless tightly regulated.

Any extra testing will add a cost to the food manufacturers, and testing will only be at the factory point. What if the toxin is biological and only grows to bad high populations in transit or on shop shelves?  That is just as likely to be a major issue for dog food safety if you are looking at bad microbe growth.

The other option would probably be to create a Government group that is tasked with random checks of manufacturers, without alerting the maker that they are coming. How often should these checks occur, and since dog deaths from bad commercial dog food are relatively rare, but when they occur they are usually to do with one or two batches of a specific manufacturers food, these spot checks are unlikely to prevent that kind of food illness that the overhaul is intended to address.

It is agreed that noncorruptible, third-party checks for heavy metals etc would be very useful, but deaths due to low doses of heavy metals, for example, cause long-term damage and accumulation, not sudden illnesses.

You should be aware that the PIFFA dog food contaminant list shown in the Appendix here, only has ONE microbial contamination most people associate with MEAT (salmonella), yet there are FIVE PESTICIDE RESIDUES (connected with dog food grains) and THREE Organochlorides (including DDT) that are NOT connected with MEAT. For them to list these items, it means that there has been sufficient detection in the past to cause problems. And yet much of the media likes to suggest that Meat is the main thing you need to be worried about!  What masterful misdirection by the majors.

The dog food standards AUSTRALIA should adopt.

Australia like the rest of the world automatically adopts the flawed and biased (by large food company input via ‘consultants), the AAFCO standards.  Note the distinction that dog food STANDARDS are more critical to ALL dog’s health than DOG FOOD REGULATION rules. This is a massive distinction that goes unnoticed because of the billions of dollars connected to the dog food industry.

The dog food standards (minimum levels of nutrition) are voluntary and were invented in America and have not changed a lot for many years, yet Australia blindly follows them!

AAFCO standards were created to allow a large amount of carbs to be added to dog food (low-quality non-bioavailable protein) and at the same time requiring unnecessarily high levels of vitamins and minerals that preclude any natural combination of meat and vegetables being called dog food.  NOTE if you don’t meet the aafco table minimum or maximum standards, a product cannot be called ‘balanced and complete’ dog food. This ensures people are afraid to feed their dogs a raw diet not made by a corporation.

It is cheap and convenient for all countries just follow the aafco standard, so no one challenges it. Also noting that the massive amount of dog food exported from America, it ensures their monopoly. Plus it ensures the market dominance of the major corporations who currently sell billions of dollars of grain the world over.

Critical Dog food standards recommendations

1              There should be a minimum level of quality meat required so dogs get sufficient bioavailable protein (and essential amino acids) and enzymes.  The current aafco tables mean makers just have to reach a numerical value for ten essential amino acids from ANY SOURCE no matter how inappropriate for a carnivore domestic dog. No matter what they cant actually use much of them, so if a company just meets the bare minimum or sometimes double the minimum but from a plant source, the dog will be very deficient in these critical nutrients.

2              Dog food does not have to have any PERCENTAGES of ingredients shown on the pack or marketing material.  Ingredients are lust listed in order of the highest amount first.

But due to Ingredient SPLITTING,  it is easy to fool consumers into thinking that just because a meat product is mentioned first and second on the ingredient list, that it might be the majority of the ingredients. 95% or more of commercial dog food in Australia has well under 50% meat even though they always appear as the first ingredient on the pack! If the first ingredient is meat and its 20%, and the next four ingredients are grain and 19% each, you are still only getting 20% meat in that pack, at most.

3              More transparency would mean that the type of meat (not just the word “meat” and the quality of the meat. should be regulated.  The by-product is often used to mean very low-quality meat.  Some companies OS have been caught out using the term ‘meat By-products’ to include:  feet, beaks, hooves, failed organs, blood, feathers, and even rats and road-kill. BECAUSE there was no explicit law against it.

4              The trick of GRAIN MEAL versus raw meat weights. 

The dog food label ingredient list, shows the ingredients from highest weight to lowest weight when added to the mix, not when it is processed and shipped. Raw or quickly cooked meat is still mostly water, up to 70% when raw. So while an ingredient list might show BEEF as the first ingredient and Corn meal (dried) as the second ingredient, the raw beef might be 25% by wet weight, and corn 20% by dry weight.

When you remove most of the water from the beef, its “meal’ equivalent is more like 10% and so only half the dry weight of the second ingredient! This means that most of the dog food protein is coming from the radically inferior grain source, NOT meat.

5              NO  added essential amino acids

Of the 22 amino acidds that make up any protein, TEN are essential amino acids that dog’s cant generate in their own body. They are vital for healthy functioning of the dog in maintenance and growth modes.

If you see the following words in the list ” L-lysine, DL-methionine, L-cystine, L-tyrosine and L-carnitine.”  Ref 3  alarms should go off.

The presence of these being added separately indicate that there is NOT ENOUGH MEAT in the product to supply these amino acids.  Instead, too much cheap grain or vegetable, that is too low  in these amino acids. is included so they have to add artificial separate amounts of these amino acids. The added essential amino acids might still not be bio available versions, they are just inserted to  meet the already low minimum aafco essential amino acid requirements.

Dog food regulations should ban the addition of these amino acids to make up for the short fall caused by the lack of meat in a dog food product.’

6             TVP’s should be banned from dog food. 

The only reason texturized vegetable protein (TVP) or ‘soy meat’ is used in dog food is to fool owners into thinking that a can of ‘dog food’ has a lot of meat in it.  Soy is provide in TVP format purely to mimic the look of meat in colour and texture, nothing more.


While tightening dog food testing in house for pathogens and toxins is definitely encouraged, and adding spot checks by an incorruptible external government agency might decrease the incidence of poisonous dog food, it will do nothing to address what happens to a product after it leaves the factory.

Many owner buy dog food in bulk bags, and leave these open or in heat or in sunlight. If the dog food doesn’t get spoiled in the transit from America or from the Australian factory to the dog store, then poor owner storage methods will surely complete the spoiling.

Since the 1950’s dog food manufactures learned that if they advertise a big chunk of meat on a label and hardly put any inside the container (use TVP’s in wet food and colouring in dry food) they will make great profits.

They have also convinced dog owners, and some suspect celebrity vets, that dogs are mostly herbivores. Dogs are still 90% carnivore and thrive on a meat, offal and bone diet.  I have shown this many times in many articles on this site via scientific tests performed by a brave few. But because universities sponsored by dog food companies are willing to speak out about in appropriate vegetable based dog food. And the dog food labs continue to spend millions in learning how to trick dogs into over eating. The owners continue to believe they are doing the best by their dogs by feeding them mainly a vegetable diet.

Only by removing the known tricks they use to obscure the lack of meat in their products, and add transparency to understanding how much dry percentage of quality meat a commercial dog food contains, will owners get what they paid for.


1              Managing the safety of domestically produced pet meat, and imported and domestically produced pet food  2012

2          Reference list of Contaminants and Residues in Petfood and Ingredients with Safety Risks   2017




From “Reference list of Contaminants and Residues in Petfood and Ingredients with Safety Risks”

The following reference list is a non-exhaustive list of potential risks, relevant to petfoods, arising from raw materials, processing and post-processing incidents, together with applicable reference sources as guidance for petfood manufacturers.

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