NCL Letter to FDA: Companions Deserve Proper Nutritional Labeling, Too

April 7, 2003
 

The Honorable Mark McClellan
Food and Drug Administration
5600 Fishers Lane
Rockville , MD 20857

Dear Commissioner McClellan:

It is refreshing to know that one of your top priorities is to ensure that consumers receive accurate information – at the drug store counter and at the grocery store – before making choices that impact their healthcare and the health of their families. The National Consumer League members also appreciate your affirmation of this commitment recently at our Consumer Health Forum at the National Press Club in Washington . 

We are well aware of your Consumer Health Information for Better Nutrition initiative and its goal that consumers receive science-based information and are not deceived by company health claims about food and dietary supplements.  Another truth-in-labeling concern has come to our attention – confusing and misleading nutrition and pricing information that consumers encounter when purchasing food for the family pet.

It is our understanding that the FDA’s Center for Veterinary Medicine has investigated the feeding directions on dog food labels, especially on products manufactured by the Iams Company. Until Iams was acquired by Procter & Gamble, its dog food was sold in pet and specialty stores. Iams had a reputation as a “premium” product and was sold for a higher price than many other pet foods.  Now the same premium, high price product is also sold in grocery and mass-merchandising stores with a label that has a reduced portion for the “recommended daily serving.”

We recently became aware of the Dec. 17, 2002 , letter Congressman Henry J. Waxman sent to the FDA. In his letter, Congressman Waxman wrote that there is evidence that Iams – without changing the nutritional content of its dog food products – decreased the amount it claimed was an appropriate serving for dogs by more than 25 percent.  According to the Waxman letter, it appeared FDA scientists believed the reduced serving size Iams recommended in its new labeling did not provide adequate nutrition for most dogs.

Through creative mathematics, the company claims feeding your pet with their product costs 44 cents per day, giving the appearance the product competes with other leading pet food products that cost 45 cents per day.  Consumers could be deceived into thinking that they are getting a bargain when they purchase the Iams product. 

If there is no change in nutritional content and manufacturers are lowering quantities, consumers may inadvertently be endangering their pet’s health.  Consumers need accurate consistent science-based standards for all manufacturers.

We are interested in knowing the status of your investigation and any actions the FDA has taken. It also would be appropriate for the FDA to provide clear nutritional guidelines to help consumers make informed purchases of pet food.  Thank you for your consideration of this important consumer concern.

Very truly yours,

LINDA F. GOLODNER
President

CC:   Congressman David Dreier
        Congressman Henry Waxman