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Nutritional Labeling
How do I calculate the Guaranteed Analysis in my pet treats?
All pet food labels require a guaranteed analysis on the label to advise the purchaser of the
product’s nutrient content. At minimum, guarantees are required for minimum percentages of
crude protein and crude fat, and maximum percentages of crude fiber and moisture. The only
exception is for products that do not and are not intended to provide protein, fat or fiber (for
example, vitamin and mineral supplements), in which case the product is exempt from guarantees
for those components. In all cases, though, a moisture guarantee is required. Guarantees for
other nutrients are normally voluntary, although additional guarantees may be required to support
claims made on the label. For example, claims such as “with calcium” or “high in vitamin E” would
require minimum calcium or vitamin E guarantees, respectively.
Unless the product is formulated through the use of sophisticated computer software with a
complete and accurate database on nutrient content of all ingredients used in the product, the
best means of determining appropriate guarantees is by laboratory analysis. A “proximate
analysis” of the finished product includes testing for the four nutrient components mentioned
above in addition to ash. Results are typically reported in percentages “as fed” (AF). If unsure as
to the units reported, it is prudent to ask the laboratory for clarification.
Important to note is that a single analysis of a product may not provide sufficient data to
determine reliable guarantees. Guarantees are declared as either “minimums” or “maximums,”
meaning that if a feed control official obtained a sample of the product and tested it in his or her
official state lab, the crude protein and crude fat must be NO LESS THAN the stated percentage
on the label, while the crude fiber and moisture must be NO MORE THAN the label declaration.
Each batch of finished product is going to vary in composition due to variation in ingredient
composition, mixing rates, and amount of water driven off during the cooking process.
Unfortunately, a single analytical value does not give any indication as to the expected batch-to-
batch variation. As a result, the composition of the batch that was tested may be very different
from the one the feed control official analyzes!
Failure to meet the guarantees may result in possible enforcement action against the product. It is
prudent, then, to test multiple batches of each product. How many? In general, the more analyses
conducted, the better one can estimate batch-to-batch variation and hence more reliably set
guarantees. Understanding economic limitations of start-up companies, it is prudent to conduct at
least two analyses of each variety to start. As more batches are produced and analyzed, more
data may indicate the need to adjust the guarantees on the next label printing.
In the following example, four batches of product are tested and the results tabulated. The best
means of determining appropriate guarantees from the data is by statistical analysis, calculating
the average and standard deviation for each nutrient (these calculations can be done easily in MS
Excel). Assuming the variation will have a “normal distribution” (i.e., it follows a “bell curve”), the
average plus or minus two standard deviations will encompass approximately 95% of the
population. In other words, based on this estimate of variation, by setting the minimums below the
low end and maximums above the high end, 95% of the time the product will meet the guarantee.
Alternatively (and far less complicated), finding the lowest value among the crude protein and
crude fat results, and then further rounding down from that value to the next whole percentage
can be done to set the minimum guarantees. For crude fiber and moisture, the same can be
done, except in those cases, the highest value is rounded up.
In the following example, if the manufacturer relied solely on data from the first batch to set
guarantees, there likely would have been problems down the road. The first batch measured 25%
crude protein. However, one of the subsequent batches was much lower at 23%. If that later
batch happened to be analyzed by a state, the product would have been found deficient. The
average crude protein was found to be 24.8%. Subtracting two standard deviations from the
average is 22.25%. Thus, a prudent minimum crude protein guarantee for this product is 22%.
Example: Calculating guarantees from proximate analysis data
 Crude Protein Crude Fat Crude Fiber Moisture Ash
 Batch
% AF % AF % AF % AF % AF
 1  25  15  4.5  7.8  3.2
  2  26  14.3  3.2  8.9  3
 3  25.2 13  4  8.1  2.9
 4  23  16  3.8  9.1  3.3
 Average  24.8  14.58  3.88  8.48  3.10
Standard Deviation 1.28 1.26 0.54 0.62 0.18
Average +/- 2SD 22.25 12.05 4.95 9.72 3.47
Min/Max 23 13 4.5 9.1 3.3
Recommended Guarantee 22 (min) 12 (min) 5 (max) 10 (max) 3.5 (max)

 NOTE: Ash guarantee not required on pet food labeling, but is typically included in "proximate
analysis" lab reports
 

DISCLAIMER Did you know?

The information contained in this website is designed to AAFCO does not regulate, test, approve or certify pet
provide advice to small petfood and treat manufacturers on foods in any way.
regulatory requirements and to assist them in the

development of proper labeling for these products. AAFCO establishes the nutritional standards for complete

and balanced pet foods, and it is the pet food company's

AAFCO has no statutory authority to regulate pet responsibility to formulate their products according to the
products. appropriate AAFCO standard.

Rather, enforcement of violations is the purview of the state
feed control officials, so companies must comply with each
state's requirements.  While most states follow AAFCO
model regulations, exact language and interpretation may
differ between states. While these documents offer guidance
that are helpful in the vast majority of states, it is the
responsibility of the manufacturer to ensure compliance with
individual state requirements.
It is the state feed control official's responsibility in
regulating pet food to ensure that the laws and rules
established for the protection of companion animals and
their custodians are complied with so that only
unadulterated, correctly and uniformly labeled pet food
products are distributed in the marketplace and a structure
for orderly commerce.

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