“Occasionally”—What It Means in Practice
Treats are meant for occasional use, not consistent nutritional delivery. However, a dental treat may be acceptable if: • The label is consistent with the product’s purpose (mechanical/ abrasive dental action) • Claims stay within food boundaries (see next section) If a product is designed to deliver a daily nutritional benefit (like vitamins/ minerals), it should be labeled as a food supplement, not a treat. Ingredient Rules for Treats For treats (food), ingredients must: • Be approved for use in animal food • Appear in AAFCO Chapter 6 or be referenced in applicable CFR provisions • Be included only for their intended purpose Key example: turmeric/curcumin If an ingredient is approved as a spice/flavoring/seasoning, you can’t use it (or market it) for an unapproved purpose such as anti-inflammatory benefits on a treat label or any food product. Other ingredients discussed as examples of non-nutritional benefit ingredients (problematic for treats when used for health claims) include: • Chamomile • Milk Thistle • CoQ10 • SAMe • MSM
Claims Boundaries for Treats (food claims only)