330 CMR 13.05
Expression of Guarantees
(1) The sliding scale method of expressing a guaranteed analysis (for example, "protein 15
18%") is prohibited.
(2) Pet foods which is formulated as and represented to be a mineral supplement, shall include
in the guaranteed analysis the minimum and maximum percentages of calcium, phosphorus and
the minimum and maximum percentage of salt. The minimum content of all other essential
nutrient elements recognized by the AAFCO Dog or Cat Food Nutrient Profile or other AAFCO
recognized nutrient profile from sources declared in the ingredient statement shall be expressed
as the element in units specified in the recognized nutrient profile. Product labels may express
the mineral guarantees in milligrams (mg) per unit (e.g., tablets, capsules, granules, or liquids)
consistent with those employed in the quantity statement and directions for use. Liquids
expressed as volume must also list a weight equivalent (e.g., 1 fl. oz. = 28 grams).
(3) Vitamins guaranteed on pet food labels shall be stated in International Units per kilogram
(IU/kg) for vitamins A, D, and E. All other vitamins shall be stated in milligrams per kilogram
(mg/kg) except vitamin B12 which may be guaranteed in micrograms per kilogram (ug/kg).
(4) The label of a pet food which is formulated as and represented to be a vitamin supplement
shall include a guarantee of the minimum content of each vitamin declared in the ingredient
statement. Vitamin guarantees shall be expressed as in 330 CMR 13.04(3). Products labeled as
in 330 CMR 13.04(2) may express the vitamin guarantees in approved units consistent with
those employed in the quantity statement and direction for use. Liquids may be expressed as in
330 CMR 13.04(2).
(5) If the label of a pet food does not represent the pet food to be either a vitamin or a mineral
supplement, but does include a table of comparison of a typical analysis of the vitamin, mineral
or nutrient content of the pet food with levels recommended by AAFCO-recognized animal
nutrition authority, such comparison may be stated in the units of measurement used in the
AAFCO Dog or Cat Food Nutrient Profiles. The statement in a table of comparison of the
vitamin, mineral, or nutrient content shall constitute a guarantee, but need not be repeated in the
guaranteed analysis. Such table of comparison may appear on the label separate and apart from
the guaranteed analysis.
(6) The use of percentages or words of similar import when referring to nutrient levels
established by the AAFCO Dog or Cat Food Nutrient Profile or other recognized nutrient profile
shall not be permitted on pet food labels, except that such direct comparisons in whole or part
of the individual nutrient contents of a pet food with those recommended by the recognized
nutrient profile may be made where the comparisons are expressed in the same quantitative units
as those used by the cited nutrient profile and the product in question meets the nutrient profile
recommended by the authority and the comparison is preceded by a statement to that effect.