Why the Term “Balanced and Complete” is Dead

January 30, 2024

By Sarah Griffiths, DCH

Ok – time to drop a bomb. I’ve been following the latest on what’s been happening in the ultra-processed pet feed space and it’s getting to me. My frustration lies in the level of shock being expressed online and the apparent misunderstanding of how the pet feed industry works. While these animal deaths and illnesses are heartbreaking, it’s not shocking in any way. It’s the reason I do what I do.

There are a plethora of reasons this incident has been able to take place and my heart breaks for anyone who’s lost a pet in this terrible way. I’m not, however, as shocked about it as some of you might be. While this particular incident is still in the investigative stages with the FDA, this is NOT the first time pet food has killed pets. There are enough of these incidents on record now to understand that there are some disturbing systemic problems within the pet feed industry. The issue is so significant that thousands, if not millions, of pet parents no longer trust veterinary advice about pet nutrition and food safety. And I’d say there are some pretty valid reasons for that.

Additionally, these extreme cases are shadowed by the millions of nutritionally-created chronic illnesses occurring in pets today due to ultra-processed feeding methods.

Today, I want to talk about the term “balanced and complete” and to highlight the vast differences for its definition in the human food space vs. the pet feed space.

….Because enough is enough. When it comes to the pet feed industry, a lot of us have had enough. The “science” is weak and biased. The logic is boarding on insanity (defined by repeating the same thing over and over and expecting different outcomes). And who pays for these industrialized practices? The animals, of course. I know a lot of you out there want change in the industry and you need to speak up if you do. When these incidents happen is when we really have a responsibility to send clear messages. This isn’t about being right or wrong. It’s about what’s best for animals.

In Human Terms, What Defines a Diet That’s Balanced and Complete?

When we look at the human health and nutrition paradigms, it’s well-documented and accepted by governments, scientists and medical professionals that a variety of fresh foods is the healthiest and most balanced way to eat. It’s also understood through SCIENCE that avoiding ultra-processed foods will help prevent diseases such as obesity, diabetes, heart disease, gastrointestinal disorders and even mental illnesses like depression and anxiety. (1) (2)

Duh! Do we need an entire body of research to come to this conclusion? Well, in case you do, it’s there. Do we need to be mathematicians and carry scales and calculators around with us when we eat? Is that how YOU eat? When you go to your doctor, what do they recommend to you as a healthy diet?

So what does it look like when a veterinary professional – even a board-certified veterinary nutritionist – recommends a healthy, balanced and complete diet for pets?

Well, it’s this:

The American Associate of Feed Control Officials (AAFCO) defines a healthy diet as “balanced and complete”. Quoting from their website: “Complete” means the product contains all the nutrients required. “Balanced” means the nutrients are present in the correct ratios.” They also define “nutritional adequacy” as meeting AAFCO’s guidelines. You can read the full outline here.

Is that what we’re striving for? Nutritional adequacy? Adequate means it’s barely sufficient.

If you want to pull the science card, let’s look at pet disease data. Research shows that 25% of all domestic dogs will die from cancer. 50% of dogs over the age of 10 will develop cancer. Canine obesity is the number on issue facing dogs today and diabetes has increased by 79.7% since 2006 according to the 2016 Banfield Veterinary State of Pet Health Report. According to the same report, feline diabetes is 3 TIMES more prevalent than canine diabetes! The number of gut-related illnesses and allergies in my own practice alone is out of control.

Why are these nutritional connections not being made by medical professionals? Veterinarians and their associations are still droning on about the superiority of ultra-processed diets and vehemently discouraging the use of fresh food diets. It’s infuriating.

Why “Balanced and Complete” is Dead

The main point of this article is help you understand why the term “balanced and complete” is a joke when it comes to animal nutrition.

Balanced and complete as per AAFCO’s definition allows ANY “approved” ingredients to be used in a formulation, regardless of it’s relevance to species-specific nutrition or whether or not it is fresh, whole or healthy.

AAFCO has a special committee called The Ingredient Definitions Committee who reviews and defines the ingredients that they deem allowable to be used to create these “balanced and complete” formulations. You have to pay $250.00 for a copy of the AAFCO publication to read those ingredient definitions. Why? Probably because it’s absolutely deplorable. Let me quote from it since I own the AAFCO publication:

Chapter 6, Section 24, Page 371 of the AAFCO Official Publication for 2021:

24.12 Cottonseed Meal, Solvent Extracted – is the product obtained by finely grinding the flakes, which remain after removal of most of the oil from cottonseed by a solvent* extraction… The words “solvent extracted” are not required when listing as an ingredient in a manufactured feed.

*Solvent (used in fat extraction of all kinds) – As defined by AAFCO in their crude fat best practice methods: “The commonly used organic (polar) solvents include petroleum ether, diethyl ether, chloroform, methanol, ethanol, isopropanol, n-butanol, acetone, acetonitrile, isopropyl ether, dioxane, tetrahydrofuran, dichloromethane, pentane, hexane, benzene, cyclohexane, iso-octanol, or mixtures of these solvents. Carcinogenicity, toxicity, flammability, hygroscopicity and cost must all be considered in choosing a solvent”

Chapter 6, Section 73, Page 448 of the AAFCO Official Publication for 2021:

“Antimicrobial Agents (73.030-039)

73.030 Formaldehyde – The food additive formaldehyde may be safely used in the manufacture of animal feeds in accordance to the following conditions:

  1. The additive is used, or intended for use, to improve the handling characteristics of animal fat in combination with certain oilseed meals by producing the from a dry, free flowing product……”

Chapter 6, Section 74, Page 456 of the AAFCO Official Publication for 2021:

“74. Processed Animal Waste Products

…..Ingredient definitions:

  • 1 Dried poultry waste (DPW) means a processed animal waste product composed primarily of feces from commercial poultry, which has been thermally dehydrated to a moisture content not in excess of 15.0%. It shall not contain less than 18.0% crude protein, and not more than 15.0% crude fiber, 30.0% ash, and 1.0% feathers.
  • ….74.4 Dried Ruminant Waste (DRW) means a processed animal waste product composed primarily of processed ruminant excreta which has been artificially dehydrated to a moisture content not in excess of 15.0%. It shall contain not less than 12.0% crude protein, and not more than 40.0% crude fiber, including straw, woodshavings, etc. and not more than 30.0% ash.
  • …74.5 Dried Swine Waste (DSW) means a processed animal waste product composed primarily of swine excreta which has been artificially dehydrated to a moisture content not in excess of……”

This is just a tiny portion of what’s in this book. Honestly, how do these people sleep at night?

Once you know this, you can’t un-know it. Now, when we refer to the term “balanced and complete,” you’ll understand why I say it’s a joke. Knowing that this is an entirely acceptable way to “balance and complete” a pet feed in AAFCO’s eyes, what’s next? Do you still accept AAFCO guidelines as the standard you wish to follow for feeding your animal?

Pet Feed Contains Literal Industrial Waste

But, you say, YOUR pet feed doesn’t contain such disgusting ingredients. Yes, that may be true but the point is that it is completely acceptable in the pet feed industry. Just because your pet feed doesn’t contain the obviously horrendous ingredients listed above, doesn’t mean there isn’t garbage in the bag. Yes, I mean literal garbage. There are many less horrific ingredients that are still completely deplorable and found in even “the best” veterinary brands of pet feed. There are hundreds of industrial waste products going into pet food from other big industries – particularly the human food and big agriculture industries.

For example:

Grain and Legume By-Products, Meals and Hulls – These come with a high risk for aflatoxin (grain mould toxin) contamination even when not reported or confirmed by the FDA. Even daily consumption of low-grade mouldy grain products can be devastating in the long term, especially since highly processed grains and legumes also increase blood sugar and tissue inflammation at the same time…. Not to mention they are heavily sprayed with herbicides (also not required to be listed as an ingredient even in human food). Let’s not forget that grains and legumes or their by-products are completely inappropriate for dogs and cats. I repeat: it’s literally garbage!

Meat By-Products – This is all the stuff that’s left over – not fit for human consumption – after animals are rendered for meat. Several recalls have been issued by the FDA for the presence of injectable drug products in meat by-products including aluminum phosphate, an anesthetic.

Deadly Mistakes in Ingredient Measurement – several reports on the FDA’s veterinary recall database indicate deadly overdose of fat soluble vitamins A & D.

The 2007 Melamine Recall – In 2007, a significant number of animal illness and deaths were linked to melamine contamination  in pet food. Melamine is a toxic chemical, similar to cyanide, that is uses in the plastic industry to produce resins when combined with formaldehyde. The source in the case of the pet food deaths was wheat gluten.

The scariest thing about all of this is that when companies are using such ridiculous ingredients, the risk of contamination is real. And it could happen at any time with any brand. It’s not really a brand problem. It’s an industry problem.

Illuminating these details makes it more understandable as to how the current FDA pet food investigation is not a one-time occurrence? It will continue to happen as long as conventional pet feed standards remain where they are.

Do you still care about AAFCO’s “balanced and complete” designation?

After reading this, does the term balanced and complete hold the same weight? Knowing that your pet feed could be balanced and completed using literally anything containing “adequate” crude protein/crude fat, etc. would you still call this healthy nutrition?

I hope this article got real for you and I hope that you’ll share it with pet parents!


  1. Food and Agricultural Organization of the United Nations: Ultra processed foods, diet quality, and health using the NOVA classification system. 2019
  2.  Canada’s Food Guide, 2024