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Milk Replacer Product Labels - Buyer Beware, or Be Aware

 

 

Who cares? Who reads instructions anyway?

 

Point taken. Many people regularly open up a new product, tool or gadget, and then promptly discard the instructions and user manual along with packaging. Then they ask a friend, a geeky teenager, or watch six YouTube vids on how to use it.

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How helpful are the labels?

 

In general, the label can be helpful if several things are true. First, the label should disclose (in sufficient detail and clarity) the product's contents. Second, the label should be up-to-date and accurate enough that the user can actually rely upon the disclosures. Third, the user needs to be educated to understand the label contents and disclosures - enough to make informed decisions.

 

 

All labels are not created equally

 

There are volumes of state and federal regulations that govern product labeling contents and disclosures of various food products. A vast difference exists in those requirements depending on whether the food product is human grade or animal grade. Consider the chart below for just the part of the product label that deals with the nutritional make-up of the product for both Enfamil® baby formula and Esbilac® puppy formula:

Wait....what? The human infant formula powder label tells me far more than I may want to know, but at least it is there should I be interested. It is fairly detailed and precise, since it is sold for human consumption, and more precisely for infant consumption.

 

It discloses the primary nutrients (protein, fat, carbohydrates), the primary and secondary dietary minerals, and the various vitamins - again in excruciating detail.

 

But for my wild mammal babies I only get three data values to make a decision and compare products? Yep.    There actually are only 2 since water (moisture) is technically not a nutrient in this context.

 

Then the protein and fat levels are just a MINIMUM percentage? Yep.

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Plus, a minimum amount of say 33% protein could actually be much higher - as much as 40% or more? Yep.

 

It says 'Guaranteed Analysis' so I can at least be sure that it has at LEAST 40% fat content, right? Nope.

 

The disclosures for water and fiber seem odd since milk has no dietary fiber. At least the guaranteed max for fiber is 0%. Since this is dry powder, why would it have any water included and up to 5%!!?

 

Clearly there are differences in the levels of disclosure required by different products. While this illustrates how remarkably different labels can be, there are some bits of useful information on the label, and other information to use with caution.

 

 

A deeper dive into an Esbilac® label

 

The label to the right is from a can of PetAg's® powdered Esbilac®. The following is very brief discussion addressing the various disclosures included on the label.

1.) PRODUCT DESCRIPTION: The first statement in red says a lot. It describes the product as intended for 'puppies' and says nothing about wildlife. Thus, feeding Esbilac® to wild mammal babies is considered to be an 'off-label' use. A similar statement is printed on some other PetAg® milk replacer products that are commonly used for wild mammals. As to the statement on prebiotics and probiotics, see #7 below.

 

2.) DIRECTIONS FOR MIXING: Several points here. The mixing directions infer this powered product is an 'instant-mix.' Yet WildAgain's extensive tests on reconstitution indicate that is not the case. It now seems that optimum reconstitution is now more individualized to each milk replacer product, depending on the water temp at time of mixing, and the resting period prior to use (allowing for more rehydration). The suggestion as to adding the powder to the water is appropriate since that improves the rehydration of the powder, as is storing reconstituted Esbilac® in the refrigerator.

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3.) DIRECTIONS FOR FEEDING: These directions (in the intentionally darkened and shaded area) are for puppies and do not apply to wild animal species, except perhaps wild canines (i.e., young coyotes).

 

4.) STORAGE: While opinions differ in the scientific literature as to exact storage length and temperature for any unopened powdered milk product, a colder temperature and shorter storage time is preferred.

 

5.) INGREDIENTS: The ingredient list is presumed to follow the regulations that specify that ingredients be listed in their order of prominence in the product. In this instance, the first 5 listed are the primary ingredients and supply almost all of the primary nutrients. The rest of the list can be viewed in two parts – (1) all of the vitamins, additives and supplements, and (2) the pro/prebiotics identified as fermentation products.

 

Regulations require that labels be updated within 6 months of a formulation (ingredients) change. In practice, it appears this time limit may be enforced if that time period exceeds two years.

 

6.) GUARANTEED ANALYSIS: As mentioned above, not all lots tested adhered to these guaranteed values. Click here to see a detailed spreadsheet of all of the lab test values for proteins and fats (as well as the test values for the dietary minerals that are not disclosed on the label).

 

7.) TOTAL LIVE GUARANTEED BACTERIA: The label value of 130,000 CFUs is interesting, but less than informative as an actual suggested daily intake value for the prebiotics and probiotics. The literature seems to suggest that to be beneficial, CFUs need to be present in the millions to many billions. So it is unclear if this is a nutritionally tested and verified value, or simply included in a relatively smaller quantity as a popular marketing strategy. At any rate, it is unclear that it would provide significant benefit to the wild mammal babies.

 

8.) CALORIE CONTENT: This value is somewhat confusing in that it does not disclose the method used for the calculation (standard Atwater or the modified version preferred by AAFCO for pet foods). WildAgain's spreadsheet shows a consistently calculated value for all products using the Atwater system.  Powdered milks are considered to have reasonable digestibility properties and generally not measured using the AAFCO system with lower kcal values.

 

9.) PRODUCT RECOMMENDATION: Interestingly, the very last sentence probably offers some of the best guidance on the label, indicating the product is for INTERMITTENT or SUPPLEMENTAL use only, and not intended to be a 'sole-source' diet. Follow this link for more on that topic. 

 

 

A deeper dive into a Fox Valley label

 

The label to the right is from a 1# package of Fox Valley 20/50. The following is a very brief discussion addressing the various disclosures included on the label.

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1.)  PRODUCT DESCRIPTION: The excerpt from the front label states that this product is intended for squirrels 4 weeks and older. The rear label expands this recommendation to species having a low protein and high fat requirement for neonatal growth. However, when comparing this product mixed 1:2 with water, WildAgain's nutritional calculator indicates that this product is not a close match to squirrel milk. In reality, all the label actually indicates that this is a formulation that contains a minimum protein content of 20% and a fat content of 50%. That's all. For this and other Fox Valley milk replacers.

 

The label also contains a lot number and expiration date. Follow this link to decode the lot number.

 

2.) GUARANTEED ANALYSIS:

As mentioned above, not all lots tested adhered to these guaranteed values. Click here to see a detailed spreadsheet of all of the lab test values for proteins and fats (as well as the test values for the dietary minerals that are not disclosed on the label).

3.) INGREDIENTS: The list is presumed to follow the regulations that specify that ingredients be listed in their order of prominence in the product. In this instance, the first 5 listed are the primary ingredients and supply almost all of the primary nutrients. The rest of the list contains all of the vitamins, additives and supplements.

 

Regulations require that labels be updated within 6 months of a formulation (ingredients) change. In practice, it appears this time limit may be enforced if that time period exceeds two years.

 

4.) MIXING DIRECTIONS: The mixing directions infer this powered product is an 'instant-mix.' Yet WildAgain's extensive tests on reconstitution indicate that is not the case. It now seems that optimum reconstitution is now more individualized to each milk replacer product, depending on the water temp at time of mixing, and the resting period prior to use (allowing for more rehydration). The suggestion as to adding the powder to the water is appropriate since that improves the rehydration of the powder, as is storing reconstituted Fox Valley 20/50 in the refrigerator.

 

5.) FEEDING DIRECTIONS: Feeding directions for recipes, amounts and intervals are highly dependent on the species being fed. The directions provided on the label appear to be too general and vague to be useful. More importantly they may likely result in under/over feeding the animal.

 

6.) STORAGE INFORMATION: The manufacturer’s recommendation is to store the product in "cool, dry place" without specifying a temperature (room temp, refrigerator?). Since powdered milk products can spoil or degrade over just a few months, published research indicates storing in the freezer (0 degrees F) is a preferred alternative in order to preserve freshness (whether opened or unopened).

 

 

Some other info on the labels

 

Some of the labels indicate weights for the package or the product. These are at best estimates and only appear useful as to about how much (weight) is in the unopened package, can or tub.

 

The labels also indicate if the product is "made" in the USA (Fox Valley products), or PetAg®'s use of the designation of "crafted" in the USA (with imported and domestic ingredients). By regulation, Fox Valley must source all ingredients and manufacturing in the USA. While PetAg has chosen to pursue a wider range of ingredient suppliers outside the USA, they have stated that their products are still manufactured in the USA.

 

 

Conclusion

 

Information on labels may be helpful, or confusing, and even misleading. The labels can leave much to the imagination as to what they omit and choose not to disclose. WildAgain's lab test spreadsheet provides very recent test values for the various ingredients as well as valuable information on the dietary minerals, including calcium and phosphorus concentrations.

 

The major pet industry milk replacer manufacturers appear to meet the state and federal labeling requirements - but that's about it. And that's not much, as to nutritional composition. It would seem, as a consumer service, they could elect to move beyond the minimum label requirements and provide more insight into the products to allow the consumer to make more informed choices.

 

In the meantime, it is up to the (mammal) wildlife rehabilitation community to perform our own research and expand our education as to the diets we provide to the wild mammal babies in our care.