Clarification on AAFCO “Natural” Definition and Microbial Ingredients

Hey all,

I get that I'm probably being too literal here and causing myself undue stress, but as far as I can tell, the public facing definition of "Natural" from AAFCO regarding feed ingredients excludes microbial ingredients, such as probiotic bacterial or fungal cells (and I suppose larger fungus forms such as mushrooms / mushroom powders).

The current definition on aafco.org includes:

“A feed or feed ingredient derived solely from plant, animal, or mined sources…”

Technically, a bacterial or fungal cell, taxonomically, does not fall under plant, animal, and certainly not as a "mined source". 

I've had people we supply to ask for signed statements regarding our ingredients "natural" status specific to AAFCO's definition, and I haven't been able to attest to anything other than by technicality, these ingredients fall outside the scope of AAFCO's definition.

I've contacted AAFCO on this asking for clarification and/or precedent for this situation, but I was curious:

a. If any of you have dealt with this specifically before

b. If anyone had thoughts/comments on this perceived technical failing of AAFCO's definition.

Thanks!

To me it literally falls under that category. 

They don't allow full view of their materials to non-members, but I found this link on their website: Natural | AAFCO

What's handy is, while their definition of "natural" is a bit narrow in scope surrounding your microbiological add-ins, they have a "Not Natural" section describing specifically what is not considered natural per their definition: "Ingredients that are chemically synthesized, such as vitamin ingredients, mineral ingredients, preservatives and special-purpose food additives."

I don't think you're wrong to be overthinking this.  I know very little about pet food, but quick searching just now says a fair number of states have adopted AAFCO standards and they also work with the FDA.  I'm curious what AAFCO will tell you regarding probiotics and fungal cells, but so long as they aren't "artificial or synthetic," they meet FDA's informal guidelines for "natural" in human food.

Is your company claiming "Natural" on the label?  I think you're fine, and if your customers are asking, I think it's fine to tell them that your product is natural in that it contains no chemically synthesized ingredients (so long as your probiotics or fungals aren't manufactured that way).  Health benefits of probiotic and fungal ingredients are widely regarded as beneficial, so I agree that AAFCO is being a bit too narrow with animal, vegetable, or mineral in their definition.