Black Foot Raw

Food Factory



Very often, experts will argue against raw feeding, especially against PMR (Prey Model Raw), stating that deficiencies in nutrients will show up in the long run… and that raw diets have to be compliant to AAFCO or NRC standards to be considered ‘balanced’ and ‘complete’ for the pet in the long run.


And you know what? They are not totally wrong. An ill-devised raw diet may reap immediate tangible benefits in the short run (better coat, better poop, etc.) but might also eventually cause your dog to drool controllably like a zombie (symptoms of thiamin deficiency) or your cat to go blind and start walking into walls, as well as jumping off their cat trees and landing with their heads (vitamin E deficiency).


However, neither AAFCO’s nor NRC’s dietary guidelines are well-suited to assess a raw diet.


That would be like refereeing football with rugby rules. You would have players with broken legs and collapsed lungs on the pitch and play would still go on. Or maybe this helps explain better. The recommended diet for someone who drinks Coke on a daily basis would be different from someone who drinks kefir every day. One is all sugar without any nutrients, yes, same goes for diet coke, and the other is chock full of nutrients and probiotics, causing different kinds of metabolic processes to the body. Obviously, the nutrient requirements for a pet on a high carbohydrate kibble diet using synthetic supplements with low bioavailability would be different from that of a pet feeding on a species appropriate raw diet.


For one, thiamin would be needed in much higher levels for pets on a kibble diet to metabolise the carbs.


I mean, really… which bowl looks in serious need of supplementing?




The Association of American Feed Control Officials (AAFCO) is an organization responsible for providing the standards and recommendations for both companion animal and livestock feeds.


Currently there are three statements pet foods can have on their label that’s AAFCO approved. These statements are (


1. “Animal feeding tests using AAFCO procedures substantiate this product provides complete and balanced nutrition for all life stages of dogs and cats.” This means the company chose to conduct feeding trials on their food. Presently, only eight dogs are required to be in an AAFCO feeding trial and only six have to complete it for that trial to qualify. These trials are only run for 26 weeks and only 4 values -hemoglobin, packed cell volume, serum alkaline phosphatase (SAP) and serum albumin are evaluated. There is no full blood chemistry panel, no complete blood count and no urinalysis required.

Before and after the trial a veterinarian will examine the dogs and look for clinical signs of nutritional disease, but unless a food is obviously mis-formulated, it’s highly unlikely the dog will develop clinical signs of a problem within this short period of time. According to David Dzanis of the FDA, “Especially in the maintenance trials, subtle chronic nutrient deficiencies or excesses can be overlooked.”


2. “This product is formulated to meet the nutritional levels established by the AAFCO Dog and Cat Food Nutrient Profiles for All Life Stages (or for growth).” Rather than doing feed trials these manufacturers choose to formulate their food to meet AAFCO nutritional panels.


3. “This product is intended for intermittent or supplemental feeding only.” This means the food does not meet AAFCO nutrient profiles. You’ll notice a lot of commercial raw foods display this on their label, which doesn’t mean a thing, since AAFCO’s standards should only be applied to kibble diets.





By definition The National Research Council (NRC) produces reports that shape policies, inform public opinion, and advance the pursuit of science, engineering, and medicine.




It’s 14 years outdated. The first edition was in the 80’s and the current one was published in 2006. (Bones had not even been tested for nutrient profile then – Cliff 2021)


Testing is also not done fresh ingredients, instead, researchers had utilised ingredients ‘commonly produced and commercially available.’ These included genetically modified grains (GMO’s) and rendered meat meals, including those sourced from dead, diseased, dying, and disabled animals (4D meats).


The study was partly funded by the Pet Food Institute, which contributed a voice in stating result expectations from the study, as well as much information relevant to the study. A bit like the 80s when Philips Morris funded research on health consequences of smoking and provided ‘helpful’ information like smoking can increase metabolism.


Some of the board members of the study include:


Gail L. Czarnecki-Maulden – senior research nutritionist at Nestle Purina PetCare, also AAFCO’s Canine and Feline Nutrition Experts Subcommittees.


Gary F. Hartnell – a Senior Fellow of GMO grain company, Monsanto.


Robbin S. Johnson – President of Cargill Foundation, mega agriculture and food corporation.


… and many more with connections to the food industry.


Don’t take it from me. In 2006, the Center for Science in the Public Interest published a report detailing “serious breaches” to conflict of interest.


NAS did a poor job of balancing points of view on a majority of the study panels examined. The NAS does not appear to consider information about potential bias or conflicts of interest prior to nominating individuals to a committee. As a result, about half the panels examined had scientists with identifiable biases who were not offset by scientists with alternative points of view…..” 

(NAS the National Academy of Science of which the NRC is the working arm)



On Supplements

To meet the nutritional requirements, most pet food companies add synthetic supplements into kibbles. However, these supplements very often do not possess high bioavailability. Also, the additives create ongoing metabolic stresses that could cause tissue malnutrition (Ron Carsten DVM MS, The Benefits of Whole Food Nutrition in Veterinary Medicine, Whole Food Nutrition Journal).


Zinc, a ‘problem’ area in raw food diets is problematic only according to the standards set by AAFCO measured on a kibble diet. The low bioavailability in kibble caused by phytates binding with zinc leads to minimum zinc amounts being higher than it should be for a pet eating a natural diet.



Balanced and Complete 

Many raw food formulators have adopted the ‘complete and balanced’ tag by following AAFCO’s guidelines, and that includes Blackfoot. This is mostly due to  appealing to public perception as  educating consumers take some time. In fact, by our research, nutritional excesses would arise from in a raw diet when kept strictly to AAFCO’s recommendations and due to the synergistic and antagonistic nature of nutrients, deficiencies would follow. Therefore, we had to put in extra work to adjust other nutrients to recreate balance. Eg. because we had to raise zinc levels to meet requirements, we had to raise copper as well, as zinc and copper compete for absorption.


The Takeaway

That pets are surviving and some into their late years does prove that there might be good things we can refer to out of NRC’s and AAFCO’s recommendations, but we also know that a lot of pets are stricken with debilitating medical conditions associated with modern, highly-processed foods. This is not to say that pets on a properly devised raw food diet would be free from such chronic conditions, but based on countless case studies and research, we can say that the risk and rate would be much lower than pets on a lifetime of high-processed diet.