Are Raw Diets Complete and Balanced (and does it matter)?


Just because raw diets don’t meet AAFCO standards doesn’t mean they’re not nutritious!

You’ve probably heard of AAFCO – the American Association of Feed Control Officials. It’s the body that sets standards for pet foods and animal feeds in the US. When you buy dog food that claims to be “complete and balanced,” it meets AAFCO dog food standards. (Keep reading to find out how easy it is for even poor quality foods to meet those standards.)

But when it comes to pre-made raw dog food, few claim to meet AAFCO standards for “complete and balanced.”  If you’re worried about feeding an unbalanced diet, that might stop you from switching your dog to raw food. And that’s unfortunate. Most dogs thrive and are much healthier on raw diets and fresh whole foods.


Most veterinarians also have complete trust in AAFCO standards. They think it’s fine to recommend any food that meets AAFCO standards. They often frown on dog owners who raw feed their dogs. As a raw feeder, I once had a conventional vet tell me, “I don’t think you’re feeding your dog a balanced diet, but I don’t know why. They didn’t teach us much about nutrition in vet school.”

That’s quite an admission. But she’d have been satisfied if I’d been feeding some cheap grocery store kibble that said it was complete and balanced. And as she examined my dog, she admitted he was in robust physical health.

It’s a big mistake on the part of most vets to blindly follow the AAFCO standards. They’re not what most people think they are.


Well-known Australian vet Dr Ian Billinghurst has a different opinion on AAFCO standards. Dr Bililnghurst authored groundbreaking books like Give Your Dog A Bone in 1993 and Grow Your Pups With Bones in 1998. He’s famous for creating the concept of BARF (Bones and Raw Food or Biologically Appropriate Raw (or Real) Food). He released his third book, The BARF Diet, in 2001.

Dr Billinghurst is very critical of AAFCO standards. He says they’re based on flawed science and are not designed to keep animals in good health. 90 to 95% of dogs who get diseases like cancer, autoimmune diseases, allergies, renal failure or irritable bowel diseases developed their diseases after a lifetime of eating foods that passed AAFCO standards.


Dr Billinghurst calls commercial processed pet foods Fake Industrial Foods (FIFs). They’re highly denatured products with ingredients from industrial food waste. They depend on carbohydrates (mainly grains or other starches) for energy. Compare that to a raw, fresh whole foods diet, which uses fats and proteins as its energy source.

And it’s easy for these poor quality fake industrial foods to pass AAFCO “complete and balanced” standards.


So, what does “complete and balanced” mean?

“Complete” means a food contains all nutrients that AAFCO classifies as essential for a dog. It meets standards of completeness designed and currently approved by an AAFCO committee. AAFCO guidelines are always changing. These standards may be different next week or next year and certainly next decade.

“Balanced” means the food contains nutrients in proportions that are currently approved by AAFCO. Again, these standards will likely change in the not too distant future.

The problem is, AAFCO itself doesn’t really know what nutrients dogs need biologically. That’s why the information is always changing.

According to Dr Billinghurst:

“Careful examination of the AAFCO guidelines reveal them to be a collection of compromises, guesses and opinions – and the writers freely admit it throughout the text!”

The guide makes no mention of whole raw foods. At best it’s a guide to help processed food manufacturers make industrial food out of substandard material, and it’s of no value to anyone who wants to give their dogs genuinely healthy food.


AAFCO standards are based on what they call “commonly used ingredients.” These ingredients are specific sources of carbohydrates, fat, fiber and protein, chosen for their cheapness. In nearly every case, these foods need to have vitamins and minerals added. Otherwise they would never pass AAFCO standards. Some examples of these commonly used ingredients include:

  • Meat and bone meal
  • Animal byproduct meal
  • Fish meal
  • Chicken liver meal
  • Peanut hulls
  • Cellulose
  • Soybean hulls
  • Vegetable oils
  • … and more

These and other common ingredients are all nutritionally poor, especially because they’ve been subjected to extreme heat before and during the manufacturing process. Fats become toxic due to heat damage, and the heat causes chemical reactions between ingredients, producing substances that are often toxic and sometimes carcinogenic. The heat also means the bioavailability of these foods after heat processing is highly questionable. AAFCO recognizes this problem.

You’ll notice that raw foods don’t contain these types of ingredients. So how can AAFCO standards possibly apply to raw?


Processed food manufacturers can meet AAFCO standards in two ways.


In the analytical method, the food is chemically analyzed to prove it meets AAFCO standards. A food made of cardboard, shoe leather, sump oil, blood and bone fertilizer with a vitamin and mineral premix will pass these standards with flying colors!


Astonishingly, the AAFCO rules say that if a food passes the feeding trial method, it doesn’t matter whether or not it passes the analytical method.

And the protocols for the feeding trials are so lenient that just about any food will pass:

  • There must be eight animals in the trial (not a statistically significant number)
  • Of the eight, two can drop out (for any reason) so only six need to complete the trial
  • Breed or sex is irrelevant
  • The trial length is 26 weeks
  • The animals are only fed the food being tested
  • They must have unlimited water
  • The animals must be pronounced healthy in pre- and post-trial veterinary exams
  • Four blood values (hemoglobin, PCV, alkaline phosphatase and albumin) are measured and the averages are compared to specified minimums

There’s no examination of urine, stools or any other blood measurements that vets routinely use to assess health.


So a food will pass the feeding trial as long as it keeps 6 out of 8 dogs alive for 26 weeks, one of more of them don’t lose more than 15% bodyweight and no blood values are below the specified minimum.

It would be an extremely poor food that would fail these parameters.

And remember, if the food passes the feeding trial, the chemical analysis becomes irrelevant!

When you see nutritionally poor foods pass these feeding trials, it’s easy to conclude that any properly formulated raw food will easily pass.


Dr Billinghurst uses the term Evolutionary Nutrition to describe a fresh whole raw food diet. Other names used are a species appropriate or natural diet.

Evolutionary nutrition:

  • Feeds animals the diet they evolved to require.
  • Based on the principles of Darwinian evolution. These are the same principles that underpin molecular biology, the sequencing of the genome and modern medical science … real science!

Formulating an evolutionary nutritional program depends on knowing the range and balance of whole raw foods an animal evolved to eat over millions of years of its genetic adaptation.


Read these principles, and you’ll understand why the AAFCO standards are completely irrelevant when it comes to an evolutionary, raw food diet.

  • The food is raw and unprocessed. This makes nutrients completely bioavailable to the extent the body needs them.
  • The material used duplicates or mimics whole raw foods that the animal’s ancestors would have eaten.
  • There’s no list of required nutrients! This information isn’t necessary (and isn’t actually known). What the animal evolved eating contains by definition every nutrient it requires, both known and unknown. The body’s homeostatic mechanisms ensure proper nutritional balance … the body takes what it needs.
  • There are no requirements for detailed rules. Just feed whole raw foods the animal evolved to require.
  • There’s no cooking so the components can be ground and mixed together with no likelihood of chemical reactions between the components.
  • It doesn’t depend on the opinions of a committee of nutritional experts but relies on feeding a wide range of whole raw foods an animal evolved to eat. There’s no big book!
  • No changes are needed, All the principles are constant and remain valid.
  • There’s no conflict between the principles and any feeding trials (contrast this with the FIF paradigm).
  • The foods are legally and biologically complete and balanced! They’d pass the AAFCO feeding trials and meet biological needs because raw food provides nutrients we know to be essential – and others like important phytonutrients, which AAFCO completely disregards.


  • When you raw-feed your dog, you meet all his nutritional requirements without having to understand any modern nutritional science whatsoever.
  • This is how dogs have survived and thrived throughout their evolution.
  • Evolutionary nutrition is the gold standard.
  • It allows the animal to reach his genetic potential for health, longevity, physical activity and reproduction.
  • The further an animal diet departs from the evolutionary diet, the more health problems are likely to develop.


Dr Billinghurst recommends feeding meats, bones, vegetables and organ meats. You can also add other healthy human foods like eggs and milk products. Supplements such as Essential Fatty Acids, probiotics, kelp, alfalfa, various herbs help replace what a dog would consume in nature.

If you’re new to raw, here’s how to get started feeding your dog a healthy whole raw food diet

Dr Billinghurst wishes more raw food manufacturers would participate in the AAFCO feeding trials, so that vets and others can see that raw diets do in fact meet the standards for “complete and balanced.”

He says that every dog he’s ever owned passed the equivalent of the AAFCO feeding trials. They’ve only ever eaten raw whole foods and they’ve passed vet exams and blood tests. They’ve maintained their weight and have rarely required his services as a vet.

It’s the same with other raw fed dogs around the world. Don’t be afraid to try a fresh, whole foods raw diet for your dog too!

If you’re already a raw feeder, visit your vet with your healthy dog, ask for blood work and let the vet witness the benefits of a raw diet! This is veterinary post-graduate training – by you and your healthy raw-fed dog!



Julia Henriques is Managing Editor of Dogs Naturally Magazine. A former international banker, she lives in Chicago with her partner Marc and two rescue Samoyeds. She volunteers on the board of Playing Again Sams (Wisconsin Samoyed Rescue).


Older Post Newer Post