Do They Really Use Dead Dogs and Cats to Make Pet Food?

You may have read online, or heard someone tell you as a dog parent, “Did you know, euthanized cats and dogs are used to make dog food?”

Indeed, we’ve long had an article on this site asking whether this might be true, based on an old video of uncertain origin, in which the then AAFCO president suggested there was little to stop cats and dogs ending up in pet food — theoretically. This is an update of that article, based on facts.

Note, at no point did he suggest this ever happened. And, more importantly, since that video — estimated to be from 1998 — both regulation and scientific studies show that the answer to the question “Do they use dead dogs and cats to make pet food?” is no. Although not everything is rosy, which we’ll come to later.

So why has this urban myth about dead cats and dogs in pet food been perpetuated? No smoke without fire? A mistrust of dog food companies?

It persists in no small part because, on several separate occasions, dog food testing has found positive traces of an animal euthanasia drug. 

This has led worried commentators to assume this drug ended up there via the rendered remains of dogs or cats euthanized by vets at animal shelters, which then somehow made their way into dogs’ kibble.

We decided it was time to examine these rumors properly and correct some of the more worrying information flying around the internet.

The history of euthanasia drugs in dog food

The first time a euthanasia drug — pentobarbital, a drug you’ll read a lot about in this article — was discovered in the U.S. in pet food was in 1998, following a survey by the FDA. ¹ It added the caveat that, by testing dry dog food bought in one U.S. town (Laurel, MD), it was not representative of the U.S. as a whole. Indeed, the FDA says in the report: 

“The surveys represent a snapshot in time, and no conclusions about dog food in general can be made. For reasons described above, the survey information does not predict the likelihood of pentobarbital in a particular brand of dog food on the market today or in the future.”

²

Another controversy occurred in 2017 and 2018. This was triggered by the discovery of pentobarbital in certain batches of dog food following the death of a pug, which had consumed canned food from Evanger’s containing traces of the drug ³. 

The drug, however, didn’t come from dead cats or dogs. The vice president of Evanger’s Dog and Cat Food Company, Joel Sher, said a now-former supplier sent his company beef from at least one cow that had been euthanized with pentobarbital ⁴.

There were also voluntary recalls issued by JM Smucker after low levels of pentobarbital contamination were identified from beef fat in its Gravy Train, Kibbles N Bits, Ol’ Roy and Skippy canned wet food. 

The levels were not high enough to “pose a threat to pet safety”, according to JM Smucker Co. spokesman Ray Hancart in a statement released at the time.

How can pentobarbital get into pet food?

The drug pentobarbital is used mainly to euthanize animals, so the main way it enters the pet food chain is via rendered animal products — where waste animal tissue and carcasses are converted into materials that can be used in animal feed at extremely high temperatures. The drug appears to be able to survive the rendering process.

As pentobarbital is used to euthanize dogs and cats, some people have assumed that the reason testing has found it present in pet food was via rendered euthanized dogs and cats. 

However, investigations in 1998 and 2000 tested the protein of the meat in pet food that had tested positive for pentobarbital for the presence of dog or cat DNA. The results from food that tested positive for pentobarbital and samples that were negative showed a total absence of dog or cat DNA ⁵.

As a result, it’s presumed in this case that the drug entered the pet food chain via euthanized cattle and/or horses, which at that point was unrestricted when it came to rendering.

A similar test to find pentobarbital in dog and cat food in 2004 found no trace of dog, cat or horse DNA in any of the samples ⁶. As the study concludes: 

“The results demonstrated a lack of correlation between species identity and the presence of pentobarbital in dog food. They also provide evidence against the presumption that euthanized pets are routinely rendered and used in pet food.”

However, it appeared that pentobarbital from euthanized cattle or horses was still being given to pet food manufacturers in tallow from external suppliers. 

What is the current law regarding pentobarbital in dog food?

In the U.S., it’s against FDA guidelines for dog food manufacturers to knowingly use euthanized animals in their pet food products ⁷. 

A spokesperson for the FDA told Dog Food Advisor: “There is currently no set tolerance for pentobarbital in pet food and FDA considers pet food containing pentobarbital residues to be adulterated under the Federal Food, Drug, and Cosmetic Act (FD&C Act). Pentobarbital residues are not affected by rendering or canning temperatures and pressures [such as heat treatments capable of killing pathogenic organisms].”

What this means is that there is no acceptable amount of pentobarbital in pet food. Whereas some substances, such as mycotoxins, are allowed in pet food at very low levels, pentobarbital is completely forbidden.

The spokesperson continued: “There are several different players connected to the issue of pentobarbital in animal food, including livestock producers, horse owners, veterinarians, renderers, haulers, and animal food manufacturers, and each has a role in preventing pet food contamination from pentobarbital residues. 

“In general, pet food manufacturers are responsible for taking appropriate steps to ensure that the food they produce is safe and properly labeled. One way a manufacturer can do this is by verifying the identity and safety of the ingredients they receive from their suppliers.”

The FDA believes that the Food Safety Modernization Act (FSMA) requirements for animal food manufacturers help prevent contamination, including pentobarbital contamination.

“The FSMA requires certain animal food facilities to create and implement a food safety plan, including an analysis of potential hazards and determining if there are hazards requiring preventive controls to reduce or eliminate those safety hazards,” added the spokesperson. 

All pet food manufacturing firms had to meet these standards by 2019.

FDA’s Guidance for Industry #245: Hazard Analysis and Risk-Based Preventive Controls for Food for Animals specifically mentions residues of pentobarbital in pet food as an example of a known or reasonably foreseeable hazard that would require a preventive control.

Following the 2017 and 2018 pet food product recalls due to the presence of pentobarbital outlined above, the FDA communicated that no level of pentobarbital in pet food is acceptable. As a result, the agency encouraged stakeholders to work together to investigate the issue and determine appropriate solutions. 

“Since that time, the FDA is not aware of any subsequent incidents with pentobarbital contamination of pet food,” said the spokesperson.

What about other types of euthanasia drugs?

Pentobarbital is the main drug used for euthanasia in the U.S. A shortage of the drug in 2021 led to some vets using other drugs to euthanize animals. A number of veterinarians used potassium chloride (KCl) and T-61, a euthanasia solution containing embutramide, mebozonium iodide, and tetracaine hydrochloride ⁸. 

In terms of these drugs potentially entering the pet food chain, potassium chloride — which is potassium and salt — is sometimes used to euthanize large animals due to its lack of “dangerous carcass residues” ⁹. 

T-61, meanwhile, according to a 1983 report, “should not be injected into food animals designated for human or animal consumption” ¹⁰. 

Other injectable methods used include intrathecal lidocaine and magnesium sulphate.

Lidocaine is sometimes used to euthanize horses — a 2016 study found that lidocaine in horse carcasses provided a “low risk of toxicity for carnivores and scavengers that might consume muscle tissue from a carcass” ¹¹. The study also found that lidocaine was used post-anesthesia, so in this case xylazine hydrochloride, midazolam hydrochloride, and ketamine hydrochloride were also used. Residues of these drugs were found in the carcass, but at levels “lower than those likely to cause sedation or toxicity if ingested”.

Magnesium sulphate — essentially Epsom salts in a saturated concentration — presents no issues with carcass disposal.

Either way, most cattle are euthanized via gunshot (see below), so any euthanasia drugs — especially following the FSMA — should not be making their way into the pet food chain.

Should you worry about euthanized pets being in your dog’s food?

The short answer is no.

However, as reported above, there have been a number of cases where euthaniasia drugs have been detected in dog food. 

As a result of the FDA guidance, in August 2019, the National Rendering Association (NRA) sent a letter requesting veterinarians help when it came to euthanising livestock. In order to stop euthanasia drugs entering the pet food chain following the FDA ban on any drugs being allowed in pet food, the association requested vets use other means to euthanize livestock, such as “such as captive bolt or gunshot” ¹². 

They also request that if pentobarbital is used, that the carcass is marked and identified, so it does not get rendered for pet food. 

As a result, some rendering companies have made changes to their process, including no longer accepting horse mortalities for rendering and requiring raw material suppliers to sign a barbiturate hazard control warranty before collection.

These new FDA rules also changed the way rendering suppliers processed euthanized cattle, thereby reducing the chance of pentobarbital entering pet food manufacturers’ recipes. 

It’s also worth noting at this point that if pentobarbital does make its way into pet food via a cow carcass, the affected material is spread across large quantities during the manufacturing process, making it less potent as it’s diluted to a point where no adverse effects are experienced by any animals that consume the food. 

Measures such as this have helped reduce the risk of pentobarbital entering the pet food chain, meaning your dog is at a much lower risk of consuming any food from cattle euthanized with pentobarbital.

It also means that, despite some websites claiming otherwise, your dog’s food does not contain dead pets.