They promise much, but do they deliver, and might they even harm?
This Stigmochelys pardalis (Leopard tortoise) was raised on a diet of mixed mass-market tortoise 'pellet' foods with fruit and 'vegetables' as suggested by the manufacturer.
People like convenience. They shop at 'convenience' stores, eat 'convenient' (processed) foods, and are clearly prepared to pay for this, in the latter case despite a convincing and growing body of scientific evidence that ultra-processed foods especially are associated with a range of serious health conditions and might even shorten their own lives. Convenience can indeed come at a heavy price.
Managing the diets of herbivorous reptiles is especially challenging. Animals such as tortoises and, say, green iguanas rely upon a complex number of interactions between their diet and environment, for one thing. In the case of temperate species, there are profound seasonal cycles, reflected not only in what is eaten at various times of year, but also in the quantities of food available - from relative plenty in spring, to a strong reduction and then nothing at all as the wheel of the seasons turns. Some tortoise species, for example, have been noted as consuming as many as 150 different species of wild plants throughout the year, sometimes young and fresh, but later dry. Different species, in different locations, also feed upon different species of vegetation, which makes attempts to formulate an 'average' diet suitable for a range of different tortoises very difficult indeed. Certainly providing a 'universal' diet is neither advisable, or indeed in our opinion, possible.
A young adult female Testudo graeca graeca in the wild here in Spain, 100% raised on a diet of natural vegetation and with zero human intervention.
To some extent manufacturers have recognised this and now market packaged, usually pelleted, foods aimed at different (albeit rather broad) dietary categories such as 'Grassland Tortoise', 'Forest Tortoise' or 'Tropical Tortoise' diets. In the many cases the claim is made that these products are 'scientifically formulated', 'developed by nutritionists', 'formulated by Ph.D. nutritionists', 'zoo-vet approved' or offer 'complete nutrition'. However, in our opinion it does not take too long after surveying the formulations and detailed descriptions to give rise to serious doubts in respect of both claims.
Unfortunately it is very clear that many buyers of these products do not have sufficient technical knowledge or experience to form a balanced judgement. Hence, we frequently see in groups and forums comments such as "If zoos use it, it must be OK", "My tortoise loves it and now won't eat anything else" (children love chocolates and fries, but they are not a healthy diet), and "It was designed by scientists who must know their job". Buyers like this are a dream for manufacturers. Less popular are those who ask questions and demand answers.
One fundamental problem is that although legislation does exist, at least in Europe, regarding the veracity and accuracy of claims made for both domestic and agricultural animal feeds, many of these products are imported from areas where little or no such regulation exists, and that in any event, despite the existence of such legislation, practical enforcement appears to be minimal. In other words, manufacturers can 'get away with it' unless reported or challenged.
We directly approached several manufacturers requesting verification and supporting evidence for some of the claims that they made in their marketing materials. It is telling that not a single one of them was willing or able to produce the information that we requested. This is extremely concerning. Indeed, it is a legal requirement that they are able to prove the claims made in a clear and understandable manner.
This makes it clear that any person producing such a product for sale in the jurisdiction covered by this legislation (in this case the UK and the EU) must be able to provide either publicly available scientific evidence or internal documented company research, of an acceptable level of 'scientific substantiation' of the claims made, for example, that the food is 'complete' nutrition or that the individual ingredients are beneficial and not harmful.
We asked very simple, direct questions.
For example we asked one manufacturer for supporting evidence that the inclusion of bee pollen in a herbivorous tortoise diet was appropriate and safe. None was provided.
This is frankly unacceptable. Purchasers should have an absolute right to know the basis upon which the foods that they are encouraged to feed their animals have been formulated, and that objective evidence is available that supports the claims made in advertisements and upon the packaging.
There is further legislation that affects precisely what ingredients can be included. They must meet certain standards and (again) objective evidence must be available that they are beneficial and not harmful, and that they must positively benefit, for example, the gastrointestinal flora and digestibility. It should be noted that this requirement must be measured against what is healthy and appropriate for the animal in question and that 'more' is not necessarily 'better' in the context of naturally slow-fermenting herbivorous reptiles. This is an important point as many of these foods include probiotic 'boosters' and ingredients such as yeasts aimed at accelerating digestibility (examples would include Lactobacillus acidophilus, Lactobacillus casei, Bifidobacterium thermophilum, Enterococcus faecium). This is, to us, one area of particular concern as we would argue that all available credible scentific and veterinary evidence suggests that artificially accelerating the digestive function in hind-gut fermenters such as herbivorous lizards (for example, Green iguanas) or herbivorous tortoises is highly damaging and will have long-term, irreversible effects upon development and health. In particular, boosting digestibility will have a direct effect upon the absorption rate of nutrients, and in turn, will cause accelerated rates of growth. Such accelerated rates of growth are generally accepted to greatly increase the incidence and severity of MBD, or Metabolic Bone Disease in tortoises among other negative impacts. One of those additional negative impacts is that accelerated fermentation can lead to a change in the normal, healthy range of pH (acidity-alkalinity) in the gut, and this in turn can cause additional very serious health issues, similar to a condition known as 'ruminal acidosis' which occurs in cattle and goats, for example. It is directly caused by the ingestion of large amounts of highly fermentable, carbohydrate-rich feeds, which result in the excessive production and accumulation of acids in the rumen. It can be fatal. If we look closely at the ingredients lists of many of these tortoise products we cannot fail to be concerned about this as they too typically are much more fermentable than the wild diet, and IN ADDITION include yeasts (for example, brewer's yeast), probiotics and other items specifically intended to accelerate fermentation. Further, the manufacturer's own feeding advice often includes suggestions to add other items such as fresh fruits and 'vegetables' that will add further to an already accelerated rate of fermentation.
Very high intakes of carbohydrates such as starches and sugars can overwhelm the system and ferment much more quickly than the fibre contained in dry grasses and hays. The result is a massive increase in acids produced by bacterial action. These acids are primarily acetic, propionic and butyric acid with lower levels of lactic acid and VFA's (McBee and McBee, 1982). Following over-consumption of starches and sugars the pH of the gut shifts to become highly acidic initiating a chain of serious consequences (typical gut pH ranges of herbivorous reptiles are in the order of 6.8-7.0). One particularly serious effect is the generation of high levels of endotoxins produced as the normal symbiotic and commensal gut bacteria begin to die in the out-of-range acidic environment created (approximately pH <5.5). The gut wall integrity can begin to degrade in these conditions, causing subsequent malabsorption of nutrients. Liver abscessing is a typical consequence of this condition as bacteria are absorbed into the bloodstream via the degraded gut wall, and seed themselves in the liver. In this context it is important to take note of the fact that liver diseases are one of the most common causes of death in captive arid habitat chelonia, representing up to 72.6% of all mortalities studied (Rosskopf, Howard, Gendron, Walder, and Britt, 1981). Some of the foods most commonly associated with causing severe gastric disruption (including sudden death) in arid habitat and savannah species in captivity include peaches, plums, pears and apples - all of which are very high in easily digestible soluble carbohydrates and fruit sugars. Species that appear particularly susceptible to such problems include:
Leopard tortoises (Stigmochelys pardalis)
African Spurred tortoises (Centrochelys sulcata)
Mediterranean Testudo species
Russian tortoise (Testudo horsfieldii)
Indian Star tortoises (Geochelone elegans)
North American Gopherus species
South African Homopus, Psammobates and Chersina species
Pancake tortoises (Malacochersus tornieri)
Radiated tortoises (Geochelone radiata)
Meadow and orchard hays represent the most acceptable form of supplemental fibre for most semi-arid and savannah tortoise species. Many Geochelone, Gopherus and Testudo species naturally experience a shift toward drier, hay-type foods as the moist spring advances towards the dry summer season. At such times, the availability high moisture-content spring annuals declines sharply, and instead tortoises are observed to pick at dry leaves, stems, dry flower heads and seed pods. With many species, they then retreat into estivation for several months, emerging rarely, or not at all, until the onset of autumn rains.
This is what the legislation says on this matter:
Another specific range of additives that are widely included in many of these products are 'pure' amino acids. Certainly some amino acids are found in 'raw' plant materials, and this is how they are accessed by wild, grazing tortoises. Others are internally synthesised during the digestive process. One immediate issue is that we simply do not have sufficient scientific information on precisely what amino acids they need, in what forms, and in particular or how much they need of each. Hence providing additional amino-acids as supplements is intrinsically high risk as we could be inadvertently providing an excess or imbalance. At least one tortoise food manufacturer (Kapidolo Farms, in the US) directly acknowledges this problem and instead provides an optional pack of entirely natural leaves selected to provide a broad cross-section of 'essential' amino acids based upon our current knowledge of human and mammalian nutrition. This is, we feel, a far safer route than (in effect) 'force feeding' the concentrated chemical forms in every meal. The results of the latter are likely to be unpredictable at best over the long term. We cannot objectively substantiate this, but we ourselves have observed what we believe to be a pattern of excess keratin growth (claws, beaks and shell) in tortoises with a history of the keeper using supplements or feed with amino acid supplements.
Vitamin additives fall into the same category, in that we have no direct evidence whatever that it is necessary (or safe in the long-term) to supplement daily - an inevitable result of using these products. Genuine cases of vitamin deficiency, with the exception of vitamin-D3 resulting from inadequate exposure to UV-B and heat, are incredibly rare even in the veterinary literature. We can ourselves recall encountering just one such case in the past fourty years, and that was in a tortoise (a Testudo hermanni) that had been maintained on what by any standards was an exceedingly deficient and limited diet (lettuce only for over 10 years). The suggestion that general vitamin deficiencies in captive tortoises are common is simply not supported by the facts. If keepers are concerned, then use of an optional multi-vitamin supplement occasionally (or more frequently under veterinary direction) should more than remove any cause for worry on this point. On the other hand, we are aware of multiple cases of over-supplementation causing direct harm and even fatalities. Specifically, over-dosing on vitamin-A and orally-delivered vitamin D3.
On a reasonably varied and balanced diet, appropriate for the species in question, only minimal vitamin supplementation on an occasional basis is justified by the evidence.
There are two further elements that need to be considered. Calcium content and fibre. We have written extensively on the critical importance of fibre, not only to digestive health but also to helping to prevent intestinal impactions in tortoises. We will not go over the same ground here, except to comment that very few of these products approach the fibre levels provided by free-ranging wild diets. It should also be noted that the manner in which the 'guaranteed analysis' is presented could often best be described as 'optimistic'. For example, 'crude fibre not less than 16%', whereas a typical 'wild' intake would range upwards from 30% for many species. Further, the processing involved in production of many of these products (extrusion, often involving heat processes) seriously depletes the availability of critical long fibres. Cold pressing and minimal disturbance to the coarse fibres is to be preferred. To be fair, some manufacturers have - finally - recognised this and now do offer pressed pellets. Others, however, including 'major league' products have not and continue to offer packaged diets that are seriously deficient in this respect. Nonetheless, these products are marketed to unsuspecting buyers as 'complete', 'scientifically formulated' and with similar accompanying claims - "holistically formulated" is another entirely meaningless term that appears with regularity.
Certainly some routine calcium supplementation is unlikely to be harmful in any way, and given that most captive diets are deficient in this respect, the inclusion of calcium additives is one of the least causes of concern. That said, again it may be preferable that instead of 'automatically' including this with every meal, it would be best that keepers take control of this and use such supplements under either veterinary direction or according to their own considered schedule, taking into account all of the available variables. If the base diet is formulated correctly (with a minimum 2:1 calcium to phosphorus ratio) then additional daily supplementation would appear to be unnecessary.
It is also a stark fact that one of the most highly regarded and well-established 'packaged' tortoise foods on the market, with many years of successful use by experienced breeders includes NONE of these concentrated additives or 'weird' ingredients.
If this is so - which it is - one is justified in asking what on earth are people thinking when they include such things in their formulations or use them? We are referring to the German company 'Agrobs' and their 'Alpin' range (with whom we have no association whatever). This is essentially a mixture of 60 meadowland grasses and herbs, prepared to preserve as many long fibres as possible, and without any added amino acids, bee pollen, fruits, grain or soy derivates, probiotics, yeasts, dead insects or any of the other truly bizarre additives other companies seek to persuade keepers are 'necessary',
Clearly, they are not 'necessary'.
If they were 'necessary' it is reasonable to assume that we would all have heard complaints from users of 'Agrobs' diets by now (they have been on the market for many years). In fact the opposite is true and they receive near-universal praise from users and there would also be no wild tortoises either, as they are also spared these 'necessary' additives. They are also the only product of their kind that The Tortoise Trust currently feels confident in recommending in situations where a commercially available dietary is required. We feel that for several reasons 1) They most closely approximate the dry content of typical wild diets in terms of protein content and digestibility 2) They preserve the fibre levels well and (critically) 3) They do not include 'weird' unproven and poorly researched ingredients that manufacturer after manufacturer is either unable or unwilling to back up with publicly available and objective research findings
Our view is simple and direct: If you cannot demonstrate beyond reasonable doubt that it is a) Necessary b) Appropriate and c) Safe - don't include it.
The inadequacy of short-term feeding trials
Tortoises do not attain sexual maturity under normal conditions of growth until circa 12-15 years of age. This can occur earlier, but almost exclusively in connection with artificially accelerated rates of growth and with accompanying growth abnormalities such as MBD. Captive chelonians are frequently placed on diets richer in useable proteins and higher in phosphorus and digestibility by a factor of several magnitudes greater than they would possibly be able to attain in the wild, and this, combined with a relative deficiency in dietary calcium is a major and direct cause of mortalities in the m 1.5 to 1.75 year age group. The growth of such specimens is greatly accelerated, and full sexual maturity has been observed by the author in one captive bred male T. graeca ibera at just 19 months of age. This animal weighed 565g and had a carapace length of 148 mm. There was severe carapace deformity and generalised overgrowth of keratin with the beak being extremely overgrown to the extent of interfering with normal feeding.
Adult tortoises that already have an established skeleton and carapace can withstand extended periods of dietary inadequacy or excess without displaying any obvious symptoms. In order to fully trial a diet, such tests must be conducted over a sufficiently long period. The time-frame during which dietary problems manifest most rapidly and clearly is that from hatchling to moderately-sized juvenile, a period which, on average, equates to between five to seven years in most species. Dietary trial periods shorter than this are therefore unlikely to offer a realistic assessment of the performance of any given formulation or regime. We asked several different manufacturers to provide details of what feeding trials they conducted and to disclose the results, preferably including supportive evidence such as photographs that could be independently assessed for 'quality' of growth, defined here as normal, healthy development. Not one was prepared to do this - a fact that should really raise serious alarm bells with potential customers (we did not ask AGROBS as we have tested that ourselves, as have knowledgeable colleagues, over more than 15 years of regular use without observing any negative effects).
Potential buyers and users of these products should realise that until manufacturers in general are willing to provide full disclosure of the methodology of feeding trials, together with supporting evidence and results, they are entrusting the life and health of their own animals to little more than marketing 'blurb' and hype. The real 'Guinea pigs' here will not be the manufacturer's animals - it will be yours.
It is our considered opinion that a minimum feeding trial period should be of at least 5 years duration and should begin with hatchlings or tortoises under six months of age. Any less than that, and it will be difficult to obtain conclusive results. Photographs, weight and growth measurements should be taken every 6 months to document both rates of growth and any effects upon shell development. It is simply not enough to trial a product for a few months and then pronounce it safe and effective for general use.
Customers and potential users really do need to start asking questions (and demanding answers) on this subject rather than accepting all the marketing claims made at face value.
Manufacturer's feeding advice
"Normally tortoises feed from dawn till dusk, though often ignoring food during the warmest hours of the day. Feed as much as the tortise (sic) can consume in 12 hours. Fresh fruits and vegetables may be mixed in if so desired" (Source: T-Rex).
This is, sadly, typical useage advice which is mirrored by several manufacturers of such products. Very similar advice is provided by a UK manufacturer (Retics and Reptiles):
The US manufacturer 'Mazuri' also advises a similar regime:
Unfortunately, the provision of fruit and 'vegetables' to semi-arid grazing species of tortoise is entirely inappropriate in our opinion, and is, further, likely to prove extremely damaging. There are two key reasons for this. Both are far, far too digestible and are too high in sugars and carbohydrates. Additionally, they tend to be excessively high in phosphorus and there are numerous examples in the veterinary literature of cases where use of fresh fruit and vegetables (as opposed to the flowers, stalks and leaves consumed in a wild diet) has led directly to severe metabolic bone disease. The 20% by weight of total diet for 'vegetables' suggested by Mazuri is shockingly high, in our considered opinion, when in fact there is zero valid basis for including such inappropriate and damaging items at all.
Another example of a Stigmochelys pardalis (Leopard tortoise) displaying the classic signs of carapace reduction and skeletel thickening, with advanced deformity caused by rapid growth on a high energy, highly fermentable diet rich in phosphorus and low in calcium. This tortoise also was raised on mass-market pelleted foods, fruit and vegetables as directed by a pet store and as suggested by many manufactures of such products.
One might be forgiven for wondering where all the 'PhD. Nutritionists', 'Veterinary specialists' and 'Scientists' were when it was decided to issue this kind of advice to keepers? Perhaps they were on their lunch breaks?
We deliberately gave this article a 'provocative' title, referring to 'weird' ingredients. Considering some of the items that certain manufacturers see fit to include, we consider this to be more than justified.
Bee Pollen
This is not, as many might assume, simply flower pollen such as a grazing tortoise might actually encounter or consume in nature. It is a very different thing entirely. It is produced by bees within the hive for their own use as a high-energy food. Indeed, some term it a 'superfood'. A typical analysis suggests 40–60% simple sugars (fructose and glucose), 20–60% proteins, 3% minerals and vitamins, 1–32% fatty acids, and 5% miscellaneous components. Precisely why this would be required by any tortoise is a total mystery. Further, it should be clear to most with any degree of understanding of herbivorous tortoise digestive physiology that tortoises should not be receiving daily supplements of fructose and glucose, or of concentrated proteins with every meal.
Horseradish
This is a root vegetable of the Brassica family... grazing herbivorous tortoises do not encounter it (or anything like it) in the wild and the feeding of root vegetables to such species is not advised. In this case, however, there is an added dimension as one of it's more interesting components is a chemical called allyl isothiocyanate, which the plant employs as a defence mechanism against herbivores. Although this degrades over time, it seems to be a distinctly peculiar choice to - in effect - force feed to tortoises with every meal. We have yet to see a tortoise become ill as a result of 'horseradish deficiency' so it is really hard to understand the thought-processes behind including such a strange ingredient. Maybe you have to be a 'PhD. Nutritionist' to get it?
Yucca Extract
This is derived from the Mojave Yucca plant. Irrespective of anything else, quite why it is an appropriate thing to feed a Mediterranean Testudo species, or African species such as Centrochelys sulcata or Stigmochelys pardalis quite escapes us. It allegedly has anti-inflammatory properties and may help with joint pain in humans although medical journals state that there is "no good scientific evidence to support these uses". It is included in several popular brands of tortoise food for reasons best known only to those who formulated the product.
Cane and Beet Molasses
These are concentrated high energy syrups obtained from sugar cane and sugar beet respectively. The latter is typically 50% sugar (sucrose) by weight. Both are widely used as 'fermentation boosters' in livestock feeds designed to increase rapid digestion. Low cost allows it to be a very popular feedstuff as a partial substitute for cereals in commercial agriculture. Both are typically employed to rapidly increase weight and growth of livestock animals in such circumstances. Here, however, we are considering feeding this on a daily basis to herbivorous tortoises..... and rapid increases in growth and weight should really be the very last thing we hope to achieve, as both are strongly associated with developmental disorders such as Metabolic Bone Disease in these species. Yet again, however, this grossly unsuitable ingredient appears in numerous 'tortoise food' formulations. Exactly the same remarks apply to 'Dried Beet Pulp' which sometimes are added in addition to molasses.
Purple Sweet Potato (Yam)
This is yet another one where you really have to wonder at how anyone could possibly consider such a thing as an appropriate ingredient in a food intended for grassland tortoises? It contains extremely high levels of starches, and also very high levels of oxalates (486–781 mg/100 g dry matter). It would normally be classed as high in 'anti-nutrient' factors and as a 'no feed' to tortoises. The exceptionally high starch content would, in fact, concern us even more than the oxalate levels. Some manufacturers do include it in their pre-packaged diets, however....
Dried dead insect powder or other protein supplements
Apparently based upon the opinion that Testudo and similar species are "opportunistic omnivores in the wild" - which is of course true to a degree, in that tortoises will often eat literally almost anything that they happen to find. The fundamental problem with this approach is that however 'opportunistic' they might be, they very, very rarely ever get the opportunity. So, although a tortoise might well consume carrion if it encounters it, they very rarely indeed ever actually encounter it. There are several fairly obvious and rational reasons for this. The first is a really simple one. If there is carrion lying around (a rare event of itself) there are a number of high density local scavengers that will get to it long before any tortoise has a chance. These include birds such as crows and magpies, in addition to mammals such as foxes, rats and badgers. The reality is that tortoises would rarely get the chance to eat carrion, and as it attracts highly efficient scavengers and predators like a magnet, the next item on the menu would very likely be the tortoise itself. Tortoises will certainly consume such items as rabbit droppings from time to time, but the number of insect parts consumed (for example) is absolutely minimal and on the level of incidental/chance intake. There is zero evidence that either carrion or insects are in any way whatever a regular or significant part of the diet of any of these species and even less so that they contribute anything of nutritional necessity or importance. As a very rare event, a small amount just might be consumed, but as justification for including these highly digestible proteins in a diet to be feed on a daily basis? We ourselves have studied wild Testudo graeca diets in Morocco and Spain over 35 years, and we have found no evidence whatever that either insects or carrion are a normal and routine part of their diet. An extensive study and analysis of the faecal pellets of Testudo hermanni hermanni in Northern Spain also failed to find evidence of this. If they are consumed at all, it is on an extremely small level indeed. We are aware of no credible evidence to the contrary and the manufacturer concerned, despite our direct request for such supporting evidence of levels of consumption in nature, failed to produce any.
On this specific topic the present author described the situation as follows, writing as long ago as 1992:
"It is necessary to comment upon the claim often made that terrestrial chelonians from and habitats receive significant additional protein in the wild as a result of consuming carrion, arthropods and other insects. This is not supported by fecal pellet analysis (Dearden, Hansen and Steinhorst, 1974) which indicates that such intake is so low as to be of virtually nil dietary significance. The levels paralleled that of other miscellaneous detritus also consumed, including small rocks, sand, bird feathers, lizard skin casts and mammal hairs (Hansen et al, 1976). Most tortoises will consume anything which is presented to them whether palatable and nutritious or not. Until separated from the public by barriers, giant tortoises at San Diego zoo were known to consume popcorn, balloons, yogurt, film wrappers, chewing gum and red-painted toenails (Bacon, 1980). Habitat analysis suggests that animals from arid habitats would not frequently encounter available sources of animal protein but that tortoises from tropical habitats would be more likely to do so on a regular basis"
In the absence of credible evidence to the contrary, that remains our view. It is rather unfortunate that 30 years later we still find ourselves confronted by manufacturers determined to effectively 'force' such ingredients on captive chelonia.
Cereals, soy derivatives, grains and maize (corn) or seed husks and hulls.
The above are often added as a cheap way to increase crude fibre levels (although they are very different from the natural, whole long-fibres that tortoises consume in the wild), and some of these also possess several anti-nutrient factors (when considered in the context of a herbivore diet), while wheat and corn contain phytic acid as well as contributing to accelerated fermentation. Of the mineral trace elements, zinc is most profoundly affected by high levels of phytic acid consumption, although calcium, magnesium, manganese, and iron are also affected to lesser extents. The foods highest in phytic acid include peas and beans (1-4%) wheat bran (5%), rice bran (8%), and soy derivatives (10.7%). Attempts to compensate by over-supplementing diets high in phytic acid with additional calcium are typically counter-productive, as this exaggerates the inhibition of zinc uptake producing a very real danger of deficiency. It is best to avoid feeding phytic acid-rich foods from the outset and certainly there appears to be very little justification for including them in the routine daily diet. Unfortunately such ingredients are incredibly common in mass-market packaged tortoise foods. Finally at least some manufactuers are slowly catching up (the above was known and written about at length almost 30 years ago by the present author) and now make a specific point of marketing their product as free from these damaging components! In addition, of course, absolutely none of these things are any part of the natural diets of these species, which could be said of many similar ingredients, of course.
To summarise, one trend really stands out from the analyses of the majority of these mass-market, packaged foods. It is that those formulating and marketing them appear to have the belief that 'more is better'. More vitamins. More sucrose and glucose. More carbohydrates. More 'high quality protein'. More 'fermentation boosters' and more 'probiotics'. More 'exotic' ingredients. One may be forgiven, hopefully, for concluding that the guiding phillosophy in many cases appears to be "throw in the kitchen sink, and we can't go wrong!"
Sadly, this is - in our honest opinion - looking at it from entirely the wrong perspective. Would it not be far better to study adequately and try to understand how these animals have evolved over countless millenia to positively thrive, in excellent health, on the diets available in their natural habitat and work hard to replicate this? It is equally sad that there are countless lessons from history that prove beyond reasonable doubt that the more we diverge from nature and the natural world, the bigger the mess we make of things. Regretably, many (not all) of the commercial tortoise foods on the market today are a vivid, and often tragic, examples of this.
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A. C. Highfield and The Tortoise Trust (c) 2023