H5N1 and raw pet food: what FDA’s food-safety-plan requirement means

Since January 2025, US manufacturers of cat and dog food made with uncooked poultry or cattle materials must address H5N1 avian influenza in their food safety plans. This alert explains who is affected, what happened, and what to do.

PNL
Guires PNL InsightsWritten by the nutrition science and regulatory teams
Reviewed byGuires PNL scientific team
Published15 Sep 2026
Last checked15 Sep 2026
Reading time6 minutes
Key takeaways
  • FDA requires covered cat and dog food manufacturers to treat H5N1 as a known or reasonably foreseeable hazard when they use uncooked or unpasteurised poultry or cattle materials.
  • The requirement followed cat deaths linked to raw pet food and raw milk in late 2024.
  • Affected materials include uncooked meat, unpasteurised milk and unpasteurised eggs.
  • Any control you rely on must be validated for the hazard.
Requirement in force · United StatesIssued 17 January 2025 · Reissued 30 September 2025
Risk levelSerious — pathogen hazard
StatusRequirement in force
AuthorityUS FDA, Center for Veterinary Medicine
Issued17 Jan 2025 · reissued 30 Sep 2025
Applies toCat and dog food using uncooked or unpasteurised poultry or cattle materials
EvidenceRegulatoryRated by the Guires Pet Nutrition Lab scientific team
WhoCat and dog food makers covered by 21 CFR 507
TriggerUncooked or unpasteurised poultry or cattle materials
ActionReanalyse the food safety plan for H5N1

01The requirement

On 17 January 2025, FDA’s Center for Veterinary Medicine told manufacturers of cat and dog food covered by the Preventive Controls for Animal Food rule 5 that they must reanalyse their food safety plans. Where a facility uses “uncooked or unpasteurized materials derived from poultry or cattle (e.g., uncooked meat, unpasteurized milk or unpasteurized eggs)”, H5N1 must be considered a known or reasonably foreseeable hazard 1. FDA reissued the notice on 30 September 2025 1.

02How we got here

  1. Dec 2024
    A voluntary recall of a frozen raw feline turkey recipe followed the death of a cat in Oregon 2.
  2. Jan 2025
    AVMA reported further cat cases in Los Angeles County linked to a raw pet food, and a separate household where cats died after drinking raw milk 2.
  3. 17 Jan 2025
    FDA requires H5N1 to be addressed in cat and dog food safety plans 1.
  4. 1 Mar 2025
    A frozen raw chicken formula for cats was voluntarily recalled for possible H5N1 contamination 3.
  5. 30 Sep 2025
    FDA reissues its notice to manufacturers 1.

03Why cats are the focus

US cat infections have been linked to commercially produced raw pet food and unpasteurised milk, and CDC advises owners not to feed pets raw pet food or raw milk 4. For manufacturers, the practical consequence is that any product relying on uncooked poultry or cattle materials needs a documented, validated way to control the hazard — or a clear rationale for why it is not significant.

04What to do now

Required actions

  • Map every recipe that uses uncooked or unpasteurised poultry or cattle materials, including milk and eggs.
  • Reanalyse the hazard analysis and document the H5N1 decision for each product.
  • Review supplier approval and verification for poultry and cattle materials.
  • Identify the control you rely on and confirm it is validated for this hazard.
  • Update monitoring, corrective action and recall procedures.
  • For exporters to the US: check whether your facility is covered by the FDA rule.

These steps summarise the FDA notice; they are not legal advice. Your preventive controls qualified individual should lead the reanalysis 1,5.

Guires Pet Nutrition Lab verdict

If your recipe uses raw poultry or cattle materials for the US market, document your H5N1 decision now — and validate any control you rely on.

05Questions brands ask

Does this apply to freeze-dried products?

It applies where uncooked or unpasteurised poultry or cattle materials are used. Freeze-drying is not a cooking step, so these products are generally in scope.

Does it apply to manufacturers outside the US?

It applies to facilities covered by FDA’s Preventive Controls for Animal Food rule, which can include foreign facilities supplying the US.

Sources

  1. FDA CVM (2025). Cat and dog food manufacturers required to consider H5N1 in food safety plans. Source ↗
  2. AVMA News (15 Jan 2025). Cat deaths linked to bird flu-contaminated raw pet food, sparking voluntary recall. Source ↗
  3. FDA (2025). Voluntary recall — Wild Coast Raw boneless free range chicken formula raw pet food. Source ↗
  4. CDC. Bird flu in pets. Source ↗
  5. eCFR. 21 CFR Part 507 — Preventive controls for food for animals. Source ↗

Evidence reviewed by the Guires Pet Nutrition Lab scientific team. This article is general information for product developers and is not legal or veterinary advice.

How to cite this article

Choose your referencing style, then copy. Check your university’s, journal’s or regulator’s guide for local variations.

Guires Pet Nutrition Lab. (2026, September 15). H5N1 and raw pet food: what FDA’s food-safety-plan requirement means. Guires Pet Nutrition Lab Insights. https://www.petnutritionlab.com/insights/h5n1-raw-pet-food

This article summarises published evidence for product developers. Cite the original sources above for specific findings, and do not reproduce this article as your own work.

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