H5N1 Is Now a Food Safety Hazard: What Raw-Feeding Veterinarians and Pet Owners Need to Know
A plain-language look at the FDA’s H5N1 determination for pet food manufacturers, what the current evidence actually shows about cats and dogs, and how to have an informed, non-alarmist conversation about raw feeding.
The short version
Why H5N1 Is Now a Pet Food Safety Concern
H5N1 highly pathogenic avian influenza has circulated in wild birds and poultry for decades, but the current global outbreak, driven largely by clade 2.3.4.4b, has moved efficiently into mammals. Since March 2024, the virus has been confirmed in U.S. dairy cattle, and it has repeatedly infected domestic cats, wild felids, and other mammals that consumed infected animals, unpasteurized milk, or contaminated meat.
For pet food specifically, the concerning development is that H5N1 has been detected directly in commercial raw pet food, with genetic sequencing linking the virus in the food to the virus in cats that became ill after eating it. That is a more direct exposure pathway than a cat catching a wild bird outdoors, which is why regulators, veterinary organizations, and manufacturers have all had to reassess raw animal ingredients. It is worth being precise: H5N1 has not been found in all raw pet food, and most raw-fed pets have not become ill. What has changed is that raw poultry is now a documented route of exposure that was not on most people’s radar even two years ago.
What the FDA Says About H5N1 and Pet Food
On January 17, 2025, the FDA’s Center for Veterinary Medicine announced that manufacturers of cat and dog food covered by the FSMA Preventive Controls for Animal Food (PCAF) rule, who use uncooked or unpasteurized materials derived from poultry or cattle, must reanalyze their food safety plans to include H5N1 as a known or reasonably foreseeable hazard. The FDA reissued that update on September 30, 2025, noting that H5N1 detections in wild birds typically rise during fall migration.
This determination followed a cluster of feline illnesses and deaths in California, Oregon, Washington, and Colorado tied to raw pet food and raw milk, and has since been reinforced by further confirmed cases, including a September 2025 FDA notice confirming H5N1 contamination in specific lots of a commercial raw cat food after a San Francisco cat became ill and was euthanized.
What Does FSMA Preventive Controls Have to Do With H5N1?
The PCAF rule, codified at 21 CFR Part 507, requires covered animal food facilities to maintain a written food safety plan that includes a hazard analysis: an evaluation of biological, chemical, and physical hazards that could reasonably occur in the food manufactured. A hazard is “known or reasonably foreseeable” when there is a credible basis to expect it could occur, based on history, illness data, or scientific literature.
Where a hazard requires control, the FDA has outlined several possible preventive controls for H5N1 in raw poultry- or cattle-derived ingredients, none of which is the single mandated method:
- Sourcing ingredients from flocks or herds verified as healthy (a supply-chain-applied control)
- Applying a processing step demonstrated to inactivate the virus, such as heat treatment or canning
- Testing and verification protocols confirming ingredients are not contaminated before production
Under Guidance for Industry #245, facilities implementing a preventive control must also monitor it, verify it, and validate it where required, and must reanalyze their full food safety plan at least every three years or whenever FDA determines new hazards warrant it, exactly the mechanism invoked for H5N1. For a veterinary audience, the key point is that this is a manufacturing process requirement, not a claim that any specific product is unsafe, and not a restriction on what an individual owner may feed at home. For more on how formulation and compliance work behind the scenes, see how pet food is formulated and what AAFCO approval actually means.
Why Raw and Uncooked Animal Ingredients Matter
“Raw pet food” is not one uniform category, and treating it that way obscures the actual risk picture. Tap through the tabs below to see how risk factors differ by protein source and by processing method.
H5N1 Risk in Cats Versus Dogs
Current evidence does not support treating cats and dogs as equally at risk. Cats have consistently shown far greater susceptibility to severe, often fatal H5N1 disease, while documented infections in dogs remain comparatively rare.
| Species | Current evidence of susceptibility | Severity of documented disease | Food-associated transmission concerns | Practical considerations |
|---|---|---|---|---|
| Cats | Well documented; dozens of confirmed U.S. cases since 2022, including clusters tied to raw pet food and raw milk | Frequently severe; neurological and respiratory signs common, high case fatality in documented clusters | Multiple confirmed cases directly linked to specific commercial products via genetic sequencing | Ask about diet in any cat with acute neurological or respiratory illness, especially with raw poultry exposure |
| Dogs | Documented but far less frequent; no confirmed U.S. dog cases linked to pet food as of current FDA reporting | Generally reported as mild with lower mortality, though fatal infections occurred internationally | No confirmed U.S. commercial pet food case in dogs to date; theoretical pathway mirrors the feline cases | Maintain awareness without alarm; evidence is limited, not reassuring |
What We Know About H5N1 Transmission Through Pet Food
The documented cases to date are illustrative, not a representative measure of overall prevalence. No reliable estimate exists for how many raw pet food products nationally might carry the virus at any given time.
What this evidence supports is that raw poultry-based pet food has, on multiple documented occasions across different countries, been a confirmed and traceable route of H5N1 exposure in cats. It does not support any claim about what percentage of raw pet food is contaminated, and it should not be read as evidence that every raw-fed cat is at meaningful risk.
What Veterinarians Should Ask Raw-Feeding Clients
Given the current evidence, it is reasonable to add a few targeted questions to conversations with raw-feeding clients, without turning every appointment into an interrogation.
For any raw-feeding household
- What species of animal protein makes up the diet, with particular attention to poultry
- Whether the diet is homemade or commercial, and if commercial, which brand
- Whether the client has any information about where the manufacturer sources poultry or beef
For homemade raw diets
- Where meat, poultry, or eggs are sourced, and whether any come from backyard flocks or hunted birds
- Whether the household has had any exposure to sick or dead wild birds
For commercial raw diets
- Whether the client is aware FDA now requires certain manufacturers to address H5N1 in food safety plans
- Whether the brand has published anything about its sourcing, testing, or preventive controls
Poultry-based formulations reasonably warrant more discussion than beef, lamb, or fish-based diets, since documented cases to date involve poultry. With cat owners, it is appropriate to be direct about documented severity. With dog owners, the conversation can focus on general awareness rather than urgency, while noting that thinner evidence is not the same as lower risk. For background on ingredient sourcing questions worth asking any raw feeding client, see our guide to whether dogs can eat raw meat and common mistakes in homemade dog food.
What Should Veterinarians Tell Clients About Raw Feeding?
The goal of this conversation is informed decision-making, not persuasion in either direction. H5N1 adds a real, documented food-safety consideration to the raw-feeding conversation, particularly where uncooked poultry is involved. It does not transform raw feeding into something categorically unsafe, and it does not mean every raw diet or every raw-fed pet is at risk.
Practical Risk-Reduction Strategies for Raw-Feeding Households
Tap each item below for practical detail you can share with clients who choose to continue feeding raw diets.
When H5N1 Should Enter the Clinical Conversation
H5N1 is not a common differential for most feline or canine illness and should not crowd out more likely causes in routine workups. It becomes clinically relevant when a raw-fed cat or dog, especially one fed uncooked poultry, presents with an acute onset of signs consistent with documented cases:
If H5N1 is suspected, follow your jurisdiction’s current reportable-disease and testing protocols, generally coordinated with state or provincial animal health authorities. Ask owners to retain the food packaging, brand name, lot number, and purchase location, information that has been essential in every confirmed pet food case to date.
What This Means for Raw Pet Food Manufacturers
For manufacturers covered by the PCAF rule using uncooked or unpasteurized poultry- or cattle-derived ingredients, the FDA’s determination is a requirement to reanalyze existing food safety plans and document how H5N1 is being addressed, whether through sourcing controls, a validated processing step, or testing and verification. This does not mean every raw product on the market is unsafe; it means the regulatory baseline for a compliant food safety plan has changed.
The Canadian Perspective
Canadian Context
Canadian regulatory requirements for pet food manufacturing differ substantially from the U.S. framework, and FSMA’s Preventive Controls for Animal Food rule does not apply to Canadian manufacturers. There is no direct Canadian equivalent to the PCAF hazard-reanalysis requirement.
The Canadian Food Inspection Agency (CFIA) has addressed H5N1 in companion animals primarily through a direct wildlife-exposure lens, advising pet owners not to feed dogs or cats raw meat from poultry, wild birds, or game birds, and to keep cats indoors and dogs leashed during peak migration seasons. CFIA has documented a confirmed 2023 case of a Canadian dog that died after chewing on an infected wild goose, an exposure route distinct from commercial pet food contamination.
Canadian public health messaging has focused mainly on preventing direct contact between pets and infected wild birds or unpasteurized dairy, rather than on commercial raw pet food supply-chain contamination specifically, reflecting that the confirmed commercial contamination cases discussed in this article occurred in the United States. Canadian pet owners and veterinarians should not assume this means the underlying biological risk is different; it may simply reflect different surveillance systems and, to date, an absence of confirmed Canadian cases tied specifically to commercial raw pet food.
Bottom Line
H5N1 is now a documented, FDA-recognized food safety hazard for certain raw and unpasteurized pet food ingredients, particularly uncooked poultry. That is new information worth factoring into the raw-feeding conversation, not a reason to declare raw feeding categorically unsafe. Cats have shown clearly greater susceptibility to severe disease than dogs, and documented food-associated cases in the U.S. to date involve cats, though evidence for dogs remains limited rather than reassuring. Veterinarians are well positioned to help clients make informed choices by asking a few targeted questions, watching for compatible clinical signs, and keeping product and lot information on hand, without turning every raw-feeding conversation into an alarm.
Frequently Asked Questions
References and Further Reading
- U.S. FDA, Center for Veterinary Medicine. “Cat and Dog Food Manufacturers Required to Consider H5N1 in Food Safety Plans.” January 17, 2025, updated September 30, 2025. fda.gov
- U.S. FDA, Center for Veterinary Medicine. “FDA Notifies Pet Owners That Tests Show H5N1 Contamination in Certain Lots of RAWR Raw Cat Food Chicken Eats.” September 3, 2025. fda.gov
- U.S. FDA, Center for Veterinary Medicine. Guidance for Industry #245, “Hazard Analysis and Risk-Based Preventive Controls for Food for Animals.” July 8, 2022. fda.gov
- U.S. FDA. “Investigation of Avian Influenza A(H5N1) Virus in Dairy Cattle.” Updated periodically. fda.gov
- American Veterinary Medical Association. “Avian influenza A (H5N1) in cats.” avma.org
- American Veterinary Medical Association. “Cat deaths linked to bird flu-contaminated raw pet food, sparking voluntary recall.” January 2025. avma.org
- American Veterinary Medical Association. “FDA reminds pet food makers that raw ingredients pose risk of exposure to H5N1.” November 14, 2025. avma.org
- Kim, Y.I., et al. “Highly Pathogenic Avian Influenza A(H5N1) Virus Infection in Cats, South Korea, 2023.” Emerging Infectious Diseases, Vol. 30, No. 12, December 2024, CDC. wwwnc.cdc.gov
- “Pathogenicity of Highly Pathogenic Avian Influenza A(H5N1) Viruses Isolated from Cats in Mice and Ferrets, South Korea, 2023.” Emerging Infectious Diseases, Vol. 30, No. 10, October 2024, CDC. wwwnc.cdc.gov
- Canadian Food Inspection Agency. “Animals susceptible to H5N1 highly pathogenic avian influenza (HPAI).” inspection.canada.ca
- Oregon Department of Agriculture. “Morasch Meats/Northwest Naturals Voluntary Recall of Feline Raw Pet Food Due to HPAI Contamination.” December 2024. oregon.gov
- CIDRAP, University of Minnesota. “H5N1 confirmed in more cats as probe into raw pet food widens.” cidrap.umn.edu
- CIDRAP, University of Minnesota. “FDA warns of H5N1 avian flu detection in raw cat food.” cidrap.umn.edu
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