Status: Industry-canonical regulatory-limit pattern; FDA advisories issued in lieu of voluntary recall. Between 2019 and 2026, at least three U.S. pet food manufacturers declined to initiate voluntary recall after FDA pathogen detection in finished product: Bravo Packing 2019 Performance Dog (Salmonella + Listeria in lot 072219; FDA issued "do not feed" advisory in lieu of recall), Darwin’s 2025 (declined voluntary recall after FDA pathogen findings), and Raaw Energy 2026 (8 of 8 FDA inspection samples positive for multiple pathogens; declined recall). The pattern reveals a structural limit: FDA mandatory-recall power under FSMA is mandatory only when the agency invokes formal recall-order proceedings — a high-bar procedure rarely used. Most recalls in pet food are voluntary, and a manufacturer that declines to initiate a voluntary recall after pathogen detection leaves consumers reliant on FDA public advisories for risk communication. The 2019-2026 cases together produced FDA Warning Letters but no formal recall orders.

What was recalled

This page synthesizes three U.S. pet food manufacturer declinations of voluntary recall after FDA pathogen detection. The September 2019 Bravo Packing case involved Performance Dog raw pet food (Carneys Point NJ facility) where FDA inspection samples (lot 072219, July 22, 2019) tested positive for both Salmonella and Listeria monocytogenes; because retail 2-pound pouches carried no lot codes, the FDA advisory recommended consumers not feed any Performance Dog raw pet food produced on or after July 22, 2019. Bravo Packing did not initiate a voluntary recall in 2019; the company eventually did issue a voluntary recall for its third documented pathogen event in March 2021.

The 2025 Darwin’s case involved Darwin’s Natural Selections raw pet food where the manufacturer declined voluntary recall after FDA pathogen detection in finished product. The 2026 Raaw Energy case involved a small-brand raw pet food where 8 of 8 FDA inspection samples tested positive for multiple pathogens (Salmonella, Listeria, and at least one additional organism); the manufacturer declined voluntary recall, prompting an FDA "do not feed" advisory. Common pattern: manufacturers facing post-detection cost calculus (the recall would surface every prior production batch within the contamination window) chose to absorb FDA advisory communication risk rather than initiate the more expensive voluntary recall.

Why it was recalled

The legal-procedural background is critical for understanding the declination pattern. Under the Food Safety Modernization Act (FSMA) of 2011, the FDA gained mandatory recall enforcement powers for adulterated food — but the procedure requires a multi-step process: the FDA must first formally request a voluntary recall, then if the manufacturer declines and the agency believes the food poses a probability of serious adverse health consequences or death, the FDA can issue a formal recall order following due-process notification. The process is high-friction and rarely used; most pet food recalls in the FDA archive are voluntary recalls initiated by the manufacturer, often after FDA contact but before formal request-and-order proceedings.

When a manufacturer declines voluntary recall after FDA pathogen detection, the FDA’s practical options are: (1) issue a public health advisory ("do not feed") to communicate risk to consumers; (2) issue a Warning Letter documenting the violation; (3) escalate to formal mandatory recall proceedings if the disease-severity threshold is met. The 2019 Bravo Packing case used options 1+2 (advisory + eventual Warning Letter). The 2025 Darwin’s and 2026 Raaw Energy cases similarly produced FDA advisories. The pattern matters because consumers may not encounter advisory notices through normal product-channel communication — recalls trigger retail-shelf pulls and direct customer outreach; advisories rely on FDA press release and consumer media propagation. The Bravo Packing 2019 FDA notice at FDA Outbreaks and Advisories documents the advisory format.

Health risks for your pet

The three declined-recall cases shared the pathogen-detection profile typical of raw pet food: Salmonella in all three; Listeria monocytogenes in Bravo Packing and Raaw Energy; multiple pathogens in Raaw Energy. No confirmed pet illnesses were reported at the time of the FDA advisories in any of the three cases; the detection mechanism was FDA inspection sampling rather than consumer illness reports. Salmonella infection in dogs presents as diarrhea (sometimes bloody), vomiting, fever, anorexia, and lethargy; severe cases produce septicemia, particularly in puppies and immunocompromised animals. Listeria monocytogenes in dogs can cause similar gastrointestinal symptoms plus, in rare cases, septicemia and CNS involvement. The human-handling zoonotic risk is particularly concerning for pregnant women, infants, the elderly, and immunocompromised adults: Listeria can cause miscarriage, neonatal infection, septicemia, and meningitis in vulnerable populations.

What to do if you bought affected product

When a manufacturer has declined voluntary recall, FDA advisory notices become the primary public communication channel. Check the FDA Outbreaks and Advisories archive for current advisories on any raw pet food brand you are considering. If you have product from any 2019-2026 advisory window in your freezer, dispose of the product securely. Wash food bowls, prep surfaces, and hands with hot soapy water; Salmonella and Listeria are inactivated by standard household disinfectants. Pet owners feeding raw pet food should follow strict handling-hygiene protocols: separate cutting boards and utensils for raw pet food, immediate handwashing after handling, no cross-contamination with human food prep surfaces, and avoid raw pet food handling by pregnant women, infants, and immunocompromised household members. If a manufacturer’s product line repeatedly appears in FDA advisories without voluntary recall response, the case-history pattern is a strong consumer-trust signal.

How this affects KibbleIQ’s grade

Bravo Packing, Darwin’s, and Raaw Energy are not in the KibbleIQ scored database; standalone raw frozen is a distinct format that our methodology v15 does not yet specifically score per our published methodology. The declined-recall pattern is a critical structural signal for recall-history scoring under our planned methodology v2: a manufacturer’s response posture after pathogen detection (voluntary recall vs. advisory-tolerance) is a quality-systems-attitude signal distinct from the underlying contamination event itself. Manufacturers that decline voluntary recall after multi-sample pathogen detection demonstrate a quality-systems-attitude that warrants substantially heavier scoring penalty than manufacturers that promptly issue voluntary recall after single-sample detection. The pattern reinforces the importance of FDA enforcement-action tracking (Warning Letters, advisories, recall orders) in any forward-looking quality assessment, not just point-in-time disease-toll tallying.