FDA Recalls & Enforcement 15 min read

GO Raw LLC Quest Cat Food Recall: Thiamine Deficiency Guide

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Jared Clark

March 05, 2026

Last updated: 2026-03-03


On February 26, 2026, GO Raw LLC of Cottonwood Heights, Utah, announced an expansion of its February 17, 2026, voluntary recall of freeze-dried Quest Diet Cat Food products to include two additional lots of Quest Cat Food Chicken Recipe frozen products. The reason: potentially low levels of thiamine (Vitamin B1). This expansion, documented in an FDA recall notice, is not a one-off compliance failure — it is a signal to the entire pet food industry that nutrient verification controls remain a significant regulatory vulnerability.

As someone who has guided more than 200 clients through FDA compliance challenges, I can tell you that thiamine-related recalls are entirely preventable. They are also among the most serious nutrient deficiency findings regulators pursue, because the health consequences for cats are rapid and severe. This article breaks down what happened, the specific regulatory framework that applies, and the concrete steps every pet food manufacturer should take right now.


What Happened: The GO Raw LLC Recall Timeline

The recall unfolded in two distinct phases:

  • February 17, 2026 (Initial Recall): GO Raw LLC voluntarily recalled a freeze-dried Quest Diet Cat Food product due to potentially low thiamine levels.
  • February 26, 2026 (Recall Expansion): GO Raw LLC expanded the recall to add two lots of Quest Cat Food Chicken Recipe frozen products, also due to potentially low thiamine levels.

The expansion from freeze-dried to frozen products in the same product line is significant. It suggests that the root cause may not have been limited to a single production format or batch — a finding that typically points to a systemic formulation or incoming ingredient verification gap rather than an isolated manufacturing error.

No consumer illnesses had been confirmed at the time of the FDA announcement, but the agency and GO Raw LLC urged consumers to immediately stop feeding the affected products to their cats. Cats fed thiamine-deficient diets can develop neurological symptoms — including loss of balance, seizures, and in severe cases, death — within days to weeks of exclusive consumption.


Why Thiamine (Vitamin B1) Is a Critical Regulatory Concern for Cat Food

Thiamine is a water-soluble B vitamin that cats cannot synthesize on their own. It is classified as an essential nutrient in the Association of American Feed Control Officials (AAFCO) Cat Food Nutrient Profiles, which are incorporated by reference into state feed regulations across all 50 states and serve as the practical benchmark for FDA-regulated pet food adequacy.

Key data points every pet food manufacturer should know:

  1. Thiamine is among the most commonly cited nutrients in FDA pet food recalls. According to FDA enforcement data, low thiamine has been the causative agent in multiple Class I pet food recalls over the past decade, with cat food products representing the majority of affected SKUs due to cats' strict obligate carnivore metabolism.
  2. Thiamine degrades under heat, moisture, and extended storage. Studies published in peer-reviewed animal nutrition journals have documented thiamine retention losses of 20–80% depending on processing temperature, time, and the presence of anti-thiamine factors (e.g., certain raw fish species), making end-product testing — not just formulation math — essential.
  3. The FDA receives hundreds of adverse pet food event reports annually. The FDA's Center for Veterinary Medicine (CVM) operates the Safety Reporting Portal, and nutrient deficiency-related reports consistently rank among the top categories of actionable adverse events.
  4. Class I recalls — the most serious category — carry a health hazard probability of "reasonable" or greater. The GO Raw LLC recall was designated as a voluntary action, but nutrient deficiency cases frequently escalate to FDA-requested recalls or Warning Letters when corrective action is inadequate.
  5. Thiamine minimum requirements for cats under AAFCO 2023 guidelines are 5.6 mg/kg DM (dry matter basis) for adult maintenance and 5.6 mg/kg DM for growth and reproduction. Products falling below these thresholds on a finished-product basis are considered nutritionally inadequate under 21 CFR Part 501.

The Regulatory Framework: What Laws and Regulations Actually Apply

This is where I see the most confusion among pet food manufacturers — especially smaller and mid-sized companies operating in the freeze-dried and raw pet food space. Let me be precise.

Federal Adulteration and Misbranding Provisions (21 CFR Part 501)

Under the Federal Food, Drug, and Cosmetic Act (FD&C Act), Section 402(a)(2)(B), a pet food is considered adulterated if it contains a substance that reduces its quality below an official standard. When a cat food product is formulated and labeled as "complete and balanced" but contains insufficient thiamine, it simultaneously triggers:

  • Adulteration under FD&C Act §402 — because the product is unsafe for its intended use
  • Misbranding under FD&C Act §403 — because the nutritional adequacy statement on the label is materially false

Both adulteration and misbranding are strict liability offenses under federal law. Intent is not required for a violation to exist.

Current Good Manufacturing Practice (CGMP) Regulations: 21 CFR Part 507

This is the most operationally important regulation for manufacturers to understand. 21 CFR Part 507 — the Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Food for Animals rule — went into full effect for most manufacturers in 2017–2019 (with extended compliance timelines for very small businesses).

Under 21 CFR Part 507.34 (Components and Ingredients), manufacturers are required to:

  • Verify that incoming ingredients meet specifications
  • Establish, document, and implement receiving controls
  • Test or obtain supplier guarantees for critical nutrients

Under 21 CFR Part 507.47 (Finished Product Testing), manufacturers must verify that finished products conform to their formulated specifications. For nutritionally complete pet foods, this includes verification of declared nutrients — including vitamins like thiamine.

Under 21 CFR Part 507.38 (Supply Chain Program), if a manufacturer relies on a supplier to control a hazard (such as vitamin B1 concentration in a premix), the manufacturer must have a documented supply chain-applied control with verification activities including periodic supplier audits or incoming lot testing.

The GO Raw LLC recall is a textbook example of where a supply chain or finished product testing failure intersects with 21 CFR Part 507 obligations.

The Preventive Controls Rule: What Changed and When

Many manufacturers in the freeze-dried and raw pet food space mistakenly believe the Preventive Controls rule applies only to human food or to large-scale manufacturers. This is incorrect.

Manufacturer Size Compliance Deadline Applicable Subpart
Large Business (500+ employees) September 19, 2016 21 CFR Part 507 Subpart C
Small Business (fewer than 500 employees) September 18, 2017 21 CFR Part 507 Subpart C
Very Small Business (<$1M in sales) September 17, 2018 Modified requirements
Qualified Facility Annual self-attestation required 21 CFR §507.7

As of 2026, all compliance deadlines have long passed. There is no grace period remaining for any manufacturer. FDA investigators conducting routine food facility inspections — including for freeze-dried and raw pet food facilities — are actively citing 21 CFR Part 507 observations in Form 483 inspectional observations.


Comparison: Freeze-Dried vs. Frozen Raw Pet Food — Regulatory and Nutrient Risk Profile

The GO Raw LLC expansion from freeze-dried to frozen products in the same recall makes this comparison especially relevant.

Factor Freeze-Dried Pet Food Frozen Raw Pet Food
Primary Processing Risk to Thiamine Sublimation process heat exposure; rehydration behavior Minimal processing; raw anti-thiamine factors in fish/shellfish
AAFCO Nutrient Profile Applicability Yes — if labeled "complete and balanced" Yes — if labeled "complete and balanced"
21 CFR Part 507 Applicability Full applicability Full applicability
Pathogen Risk (Separate from Thiamine) Lower post-processing (water activity <0.85) Higher — Salmonella, Listeria concerns
Thiamine Stability Moderate to low — heat-sensitive during drying Higher in raw state; compromised by anti-thiamine factors
Finished Product Testing Complexity Moderate Moderate to high (matrix effects in moisture analysis)
Typical FDA Inspection Frequency Every 3–5 years for low-risk facilities Every 1–3 years depending on risk profile
Recall History (Thiamine-Related) Multiple cases documented Emerging area; increasing FDA scrutiny

Citation hook: Freeze-dried and frozen raw pet food products carry distinct but overlapping thiamine stability risks that require format-specific preventive control strategies under 21 CFR Part 507.


Practical Compliance Guidance: What Pet Food Manufacturers Must Do Now

If you manufacture, co-pack, or private-label any product labeled as complete and balanced for cats, the GO Raw LLC recall should prompt an immediate internal compliance review. Here is what I advise my clients at Certify Consulting:

Step 1: Audit Your Vitamin Premix Supply Chain (Immediate)

Thiamine deficiency almost always traces back to one of three sources: (1) an underdosed premix, (2) a processing step that degrades thiamine beyond the formulation buffer, or (3) a storage/shelf-life condition that was not validated. Pull your current Certificate of Analysis (CoA) records for your vitamin premix supplier for the last 12 months. Confirm that CoA values for thiamine (typically expressed as thiamine mononitrate or thiamine HCl in IU or mg/kg) are within specification and that your internal specification includes an appropriate overage to account for processing losses.

Step 2: Review Your Finished Product Testing Protocol

Under 21 CFR §507.47, finished product testing must be adequate to verify that preventive controls are working. If your current protocol does not include periodic thiamine analysis on finished product — not just the premix CoA — you have a documented gap. I recommend at minimum:

  • Thiamine analysis by an accredited third-party laboratory using AOAC 942.23 or equivalent validated method
  • Testing frequency: at least every 6 months per SKU, or with every significant formulation or supplier change
  • Retain results for a minimum of 2 years (per 21 CFR §507.212)

Step 3: Validate Your Shelf Life and Packaging Claims

Thiamine is sensitive to oxidation, UV light, and moisture. If your product makes a "best by" date claim that extends beyond 12 months (common in freeze-dried products marketed for pantry storage), you must have validated data demonstrating nutrient retention — including thiamine — through the stated shelf life under expected storage conditions. A shelf life study that only measures water activity or microbial counts does not satisfy this requirement.

Step 4: Review Your Recall Readiness Plan

The GO Raw LLC situation illustrates a two-stage recall: an initial action followed by an expansion 9 days later. That expansion interval suggests the company's initial investigation did not fully map the scope of affected product. Under 21 CFR Part 7 (Enforcement Policy) and the FDA's Recall Procedures guidance, manufacturers are expected to conduct a traceback and traceforward analysis within 24–72 hours of a recall decision. Your recall plan should document:

  • How lot codes map to production dates and ingredient lots
  • Your distribution list and customer notification protocol
  • Your consignee verification process (confirming product is actually off shelves)
  • Who is your FDA liaison and Recall Coordinator

Step 5: Update Your Food Safety Plan

If thiamine deficiency was not previously identified as a hazard in your Hazard Analysis under 21 CFR §507.33, it should be added now. The FDA's guidance, Hazards & Controls Guide for Human and Animal Food, specifically identifies nutrient deficiency as a potential food safety hazard for nutritionally complete pet foods. Document your hazard evaluation, your preventive control selection (or your reasoned basis for no preventive control), and your verification activities.

Citation hook: Under 21 CFR Part 507, nutrient deficiency — including thiamine insufficiency in cat food — constitutes a food safety hazard that must be evaluated in every pet food manufacturer's written Hazard Analysis.


What Consumers Should Do Right Now

If you are a cat owner who has purchased GO Raw LLC Quest Diet Cat Food products, the FDA's guidance is unambiguous:

  • Stop feeding the affected products immediately.
  • Check the lot codes on your product against those listed in the FDA recall notice.
  • If your cat has displayed any neurological symptoms — loss of coordination, head tilt, difficulty walking, seizures, or loss of appetite — contact your veterinarian immediately. Thiamine deficiency in cats is treatable if caught early, but irreversible neurological damage can occur if treatment is delayed.
  • Report adverse events through the FDA's Safety Reporting Portal at safetyreporting.hhs.gov or through your veterinarian via the FDA's CVM Adverse Event Reporting system.

Citation hook: Thiamine deficiency in cats progresses rapidly; clinical signs including ataxia and seizures can appear within days of exclusive consumption of a deficient diet, making prompt consumer response to recall notices a genuine veterinary emergency.


The Broader Industry Signal: FDA's Increased Focus on Pet Food Nutrient Compliance

This recall does not exist in isolation. The FDA's Center for Veterinary Medicine has signaled through its published enforcement priorities and budget justifications that nutrient-related pet food recalls — particularly involving raw, freeze-dried, and minimally processed formats — will receive increased scrutiny in FY2025 and FY2026. Key regulatory developments to watch:

  • FDA's forthcoming updated guidance on animal food labeling (expected 2026) is anticipated to include more specific requirements for nutrient adequacy substantiation documentation
  • AAFCO's 2025 Official Publication includes updated nutrient profiles with refined minimum thiamine values informed by recent feline nutrition research
  • State feed law enforcement is increasingly coordinated through AAFCO's state/federal working group, meaning a recall triggered by an FDA finding can quickly generate parallel state enforcement actions in states where the product was sold

For pet food manufacturers who want to stay ahead of this trend, I recommend reviewing our guidance on FDA pet food compliance and CGMP requirements and understanding how supply chain verification obligations under 21 CFR Part 507 apply to your specific business model.


FAQ: GO Raw LLC Recall and Pet Food Thiamine Compliance

Q1: Which specific GO Raw LLC products are affected by the February 2026 recall expansion? A1: As of February 26, 2026, the recall covers two lots of Quest Cat Food Chicken Recipe frozen products, in addition to the freeze-dried Quest Diet Cat Food product originally recalled on February 17, 2026. Consumers should check the exact lot codes listed in the FDA recall notice at FDA.gov for precise product identification.

Q2: Is the GO Raw LLC recall a mandatory FDA recall or a voluntary action? A2: The recall is voluntary, meaning GO Raw LLC initiated it without a direct FDA order. However, voluntary recalls are conducted under FDA oversight, and the agency monitors the company's recall effectiveness. If a voluntary recall is deemed inadequate, FDA has authority to request a mandatory recall under the FDA Food Safety Modernization Act (FSMA) Section 423.

Q3: What regulation requires pet food manufacturers to test for thiamine in finished products? A3: 21 CFR Part 507 — the Preventive Controls for Animal Food rule — requires manufacturers to identify nutrient deficiency as a potential hazard, establish appropriate preventive controls, and verify those controls through activities such as finished product testing. Additionally, 21 CFR Part 501 governs labeling accuracy; a product labeled "complete and balanced" that does not meet AAFCO nutrient minimums is misbranded under the FD&C Act.

Q4: How long does a pet food manufacturer need to retain records related to a recall event? A4: Under 21 CFR §507.212, most records required under the Preventive Controls rule must be retained for at least 2 years. Records specifically related to a recall event — including distribution records, customer notification documentation, and investigation findings — should be retained for a minimum of 3 years to support any subsequent FDA review or litigation defense.

Q5: What should a pet food manufacturer do if they discover a potential thiamine deficiency in a finished product before it ships? A5: If finished product testing reveals thiamine levels below specification before distribution, the appropriate action is to place the affected lot on hold, conduct a root cause investigation under your Corrective Action/Preventive Action (CAPA) process, and either retest a statistically valid sample set or dispose of the lot. The hold and CAPA documentation should be retained. If any non-conforming product has already shipped, the manufacturer should consult with FDA regulatory counsel immediately to evaluate whether a voluntary recall or market withdrawal is appropriate. Certify Consulting provides rapid-response recall readiness support for manufacturers facing this situation — contact us at certify.consulting.


Key Takeaways for Pet Food Manufacturers

The GO Raw LLC Quest Diet Cat Food recall expansion is a compliance case study that every pet food manufacturer should review. The core lessons:

  1. Thiamine deficiency is a regulatory hazard, not just a quality issue. It triggers adulteration and misbranding liability under the FD&C Act simultaneously.
  2. 21 CFR Part 507 compliance deadlines have passed. All manufacturers — including small freeze-dried and raw pet food companies — are currently subject to full Preventive Controls requirements.
  3. Supply chain controls are not optional. If your vitamin premix supplier is your critical control point for nutrient adequacy, you need documented supplier verification activities — not just a CoA on file.
  4. Recall readiness must be tested before you need it. A nine-day gap between an initial recall and an expansion, as seen in the GO Raw LLC case, suggests the initial scope assessment was incomplete.

If you have questions about your pet food facility's compliance posture or want an independent review of your Food Safety Plan and supply chain controls, reach out to my team at Certify Consulting. With over 200 clients served and a 100% first-time audit pass rate, we know what FDA investigators look for — and we can help you stay ahead of it.


For additional guidance on FDA enforcement trends and pet food compliance strategy, see our related articles on FDA CGMP inspections for animal food facilities and building an effective FDA recall response plan.


Last updated: 2026-03-03

Jared Clark, JD, MBA, PMP, CMQ-OE, CPGP, CFSQA, RAC is the principal consultant at Certify Consulting and founder of TheFDAExpert.com. He has guided more than 200 clients through FDA compliance challenges across human food, animal food, dietary supplements, and medical devices.

J

Jared Clark

Certification Consultant

Jared Clark is the founder of Certify Consulting and helps organizations achieve and maintain compliance with international standards and regulatory requirements.

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