With Children ill with E. coli and an Epidemiological link to Raw Farm Cheese, why no Recall?

The FDA and CDC, in collaboration with state and local partners, continue to investigate a multistate outbreak of E. coli O157:H7 infections linked to RAW FARM-brand raw dairy products. FDA’s investigation is ongoing.

FDA has again recommended that RAW FARM, LLC voluntarily remove their raw cheese products from the market, and the firm has not responded.

FDA has initiated an onsite inspection and sample collection at RAW FARM, LLC in coordination with state partners. To date, FDA is not aware of any positive E. coli tests in RAW FARM-brand raw cheddar cheese products from this time period. FDA will update this advisory should additional information become available.

Since the last update on March 15, 2026, two (2) additional illnesses have been reported. A total of nine (9) people infected with the outbreak strain of E. coli have been reported from three (3) states. Illnesses started on dates ranging from September 1, 2025, to February 20, 2026. Three (3) people have been hospitalized and one (1) person developed hemolytic uremic syndrome (HUS), a serious condition that can cause kidney failure. No deaths have been reported. Over half of the illnesses are in children under five (5) years old.

State and local public health officials are interviewing people or their caregivers about the foods they ate in the week before they got sick. Of the eight (8) people interviewed, all eight (8) (100%) in this outbreak reported consuming or being served raw dairy products.  

Of the eight (8) people interviewed, seven (7) had brand information available. One (1) person drank raw milk but didn’t know the brand. Of the seven (7) people interviewed who knew a brand, seven (7) (100%) reported RAW FARM-brand dairy products. In 2026, five (5) people reported consuming or being served RAW FARM-brand raw cheddar cheese. In 2025, two (2) sick people reported consuming RAW FARM-brand raw milk. Affected RAW FARM-brand raw milk from 2025 should no longer be for sale.    

Whole genome sequencing (WGS) analysis of E. coli isolates from ill people shows that they are all closely related genetically to each other. This means that people in this outbreak are likely to share a common source of infection.  

The FDA, under the Food Safety Modernization Act (FSMA), has the authority to issue a mandatory recall for food products (excluding infant formula) if there is a “reasonable probability” that the food is adulterated or misbranded and poses a serious health risk. The FDA must first provide an opportunity for a voluntary recall before issuing a mandatory order. The FDA must determine that the food is adulterated or misbranded and that its use/exposure will cause serious adverse health consequences or death. If the company refuses or fails to act, the FDA can order them to immediately stop distribution and notify other parties, including the public. This authority applies to all food regulated by the FDA.

https://www.marlerblog.com/files/2026/04/MandatoryRecallGuidance-1.pdf

Republished with permission from Bill Marler and Marler Clark. Copyright (c) Marler Clark LLP, PS. All rights reserved.