If you’ve bought a bottle of “cold-pressed” juice, a package of deli meat, or a bag of raw pet food lately, there’s a good chance it’s been through High-Pressure Processing (HPP) — also called High-Pressure Pasteurization. It’s one of the fastest-growing food safety technologies in the U.S., and also one of the most misunderstood. It’s also at the center of a regulatory turf war between two federal agencies that have conflicting standards on food safety for raw pet food food.
How It Works:
HPP uses pressure instead of heat to kill bacteria. Sealed packages of food are submerged in water inside a steel chamber and subjected to extremely high pressure — often 60,000 to 87,000 pounds per square inch. That pressure breaks down the cell walls of bacteria, inactivating pathogens like Listeria, Salmonella, and E. coli without cooking the food. Because it does not use heat to kill bacteria, HPP is marketed as a way to extend shelf life while preserving the taste, texture, and nutrients of fresh food.
Why Companies Use It:
Raw meat, poultry, unpasteurized juice, and raw pet food can all carry pathogens, and regulators have taken an increasingly strict stance on their presence. HPP gives manufacturers a way to reduce bacterial counts to safer levels — and satisfy regulators — without heating a product that is meant to be sold as raw or fresh.
But how strict that stance is depends heavily on which agency, and which product, you’re talking about — and that inconsistency is the real source of the controversy.
The USDA/FDA Discrepancy:
The USDA, which oversees meat and poultry for human consumption, does not have a zero-tolerance policy for bacteria like Salmonella in raw meat. Poultry processing plants are allowed a certain percentage of positive Salmonella samples before they’re required to take corrective action, and raw meat sold at retail routinely carries some bacterial load. The USDA’s logic is straightforward: raw meat is expected to be cooked before it’s eaten, cooking kills the bacteria, and these bacteria occur naturally in live animals. That is why raw meat carries safe handling instructions for products intended to be consumed by people. Humans can tolerate a low-level presence of bacteria, which allows foods such as soft egg yolks, or rare steaks, to still be enjoyed safely. Dogs and cats have a much higher tolerance for most bacteria, and so the “safe” levels for them could be significantly higher.
But the FDA, by contrast, enforces a zero-tolerance policy for Salmonella and other bacteria in all pet food — dry, canned, or raw — treating any detectable presence as an “adulterant”. There is no cooking step between the bag and the bowl for pet foods, and the FDA’s stated concern is less about the pet’s health than about the humans in the household — kids, elderly relatives, or immunocompromised people who might mishandle contaminated food.
The Raw Pet Food Battle:
This discrepancy is the crux of the debate between the FDA and raw pet food manufacturers. Raw diet brands argue the double standard is unfair: the same Salmonella-positive chicken that is legally sold to a human at the grocery store (with cooking-instructions for humans) becomes an “adulterated,” recall-triggering product the moment it’s packaged as pet food. Some companies have pushed back hard — one manufacturer, Lystn (maker of the Answers brand), sued the FDA over the policy after a positive Salmonella sample triggered a warning, arguing the zero-tolerance standard for pet food is not founded in the same food-safety science the agency applies in other areas.
The FDA’s counter-argument is about exposure pathways, not just the meat itself: pet food is handled in kitchens, scooped with hands, and fed from bowls that don’t always get sanitized the way a cutting board does after raw chicken. Documented human Salmonella outbreaks have been traced to contaminated dry pet food, but there are no documented ties to raw pet food in spite of numerous FDA forced raw pet food recalls.
HPP has become the raw pet food industry’s compromise. Under the FDA’s Investigations Operations Manual, there are only three recognized ways to reduce pathogens in raw meat products: cooking, irradiation, and high-pressure processing. Cooking is not an option for fresh or raw products. Irradiation requires specialized facilities and is not popular among those preferring a minimally processed, more natural diet. That leaves HPP as the preferred option for a raw food manufacturer to satisfy FDA pathogen requirements while still calling the product raw.
Where the Controversy Comes In:
HPP has generated its own separate controversies wherever it’s used:
Is it still “fresh” or “raw”? This has ended up in court repeatedly on the juice side of the industry. Several juice makers — including brands like Suja and BluePrint — were sued by consumers who argued that HPP-treated juice shouldn’t be marketed as “fresh,” “raw,” or “cold-pressed.” The FDA has stated plainly that companies can’t call HPP-treated juice “fresh,” citing federal labeling regulation 21 CFR 101.95, though it has acknowledged there’s no specific rule governing the word “raw.” Court outcomes on “raw” and “cold-pressed” labeling suits have been mixed — some were dismissed, others settled — and the labeling question remains unsettled.
Does pressure generate heat? Opponents argue that intense pressurization inevitably raises product temperature, undercutting the “unheated” claim. HPP operators counter that their systems are engineered to keep the water bath and product cool throughout the cycle, which is central to the claim that the food isn’t “cooked.”
Does it destroy nutrients? Critics say any processing degrades vitamins and enzymes. Industry and much of the food-science literature suggest nutrient loss from HPP is minimal compared with traditional heat pasteurization — but studies are still being done to determine how “minimal” it is.
Summary:
HPP, like any processing method, works as well as the manufacturer’s quality control step to reduce pathogens. HPP reduces pathogen risk, but “HPP-treated,” “fresh,” and “raw” aren’t always interchangeable claims, and the acceptable-risk bar for a product depends a great deal on which federal agency is holding the ruler.
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References
– FDA Investigations Operations Manual (2026), U.S. Food and Drug Administration — https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/inspection-references/investigations-operations-manual
– “High pressure processing: more raw pet food research needed,” PetfoodIndustry.com
– “High-Pressure Processing and Raw Pet Food Diets: What You Need to Know,” Pet MD
– “About Pet Food Safety,” CDC Healthy Pets, Healthy People
– FSIS Directive 6120.2, “High Pressure Processing (HPP),” USDA Food Safety and Inspection Service
– “Judge tosses HPP-treated juice lawsuit vs Hain Celestial,” Food Navigator-USA
– “Suja Life ‘raw’ juices in lawsuit on high pressure processing (HPP),” Food Navigator-USA
– “New York Court Gives Juice Labeling Claims the Cold Treatment,” Holland & Knight Insights
– FDA Warning Letter, Pressure Safe, LLC (520442), 06/07/2017, fda.gov
– “FDA’s fixation on raw pet food ratchets up again,” PetfoodIndustry.com
– “Raw pet food brand sues FDA over zero Salmonella policy,” PetfoodIndustry.com
– “Explaining the FDA Zero Tolerance Policy,” Viva Raw
– “Salmonella Presence and Risk Mitigation in Pet Foods: A Growing Challenge with Implications for Human Health,” PMC/National Library of Medicine
– “High pressure processing to control Salmonella in raw pet food without compromising the freshness appearance,” Food Control / ScienceDirect
– “Inactivation of Salmonella, Shiga Toxin-producing E. coli, and Listeria monocytogenes in Raw Diet Pet Foods Using High-Pressure Processing,” ScienceDirect
– “The efficacy and safety of high-pressure processing of food,” EFSA Journal, 2022
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