Why would plant-based cookie dough packaging say "Do not consume raw dough"?

I was surprised at how difficult it was to find the answer, but I eventually found articles by the FDA and CDC.

Consumers should be aware that there are additional risks associated with the consumption of raw dough, such as particularly harmful strains of E. coli in a product like flour.

Flour is derived from a grain that comes directly from the field and typically is not treated to kill bacteria[...] So if an animal heeds the call of nature in the field, bacteria from the animal waste could contaminate the grain, which is then harvested and milled into flour.

Common “kill steps” applied during food preparation and/or processing (so-called because they kill bacteria that cause infections) include boiling, baking, roasting, microwaving, and frying. But with raw dough, no kill step has been used. [...] Common symptoms for Shiga toxin-producing E. coli are diarrhea (often bloody) and abdominal cramps, although most people recover within a week. But some illnesses last longer and can be more severe, resulting in a type of kidney failure called hemolytic uremic syndrome (HUS).

That's pretty gross.

But then this number of people reportedly infected is so small that I'm surprised at the prevalence of the warnings (such as on packaging):

In recent years (2016 and 2019), two outbreaks of E. coli infections linked to raw flour made more than 80 people sick. Flour and baking mixes that contain flour have long shelf lives, so it’s a good idea to check your pantry to see if you have any flour or baking mixes that have been recalled in recent years.

There is no rule that plant based food is safe to be eaten raw. Also, on a side note, the salmonella reasoning was somewhat misguided - not that it isn't a risk, but it isn't the reason why cookie dough is not intended for raw consumption.

When determining food safety, one doesn't ask "where will the bacteria come from", except in some very special cases (eggs are one of them). Bacteria, yeasts and mold spores are always present everywhere, on all surfaces in the kitchen, in the fridge, on our bodies, and in the air. The question is not "will it have bacteria", but "will bacteria grow in it".

And for the "will bacteria grow in it", the answer is by default "yes". For the answer to become "no", there has to be a special reason. For example, raw fruit and vegetables are still alive after picking and can resist bacterial infection (else they would have rotted on the plant). Dry foods such as ripe beans don't contain enough moisture for bacteria to grow. Preserved foods have had some necessary factor taken away. And so on.

Cookie dough doesn't fall under any of these exceptions. For all intents and purposes, it is a raw ingredient, which has to be cooked within 3-5 days of making, and stored under refrigeration in that time.

Could be lots of things but I have to tell you I once worked temporarily in a warehouse packing food products and the nutrition labels they used were just 'templates' that they reuse on several different products so the first thing that came to mind was that they were reusing the regular cookie dough label on the plant-based cookie dough product.

Plant based means what? Could mean anything.

Does it mean there can be no pathogens in there?

It does not mean its perfectly cleansed and ready to pop into one's mouth because it came from a fancy package.

Think in terms of

• "Prepared & Ready to eat"
  (modern ready to consume packged junk food - cookies, chips, biscuits etc.)

vs

• "Prepare to eat" (most of human existence)

You have to get to specifics of ingredients and the supply chain of each.

• Would you eat fruits or vegetables without washing?

• Would you cook and eat rice without washing?

Probably not, because you've already assumed and are aware that it may have things that you may not wish to consume; be it pests or pesticides/ fertilizers.

The typical rice had in Indian or Asian house holds is washed several times, soaked and then cooked. That's how you its consumed.

Because something is plant-based does not make it ready to consume without a basic "cleanse/ cook" process - which varies for each item.

Whole wheat flour is typically grinded/ milled so you dont wash it, like say whole grain rice. Same with rice flour.

Now, how and why your "previous cookie dough" was okay to eat - you'd have to ask their supply chain & what they do to make it "ready to eat" raw.

Why most other stuff is not "ready to eat" I've outlined above.