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In July 2025, the U.S. Food and Drug Administration and U.S. Department of Agriculture (USDA) issued a joint Request for Information seeking data to develop a “uniform definition” of ultra-processed foods. The agencies said a uniform definition would allow for consistency in research and policy and “pave the way for addressing health concerns associated with the consumption of UPFs.” The comment period closed on Oct. 23, 2025, and drew more than 5,000 comments.

On Aug. 10, 2026, the U.S. Department of Health and Human Services (HHS) and USDA announced that they had submitted a proposed UPF definition to OMB for final review. As of Oct. 13, 2026, the text had not been released. The agencies have described it as a “white paper,” rather than a regulation, consistent with earlier statements that the definition would be introduced as a research tool rather than through formal rulemaking. HHS has described the goal as creating “a stronger foundation for future nutrition research.”

OMB’s public calendar lists a series of meetings under Executive Order 12866 concerning the “White Paper: Proposed Definition of Ultra-Processed Food” through September and into October 2026. These meetings are one of the last formal opportunities to put data and perspective in front of decision-makers before the definition is published. Once published, attention will likely shift to how agencies, legislatures, and other policymakers incorporate the definition into nutrition programs, procurement requirements, labeling frameworks, and other policy initiatives.

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Photo of Chris DeLacy Chris DeLacy

Christopher DeLacy brings over 23 years of experience navigating the complex intersection of law, policy, and politics. As Co-Chair of the Federal Government Law & Policy Practice, he serves as a lead strategist for corporations, trade associations, and nonprofits seeking to shape federal…

Christopher DeLacy brings over 23 years of experience navigating the complex intersection of law, policy, and politics. As Co-Chair of the Federal Government Law & Policy Practice, he serves as a lead strategist for corporations, trade associations, and nonprofits seeking to shape federal policy and manage high-stakes regulatory challenges.

  • Legislative Strategy: Chris designs and executes complex, multiyear advocacy campaigns, combining grassroots and grasstops mobilization with direct representation before Congress and the executive branch. These efforts often include companion litigation, regulatory, and state lobbying matters.
  • Political Law & Compliance: A recognized authority on political law, he guides clients through the rigors of the Federal Election Campaign Act, the Lobbying Disclosure Act, and government ethics rules. He has represented clients before the Federal Election Commission and the House and Senate Ethics committees.
  • Emerging Policy Leader: He is a frequent commentator on cybersecurity, data privacy, and emerging technology issues, offering clients foresight into evolving federal legislation, regulation, and tax incentives.

Before private practice, Chris served as Counsel to U.S. Senator John Warner of Virginia and the House Committee on Science, Space, and Technology.

Photo of Campbell Genn˘ Campbell Genn˘

Campbell Genn advises organizations across the entire farm-to-fork supply chain on food, nutrition, and agricultural policy. Leveraging her background in the food industry and her tenure as Senior Advisor to the U.S. Secretary of Agriculture, she approaches her practice through a business lens—helping

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Campbell Genn advises organizations across the entire farm-to-fork supply chain on food, nutrition, and agricultural policy. Leveraging her background in the food industry and her tenure as Senior Advisor to the U.S. Secretary of Agriculture, she approaches her practice through a business lens—helping clients navigate and shape the policies affecting their ability to produce safe, affordable, and nutritious food. Campbell delivers strategic counsel and advocacy across a broad spectrum of emerging issues, including federal feeding programs (SNAP, WIC, school meals), USDA and FDA labeling initiatives, the definition of “ultra-processed foods,” meat, poultry, and egg safety regulations, the Farm Bill, and agricultural trade. Beyond these core areas, she equips organizations to anticipate, navigate, and drive whatever the regulatory landscape demands next.

Clients rely on Campbell’s insider insights and deep relationships across Congress, the USDA, the FDA, and key regulatory bodies for the foresight and positioning required to thrive in a highly regulated food system. She bridges the gap between well-intentioned policy concepts and operational reality. By grounding regulatory proposals and legislative bills in practical business operations and essential nutrition science that is often missing from the debate, Campbell empowers clients to engage policymakers and shape emerging regulations and legislation into workable, science-based, strategies.

As Senior Advisor to the U.S. Secretary of Agriculture, Campbell operated at the heart of federal decision-making. During her tenure at USDA, she advised Cabinet leadership on national nutrition policy, supply-chain resilience, and food safety, while contributing significantly to the development of the 2020-2025 Dietary Guidelines for Americans. At the height of the COVID-19 pandemic, Campbell played a key role in executing the policy to distribute nearly $100 billion in food assistance and led an eight-person team that restored national protein processing capacity within two weeks. Serving as USDA’s primary point of contact for White House policy communications—including Presidential speeches and executive orders—her Executive Branch experience gives her an unparalleled understanding of how federal policy is forged, how cross-agency coordination operates, and how to navigate Washington to pursue real-world business results.

In the private sector, Campbell led advocacy coalitions and drove government relations strategy for hundreds of food manufacturers, ingredient suppliers, and agricultural producers. She has directed high-stakes campaigns representing nearly 400 commercial enterprises—protecting business competitiveness, managing heightened federal scrutiny, and approaching complex regulatory and marketing challenges across the supply chain.

˘ Not admitted to the practice of law.
Photo of Alice Kessler Alice Kessler

Alice Kessler is the Co-Managing Shareholder of the Sacramento Office, Co-Leader of the California Government Law & Policy Group in the firm’s Sacramento office, and Co-Chair of the firm’s LGBTQ+ Affinity Group. She is an accomplished legislative strategist with a track record of…

Alice Kessler is the Co-Managing Shareholder of the Sacramento Office, Co-Leader of the California Government Law & Policy Group in the firm’s Sacramento office, and Co-Chair of the firm’s LGBTQ+ Affinity Group. She is an accomplished legislative strategist with a track record of rapid advancement grounded in proven strategic and communication talents, collaborative skills, and trusted integrity. Alice has deep relationships with California policymakers, thought leaders, and community-based organizations. She leverages her well-honed skills to build consensus, gain buy-in, and motivate team members and partners.

Alice helped to launch the startup state advocacy practice at one of the largest public affairs consultancies on the West Coast, where she worked to advance the interests of technology firms, automakers, trade associations, and local government entities. As managing partner for one of the fastest growing lobbying firms in Sacramento, she oversaw all business operations and represented clients in the areas of energy, technology, health care, and education.

She has led policy and community initiatives in the San Francisco and North Bay Area markets for the largest cable television and broadband provider in the United States. She has also directed all legislative, political, and administrative advocacy for a $12 million organization that has been the driving force behind some of the most comprehensive civil-rights protections in the nation for LGBTQ+ individuals.

Alice also volunteers her time for her community. Among other honors, she has been recognized as an individual who has made an impact on the movement to secure full and lasting equality for LGBTQ+ people. She has appeared extensively in print, broadcast, and radio media, including the Los Angeles Times, San Francisco Chronicle, Sacramento Bee, and San Diego Union Tribune.