UNC, Harvard Launch Initiative to Inform Ultra-Processed Food Policymaking
The University of North Carolina at Chapel Hill (UNC) Global Food Research Program and Harvard Law School's Food Law and Policy Clinic have launched the Food Policy Accelerator, a new initiative intended to provide policymakers and advocates with scientific research, food supply data, and legal expertise to support the development of policies addressing ultra-processed foods (UPFs).
Developed in collaboration with Fed UP!, an organization focused on researching and raising awareness of UPFs and their potential health effects, the initiative will offer technical assistance to federal, state, and local government agencies, legislative offices, nonprofit organizations, and advocacy groups.
Specifically, the Food Policy Accelerator will combine nutrition science with legal and policy analysis to support the development and implementation of regulations related to food labeling, marketing restrictions, school nutrition standards, public food procurement, and access to minimally processed foods.
The initiative's work will include:
- Food supply analysis and nutrition profiling: Evaluating which products would be affected by proposed regulations, establishing nutritional criteria, and assessing potential effects on food availability, affordability, and purchasing patterns
- Policy development and technical assistance: Providing scientific guidance and feedback on proposed legislation and regulations addressing food labeling, marketing, school nutrition, and public food procurement
- Legal research and support: Helping state and local governments navigate legal questions related to food regulations and public health policies
- Resources for policymakers: Developing fact sheets, issue briefs, expert testimony, public comments, and other materials to inform regulatory and legislative decisions.
For example, the Accelerator could help a state considering front-of-package labeling requirements determine which products would be covered by proposed rules, establish nutritional criteria, and evaluate legal considerations. Similarly, school districts and local governments could use the initiative's food supply research to assess the potential effects of new procurement standards.
The Accelerator will also conduct longer-term research to evaluate how proposed policies could affect different populations, identify research gaps, and develop scientific and legal resources that can be adapted across jurisdictions.
U.S. Policymakers Consider How to Define and Regulate Ultra-Processed Foods
The Food Policy Accelerator's launch comes amid ongoing federal and state efforts to define and regulate UPFs, as well as scientific debate over the appropriateness and potential consequences of regulating foods based on processing characteristics.
In August 2026, the U.S. Food and Drug Administration (FDA) and U.S. Department of Agriculture (USDA) submitted a proposed federal definition for UPFs to the White House Office of Management and Budget (OMB) for final review. Although U.S. Health Secretary Robert F. Kennedy Jr. has been teasing that a federal UPF definition is “coming soon” since early 2026, OMB has been mired in discussions with concerned industry representatives and the White House is unlikely to rush to publish a definition, per Food Fix.
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The proposed definition followed a joint FDA–USDA Request for Information issued in July 2025, which received mixed responses from food system stakeholders.
Although some stakeholders have supported establishing a federal definition as a basis for addressing potential health harms associated with UPFs, others have raised concerns about the scientific validity and unintended consequences of regulating foods as a category based on processing.
Specifically, critics have argued that an emphasis on processing rather than nutritional composition could unfairly characterize nutrient-dense foods as unhealthy, while further stigmatizing food processing practices that serve important food safety and nutritional purposes.
A federal definition could establish a common framework for future regulatory actions.
At the state level, California recently passed a bill establishing a certification seal for foods that are classified as “not-ultra-processed.”
Against this evolving regulatory backdrop, the Food Policy Accelerator aims to help policymakers evaluate the scientific and legal implications of proposed UPF policies.
"Federal policymakers, as well as state and local leaders, are exploring new ways to protect public health through food policy, but developing effective regulations requires navigating complex legal and scientific questions," said Emily Broad Leib, J.D., Director of Harvard Law School's Center for Health Law and Policy Innovation and Fed UP! scientific contributor.
