The current Congressional session has seen the introduction of bipartisan legislation that, if enacted, would dramatically change the regulatory landscape for pet food and animal feed products. The reintroduced Pet Food Uniform Regulatory Reform Act (PURR Act) would make sweeping changes to the regulatory framework for dog and cat food ingredients and claims in which the Food and Drug Administration (FDA) and the states currently share jurisdiction. The newly introduced Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2026 would extend many of the requirements of the PURR Act to all animal food and feed. The reintroduced Innovative Feed Enhancement and Economic Development Act (Innovative FEED Act) proposes to create a new regulatory framework for “zootechnical animal food substances” under which such substances would be regulated by FDA as food additives rather than as animal drugs. While many key stakeholders have expressed support for the PURR Act, state regulators continue to oppose the legislation and have recently introduced resolutions designed to support ongoing state regulation. Many stakeholders including FDA appear to support the Innovative FEED Act, and the agency has said that it intends to develop policies to facilitate the marketing of zootechnical animal food substances in the event the legislation does not pass. This alert provides a concise summary of these key initiatives as well as ways in which stakeholders can further engage on the issues.

Click here to read the full alert on cov.com.

Photo of Deepti Kulkarni Deepti Kulkarni

Drawing from over 15 years of experience working in FDA’s Office of Chief Counsel and private practice, Deepti Kulkarni provides strategic advice to clients on a wide range of matters involving FDA and USDA regulatory oversight of foods, dietary supplements, and animal health…

Drawing from over 15 years of experience working in FDA’s Office of Chief Counsel and private practice, Deepti Kulkarni provides strategic advice to clients on a wide range of matters involving FDA and USDA regulatory oversight of foods, dietary supplements, and animal health products. She works closely with clients to develop and execute strategies to satisfy regulatory requirements and mitigate enforcement and litigation risk while also meeting key commercial goals.

Deepti also counsels clients on potential crises, such as product recalls, import refusals, and responding to agency warning or noncompliance letters, adverse inspection findings and other regulatory actions.

Chambers USA reports that Deepti is “a very strategic lawyer with deep expertise and strong business acumen,” “a food law and regulation expert,” who “has an incredibly thorough grasp of the regulatory process,” finds “creative solutions to novel and complex issues,” and “is also very responsive and gives sound and practical advice.”

Deepti previously served as an Associate Chief Counsel in FDA’s Office of Chief Counsel. While at FDA, she counseled various components of FDA and HHS on a broad scope of issues related to foods, dietary supplements, cosmetics, and animal health products as well as cross-product matters involving imports and exports, advisory committees, and constitutional issues. She also played a key role in the development and implementation of regulatory frameworks for foods and other products developed using biotechnology, gene editing, and other new and emerging technologies. Deepti received several awards during her time at the FDA, including the FDA Award of Merit (FDA’s highest award), Commissioner’s Special Recognition Award, and the CFSAN Director’s Special Citation Award.

Deepti also serves as an Adjunct Professor of Law at Georgetown Law School where she teaches Food and Drug Law.

Read more about Deepti Kulkarni
Show more Show less
Photo of Jeannie Perron Jeannie Perron

Jeannie Perron is a member of the firm’s Food and Drug Practice Group, resident in the Washington, DC Office.

In addition to being an attorney, Jeannie also holds a degree in veterinary medicine and has practiced as a veterinarian.  She specializes in food…

Jeannie Perron is a member of the firm’s Food and Drug Practice Group, resident in the Washington, DC Office.

In addition to being an attorney, Jeannie also holds a degree in veterinary medicine and has practiced as a veterinarian.  She specializes in food and drug law, with a sub-specialty in animal food and drug law.  In this capacity, she represents companies that manufacture feed, feed ingredients, drugs, biologics and medical devices for animals, as well as clients in related industries.

Her specialties also include advising clients and providing representation on matters before the United States Department of Agriculture arising under the Animal Welfare Act.  Her clients are animal research companies, pharmaceutical companies, and animal dealers and exhibitors.

Another specialized area of practice relates to the importation of animal-derived ingredients and products.  Jeannie advises clients on USDA regulations and procedures in this area and assists clients in securing the required permits and certifications.

In addition to these other practice areas, Jeannie also advises clients in the regulation of dietary supplements, over-the-counter drugs, cosmetics for humans, and import and export of products regulated by the United States Food and Drug Administration as well as those having animal or microbially-derived ingredients regulated by USDA. 

Read more about Jeannie Perron
Show more Show less
Photo of Grant Dixon Grant Dixon

Grant Dixon advises a range of international clients on pharmaceutical compliance and enforcement matters. In this area, Grant regularly counsels pharmaceutical manufacturers on U.S. CGMP compliance and remediating deficiencies identified during regulatory inspections, including preparation of submissions to regulators. He also conducts internal…

Grant Dixon advises a range of international clients on pharmaceutical compliance and enforcement matters. In this area, Grant regularly counsels pharmaceutical manufacturers on U.S. CGMP compliance and remediating deficiencies identified during regulatory inspections, including preparation of submissions to regulators. He also conducts internal investigations of allegations concerning compliance with Current Good Manufacturing Practices, Current Good Clinical Practices, and other U.S. FDA regulatory requirements.

Grant also represents companies that manufacture feed, feed ingredients, drugs, biologics and medical devices for animals, those that provide veterinary medical services and that perform biomedical research, as well as clients in related industries.

Read more about Grant Dixon
Show more Show less
Photo of Alicia Lee Alicia Lee

Alicia Lee is an associate in the firm’s Food, Drug, and Device Practice Group. She advises food and dietary supplement companies on a wide range of regulatory and compliance matters, including FDA’s food safety and labeling requirements and FTC’s advertising standards. She provides…

Alicia Lee is an associate in the firm’s Food, Drug, and Device Practice Group. She advises food and dietary supplement companies on a wide range of regulatory and compliance matters, including FDA’s food safety and labeling requirements and FTC’s advertising standards. She provides strategic advice to food technology companies regarding Generally Recognized as Safe (GRAS) determinations, color additive petitions, and other premarket submissions to FDA. Alicia also advises clients on FDA requirements relating to imports and guides clients through import refusals.

In addition, Alicia assists manufacturers of pet food and animal feed navigate a complex regulatory landscape, including with respect to ingredient approvals, regulatory classification, and labeling. She also counsels clients on requirements under the Animal Welfare Act.

Read more about Alicia Lee
Show more Show less