Ultra-processed food definition and initial feedback to FDA and USDA reveal complex challenges for rule-makers

Ultra-processed food definition and initial feedback to FDA and USDA reveal complex challenges for rule-makers

The FDA, USDA, and the Department of Health and Human Services (HHS) have jointly issued a Request for Information (RFI) to gather public input and develop a uniform federal definition of "ultra-processed foods" (UPFs). This move follows the May 2025 "Make America Healthy Again" (MAHA) Commission report, which highlighted UPFs as a significant contributor to chronic health conditions, particularly in children. The agencies aim to create a consistent definition to guide future research, regulatory policy, and consumer guidance.

Current Status:

The RFI was published in late July 2025, inviting wide-ranging input on defining UPFs. As of now, no final definition has been established, with the agencies set to synthesize stakeholder comments after the submission deadline on September 23, 2025.

Various Definitions and Approaches Being Proposed or Discussed:

1. Existing Classification Systems:
2. Agencies seek input on the strengths and weaknesses of existing UPF classification frameworks, such as the NOVA classification, to help refine criteria.
3. Ingredient-Based Criteria:
4. Some definitions focus on the presence and amount of certain ingredients, like synthetic additives (thickeners, stabilizers, colorings, flavorings).
5. There is debate over whether the inclusion should be ingredient-driven or based on the food’s compositional profile.
6. Processing Methods:
7. Consideration of physical, biological, or chemical processes used in manufacturing, such as extrusion, hydrogenation, or use of novel technologies.
8. Some stakeholders emphasize processing steps as indicative of UPFs, while others argue for integrating both factors.
9. Terminology:
10. The agencies question whether "ultra-processed" is the best term or if alternative terms might more accurately reflect the health implications or processing extent.
11. Nutritional and Other Attributes:
12. Discussions include whether to factor in nutritional composition (e.g., energy density, added sugars, sodium), and sensory qualities like palatability, into the definition.
13. There's debate on whether UPFs should be defined solely by processing or also by their nutritional impact.
14. Policy and Regulatory Context:
15. A uniform definition is seen as crucial to enable consistent labeling laws, marketing restrictions, and public health messaging.
16. Several states have proposed legislation with differing UPF definitions, highlighting the need for federal alignment.

Key Points: - There is consensus on the need for a single, standardized federal definition to unify research and regulatory efforts. - Scientific consensus on the mechanisms linking UPFs to health outcomes remains unsettled; the RFI aims partly to clarify this. - The FDA, USDA, and HHS appear aligned in their urgent interest in combating chronic diseases linked to UPFs through this definitional clarity.

Some notable definitions proposed include Kimberly Alley's targeting of ultra-processed foods with MSG and anything sweetened with anything but cane sugar, Steven Pexton's definition of UPFs as industrially formulated products made mostly or entirely from substances extracted from foods, derived from food constituents, or synthesized in laboratories, and Christopher Perron's definition of UPFs as foods we would be unable to create on our own in a natural environment.

In summary, the agencies are actively soliciting information in mid-2025, with a detailed RFI open until September 23, 2025. The definitions under consideration differ mainly on the emphasis placed on ingredients, processing techniques, nutritional content, and terminology, reflecting diverse stakeholder views. The outcome will shape future U.S. food policy on UPFs.

1. The Food and Drug Administration (FDA), United States Department of Agriculture (USDA), and the Department of Health and Human Services (HHS) are seeking public input to develop a uniform federal definition of "ultra-processed foods" (UPFs) for future research, regulatory policy, and consumer guidance.
2. The FDA, USDA, and HHS are considering various methods for defining UPFs, including examining existing classification systems, focusing on the presence and amount of certain ingredients, considering physical, biological, or chemical processing methods, and debating on appropriate terminology to accurately reflect health implications.
3. The federally proposed definition of UPFs may factor in nutritional composition, such as energy density, added sugars, sodium, and sensory qualities like palatability.
4. The establishment of a uniform federal definition is crucial for consistent labeling laws, marketing restrictions, and public health messaging, ensuring policy and regulatory alignment between states, and contributing to the clarification of the scientific consensus on the mechanisms linking UPFs to health outcomes.

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