How stakeholder feedback might shape a federal definition of ultra-processed foods

By Scarlett Salem, MS, MPH and Jared Rothstein

The FDA and USDA are moving toward establishing a federal definition of ultra-processed foods, with a proposal expected in the coming months. Public comments submitted in response to the agencies’ request for information reveal broad interest in defining UPFs — but little consensus on how that definition should be structured.

Stakeholders remain divided over whether to rely on processing-based frameworks like NOVA, incorporate nutrient criteria, or develop hybrid approaches grounded in labeling feasibility and existing nutrition policy. Many also raised concerns about unintended consequences for food access, labeling, and federal nutrition programs.

This AgencyIQ analysis examines key themes from stakeholder feedback and what they signal for the direction of a federal UPF definition.

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