FDA, USDA take first steps to define ultra-processed foods

On July 25, the FDA and USDA issued a joint request for information seeking input on relevant factors and criteria that should inform a standardized federal definition of ultra-processed foods. With the release of the RFI, the administration has begun to build a policy foundation upon which future government actions to address and restrict UPFs will likely occur.

By Jared Rothstein | Jul 28, 2025 4:21 PM EDT

Background and recent policy activities on ultra-processed foods

Ultra-processed foods have emerged in recent years as a topic of public health concern. They are generally described as foods that undergo a high degree of industrial processing, contain a significant number of additives and tend to have high levels of nutrients of concern such as saturated fat, sodium and added sugar. Other characteristics often cited in public discourse, policymaking, and research include UPFs having long shelf life and high energy density, and being ready to eat and highly palatable. The most frequently cited scientific approach for defining UPFs, particularly for nutrition research, relies upon the NOVA classification system. This classification divides food into four main categories: unprocessed or minimally processed foods (such as fresh fruits and vegetables, meat, milk, and eggs), processed culinary ingredients (such as oils, butter, sugar and salt), processed foods (such as canned meat, fresh bread and cheeses), and UPFs (such as soft drinks, breakfast cereals, and confectionary and snack products).
Research on UPFs has found associations with obesity and diet-related chronic disease, with limitations and caveats. One National Institutes of Health study found that participants ate around 500 calories more per day on a UPF-specific diet compared to a diet of minimally processed foods. A systematic review examining the association between UPFs and cardiovascular disease found an adverse association between overall UPF intake and cardiovascular disease and coronary heart disease, though there were divergences based on food categories. “Sugar-/artificially-sweetened drinks and processed meats were associated with higher CVD risk, whereas inverse associations were observed for bread/cold cereals, yoghurt/dairy desserts, and savoury snacks.” Another study found that reductions in UPF consumption were associated with lower incidence rates of type 2 diabetes, though the research similarly found variances depending on the food categories: “Savoury snacks, animal-based products, ready-to-eat/heat mixed dishes and artificially- and sugar-sweetened beverages (ASB/SSB) were associated with higher incident type 2 diabetes mellitus, whereas breads, biscuits and breakfast cereals, sweets and desserts, and plant-based alternatives were associated with lower incident type 2 diabetes mellitus.” A systematic umbrella review of 45 pooled meta-analyses and systematic reviews broadly found that “greater exposure to ultra-processed food was associated with a higher risk of adverse health outcomes, especially cardiometabolic, common mental disorder, and mortality outcomes,” though the vast majority of the data used was rated as low quality or very low quality.
States have begun developing policies to restrict and regulate UPFs. Most of the recent state legislative efforts have focused on the presence of specific food or color additives as the primary defining characteristic of a UPF. For example, a recent Arizona law was the first to define a UPF as any food or beverage that contains an additive listed in the legislation, including synthetic colorants and preservative ingredients. Other states have focused on defining UPFs based on additive categories with technical functions. For example, legislation in California defines UPF as any food or beverage that contains an ingredient with certain FDA-defined technical effects as outlined at 21 CFR 170.3(o). The list covers surface-active agents; stabilizers and thickeners; propellants, aerating agents, and gases; colors and coloring adjuncts; emulsifiers and emulsifier salts; flavoring agents and adjuvants; flavor enhancers; and non-nutritive sweeteners. California’s legislation also bifurcates UPFs into two categories, one being “particularly harmful ultraprocessed food,” based on “specified factors, including, among others, whether, based on reputable peer-reviewed scientific evidence, a substance or group of substances are linked to health harms or adverse health consequences”; the other being all other UPFs.
Initiatives to study and address UPFs have accelerated under the Trump administration. A joint nutrition regulatory science program announced by the FDA and NIH will include a focus on UPFs and their impact on human health, according to the press release. The administration’s interest in UPF research is evident in a recent grant opportunity published by the FDA, which aims to fund a study of the nutritional qualities of school meals and implementation interventions, including replacing UPFs with whole food offerings. HHS and USDA are expected to soon release an updated version of the U.S. Dietary Guidelines for Americans, with a focus on encouraging whole foods over UPFs in diets. HHS is also planning a “Take Back Your Health” public health campaign highlighting the links between UPF consumption and diabetes to reshape and improve dietary habits. Finally, the Make America Healthy Again Commission’s strategy on mitigating childhood chronic disease is expected to focus on actions to study UPFs and minimize their consumption.

Overview of the FDA’s request for information on UPFs

HHS, FDA, and USDA wrote that the request for information will be used to establish an actionable UPF definition that can be used by the federal government. In their joint press release announcing the RFI, the agencies wrote that the RFI will be used “to gather information and data to help establish a federally recognized uniform definition for ultra-processed foods.” The announcement mentions that a clear definition established by the federal government is “a critical step in providing increased transparency to consumers about the foods they eat” and will be used to inform research and policy activities “to pave the way for addressing health concerns associated with the consumption of ultra-processed foods.”
The notice highlights emerging public health concerns associated with widespread consumption of foods considered “ultra-processed” or “highly processed.” The agencies cite research demonstrating that more than half of calories consumed by American adults and children are from UPFs and found links between consumption of these foods and a variety of negative health outcomes. The notice emphasizes that improvement of nutrition is, therefore, a critical intervention to mitigate diet-related chronic illnesses and improve public health. The RFI also cites examples of different policies and scientific approaches to define and classify UPFs, with attention paid to the degree of processing, nutrient composition and presence of additives.
The RFI seeks feedback on how to accurately characterize and classify UPFs. The agencies request feedback on what current classification systems or policies should be considered when defining UPFs, including information on what advantages and challenges might exist in using these systems to classify foods. Feedback is also sought on the characteristics of food ingredients and their suitability for defining UPFs, including whether the amount and proportion of their use in the finished food product is relevant to characterizing a food as ultra-processed. The RFI seeks input on what types of physical, biological or chemical processing techniques might be used to characterize a food as ultra-processed. The role of nutritional composition, caloric density, and palatability are also raised as potential factors to characterize a UPF. Finally, the agencies request feedback on how they might incorporate all these various factors into an integrated UPF classification system, whether the “ultra-processed” terminology for foods is appropriate, and how a UPF classification could be incorporated into federal food and nutrition policies and programs.

Analysis and next steps

The RFI foreshadows the coming challenge of establishing a clear and consistent definition. The notice connects UPFs with “a range of negative health outcomes, including cardiovascular disease, obesity, and certain cancers,” as well as “lower diet quality, increased caloric intake, and the intake of food additives.” At the same time, it acknowledges that current definitions cannot accurately isolate UPFs that negatively impact health outcomes. The agencies note that UPFs “encompass a broad range of industrially processed foods,” including foods that are high in added sugars, sodium and saturated fat such as snack foods and soft drinks, and foods that are considered beneficial to health and dietary patterns such as whole grain products and yogurt. The notice also points to the divergent approaches to UPF classification that have been developed by scientific researchers and policymakers, including proposals that focus on additive categories, processing steps, or lists of specific ingredients, indicating that there is not yet a common consensus of what makes a food ultra-processed. During a July 27, 2025, interview with POLITICO’s Dasha Burns, FDA Commissioner MARTIN MAKARY stressed this point, saying “if we’re showing humility and we’re being honest, there’s no perfect definition. This is an attempt to try to say, ‘Here’s a group of foods that’s generally not as healthy as more wholesome foods.’”
In discussing the UPF RFI, Makary also seemed to suggest that a federal definition would integrate elements that account for processing, additives and nutrients. Makary described steps in food production, noting “so, there’s sort of raw foods and whole foods and things you eat right out of the ground or from a farm. And then there’s our processed foods, which could be as simple as taking good healthy foods and putting them in a can. … It doesn’t mean it’s bad for you just because it’s processed. I mean, cutting a cucumber could be processed. And then there’s what we call ultra-processed. It’s the bars you buy that look like health bars. You turn it over and it’s got 35 ingredients, right? And so, how do you really describe that group of foods that we know are designed for high shelf life? We know they’re loaded with chemicals. And how do we encourage people to eat more wholesome foods and natural foods and things with fiber and complex carbohydrates instead of simple carbohydrates?” Makary also emphasized that the agency needs to adequately differentiate the highly processed foods that present health concerns, suggesting that a more nuanced and integrated approach may be the agency’s preference when crafting a definition.
The coming update of the DGA is one immediate area where a UPF definition would likely be used. The MAHA Report was highly critical of the DGAs, asserting that they have been “compromised” by industry and have “little distinction between industrially processed foods and home-cooked or whole foods if their nutrient profiles look similar.” The report reprimanded the 2025 Dietary Guidelines Advisory Committee for not including any recommendations in the latest iteration for limiting ultra-processed foods in the diet. However, the 2025 DGAC did evaluate current research on dietary patterns with UPFs and recommended continued examination of the association of UPFs with health and development in its 2025 Scientific Report. The committee emphasized that attempts for its inclusion in the DGA review process led to “inconsistency among definitions” and “evidence graded as limited but might change if a more rigorous definition of ultra-processed foods is developed and further studies are conducted.” Altogether, this signals that the administration will be focused on incorporating a definition of UPFs in the next DGA and issuing recommendations to limit the category in diets.
Incorporating a UPF definition into the DGA recommendations would reshape federal food assistance and meal programs. The current 2020-2025 iteration of the DGA notes that “the National School Lunch Program and the Older Americans Act Nutrition Program incorporate the Dietary Guidelines in menu planning; the Special Supplemental Nutrition Program for Women, Infants, and Children applies the Dietary Guidelines in its program and educational materials; and the Healthy People objectives for the Nation include objectives based on the Dietary Guidelines.” KYLE DIAMANTAS, the FDA’s deputy commissioner for human foods, also suggested in an interview with The New York Times that a UPF definition could be used to shape meal programs for the military, prisons and Veterans Affairs hospitals. Furthermore, with the rise in state food restriction waivers under the Supplemental Nutrition Assistance Program, it could be anticipated that future state waiver requests may seek to limit the purchase of certain categories of food that are classified as UPFs of particular public health concern.
A federal UPF definition could also be used to inform future food labeling initiatives. Prior comments by Makary have suggested that the agency’s UPF work could encourage companies to label foods as “non-ultraprocessed”. The FDA could be inclined to follow up on the definition with an established voluntary claim to communicate on the package that a food is “non-UPF” to consumers. The Non-GMO Project organization is already working to issue its own Non-UPF Verified certification, which could be informed by the federal definition. And with the FDA’s ongoing work to issue a mandatory front-of-package nutrition labeling rule, the agency will also likely face public pressure to incorporate some element of the UPF definition into its FOPNL scheme, though that approach is unlikely to easily work within a framework that is designed to only highlight nutrients to limit.
The MAHA strategy could be an early indication of how the administration might make use of the RFI and a federal UPF definition. The RFI is described by the agencies in their announcement as a key deliverable of the “Make Our Children Healthy Again Assessment,” which highlighted UPF consumption and dietary prevalence as a major contributor to childhood chronic disease. The RFI also cites the MAHA assessment as a relevant background document justifying the request. With the administration planning to follow up on the MAHA report by Aug. 12 with a government-wide strategy, it may articulate how a UPF definition once developed, would be used to inform food and nutrition policy, and research programs.

To contact the author of this item, please email Jared Rothstein ( jrothstein@agencyiq.com)
To contact the editor of this item, please email Ashley C. Klein ( aklein@agencyiq.com)

Key documents and dates

Ultra-Processed Foods; Request for Information (published July 25, 2025)
Deadline to submit comments: Sept. 23, 2025