FoodFight USA Calls on FDA to Reassess Refined Carbohydrates and Ultra-Processed Foods

November 21, 2025

Ultra-processed foods (UPFs) now dominate the American diet, and refined carbohydrates are at the core of this public health crisis. As part of our ongoing fight to better regulate food additives and curtail the consumption of UPF, FoodFight USA has submitted a formal public comment in strong support of a landmark petition filed by former FDA Commissioner Dr. David A. Kessler. When someone who once led the FDA calls for modernizing the agency’s oversight, it’s a signal that meaningful reform is both necessary and long overdue.

Dr. Kessler’s petition urges the Food and Drug Administration to revoke the outdated GRAS status (“Generally Recognized as Safe”) for processed refined carbohydrates used in industrial food processing. But the petition does far more than address one ingredient category. It proposes a new model for regulating ultra-processed foods that evaluates ingredient categories, not individual chemical compounds, creating a path toward broader reforms the United States urgently needs.

You can read both Dr. Kessler’s original petition and our FoodFight USA statement of support below. And if you want to join the fight and learn more about opportunities to clean up America’s food system, please sign up for our newsletter. 

📄 Read Dr. Kessler’s original petition

📄 FoodFight USA response to Kessler Petition

What’s the harm in refined carbohydrates?

Ultra-processed foods have become the backbone of the American food system. They now account for nearly 60% of total calories consumed by the average adult, and refined carbohydrates are foundational to their formulation and mass production. These refined grains, starches, and sugars promote overeating, disrupt metabolic function, and contribute to rising rates of obesity, diabetes, and cardiovascular disease.

The science is clear:

  • 93% of Americans overconsume refined grains.
  • Only 2% meet whole grain intake recommendations.
  • UPFs are directly linked to metabolic dysfunction, weight gain, and chronic disease.
  • Current GRAS determinations for refined carbohydrates rely on decades-old assumptions that do not reflect modern consumption levels.

Dr. Kessler’s petition recognizes that today’s levels of exposure fundamentally differ from the conditions under which refined carbohydrates were initially deemed “safe.” FDA policy requires the agency to revisit GRAS determinations when exposure increases sharply.  Nowhere has this increase been more dramatic than with refined carbohydrates and UPFs.

Why FoodFight USA Supports Dr. Kessler’s Petition

FoodFight USA strongly supports Dr. Kessler’s petition because it presents a clear, compelling, and legally grounded case for reevaluating the GRAS status of processed refined carbohydrates.

  1. The health evidence is overwhelming.
     Refined carbohydrates are a major driver of caloric overconsumption, metabolic disruption, and diet-related disease. They are no longer occasional ingredients. They are chronic dietary exposures found across nearly all ultra-processed foods.
  2. Dr. Kessler lays out a precise legal framework for removing GRAS status.
     The petition explains that GRAS determinations are time-dependent and must be reevaluated when exposure dramatically increases. The legal foundation is solid: FDA has full authority to revoke GRAS status without new legislation.
  3. This approach is not anti-business. It is pro-science and pro-transparency.
     If manufacturers believe refined carbohydrates are safe at today’s exposure levels, they should already possess the scientific data necessary to submit a formal food additive petition to FDA. This process creates a level playing field and ensures consistency across the food industry.

How FDA Can Build on the Model Laid Out by Dr. Kessler

Dr. Kessler’s petition offers FDA a powerful new template:
Evaluate ingredient categories, not isolated chemicals.

FoodFight USA believes this is a promising path to meaningful reform.

Using this category-based approach, FDA could review and potentially revoke GRAS status for additional ingredient groups that are most closely associated with UPFs, categories highlighted in our own public comment, including:

  • Emulsifiers
  • Stabilizers and thickeners
  • Gases and propellants
  • Surface-active agents
  • Flavoring agents and flavor enhancers
  • Coloring agents and color adjuncts
  • Non-nutritive sweeteners

Reviewing ingredients by category allows FDA to escape the endless regulatory “whack-a-mole” of evaluating individual chemicals while industry reformulates faster than the agency can assess safety.

This systems-level model aligns regulatory oversight with how UPFs are actually produced and consumed. It moves FDA toward a more proactive, comprehensive food safety strategy.

Use the Petition as a Roadmap to Close the GRAS Loophole

While FDA cannot unilaterally eliminate the GRAS framework—Congress would need to act—the agency can demonstrate its limitations.

By revoking GRAS status for refined carbohydrates and adopting a category-based review model, FDA can:

  • Expose how outdated the current system is;
  • Show that modern exposures far exceed historic assumptions;
  • Clearly illustrate the need for legislative reform; and
  • Build momentum toward a transparent, science-based safety review process.

This petition creates a framework for greater reforms in the future, one that finally aligns U.S. food safety oversight with modern science.

Why This Matters for American Families

Without meaningful FDA oversight, the U.S. continues to operate the world’s largest uncontrolled experiment in dietary chemical exposure. Americans eat more UPFs and refined carbohydrates than almost any other nation and the health consequences reflect it.

Revoking the GRAS status of processed refined carbohydrates is not anti-industry.

It is pro-transparency, pro-consumer, and pro-science.

 

It ensures that all companies play by the same rules and that none can hide behind outdated assumptions or regulatory loopholes.

FoodFight USA urges the FDA to act swiftly on Dr. Kessler’s petition. This is a rare opportunity for the agency to take immediate, evidence-based action that protects public health and sets the stage for comprehensive reform.

📄 Read Dr. Kessler’s original petition

📄 FoodFight USA response to Kessler Petition

To stay updated on this petition, future FDA actions, and our work to improve the safety and transparency of America’s food system, subscribe to the FoodFight USA newsletter.