Fixing Our Food System Starts with Defining Ultra-Processed Foods

December 3, 2025

FoodFight USA’s Response to the FDA, HHS, and USDA’s Call for a Federal Definition

In July 2025, the FDA, USDA, and HHS announced a major step forward: the U.S. government is officially working on a uniform federal definition of ultra-processed foods (UPFs). Currently, the U.S. has no standard definition, even though UPFs make up 70% of packaged foods in stores, and children get over 70% of their calories from them.

Dozens of studies have linked diets high in UPFs to heart disease, Type 2 diabetes, cancer, obesity, depression, anxiety, and early death. One American dies every four minutes from preventable diet-related illness.

Along with the federal government’s announcement was a request for public input. Thus, FoodFight USA collaborated with Eat Real and Dr. Joseph Shaw to submit an extensive comment urging a clear, practical, science-based definition. You can read our public comment 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 FoodFight USA’s full public comment (PDF)

Why UPFs Need a Clear National Definition

UPFs are unhealthy because of their ingredients or nutrient profile. But those aren’t the only factors–the processing itself can fundamentally change how food interacts with the body. Studies in the U.S., Japan, and Europe all confirm that UPFs can disrupt hunger cues, make people eat faster, and encourage overeating.

But the biggest problem?

There’s no single way to define an ultra-processed food. Different researchers and institutions use different systems. This makes it harder to study UPFs and even harder to regulate them.

A national definition would:

  • Make scientific research more consistent
  • Help schools, agencies, and lawmakers set evidence-based nutrition standards
  • Guide food labeling, marketing rules, and safety oversight
  • Give consumers clearer, more honest information

FoodFight USA recommends this definition be reviewed every two years by an FDA office (either newly created or authorized within an existing one), ensuring it stays aligned with emerging science.

How FoodFight USA Proposes To Define UPFs

We propose a definition that is tiered, simple, and built on strong evidence. A food would qualify as UPF if it meets any of these criteria:

Foods high in sugar, salt, saturated fat, low in fiber, and containing additives linked to heavy processing

UPFs often have unhealthy nutrient profiles plus industrial additives that don’t appear in home cooking. FoodFight USA recommends using thresholds from global models like the Pan American Health Organization (PAHO) Nutrient Profile Model, combined with clear markers of high processing, such as the following:

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

Countries that have tried nutrient-only rules saw companies simply swap sugar for artificial sweeteners. Only when processing and nutrients are considered can we close the loopholes.

Foods containing ingredients linked to documented health risks

Large recent studies from NIH, NCI, the BMJ, and global research centers have linked UPF consumption to:

  • Obesity
  • Cardiovascular disease
  • Type 2 diabetes
  • Dementia and cognitive decline
  • Stroke
  • Behavioral and developmental issues
  • Increased all-cause mortality

Any substance repeatedly linked to these outcomes should automatically qualify a food as UPF, with pending scientific review every two years.

Foods with ingredients already banned or restricted elsewhere

Because of the GRAS loophole, 10,000+ chemicals have been allowed into the U.S. food supply, which is far more than other countries. In contrast, the EU, Japan, Canada, Australia and New Zealand only allow less than 900 additives in their food systems.

More than 44 countries now apply front-of-package warning labels for unhealthy food. Many have banned dyes, preservatives, and additives still common in American foods.

U.S. states are now doing the same:

  • 16 states have already passed bipartisan bills banning or restricting harmful additives.
  • 35 other states have pending bills that also seek to ban certain harmful additives and/or disclosure requirements.
  • California has passed a first-in-the-nation bill to develop a legal definition of UPFs for school food standards.

If an additive is banned, restricted, or labeled abroad or in multiple U.S. states, foods containing it should qualify as UPFs.

Foods engineered for hyperpalatability and addictive eating

UPFs are designed to be eaten quickly, easily, and often unconsciously. Research shows:

  • Combining fat and carbs in a 1:1 calorie ratio hijacks the brain’s reward system.
  • Softer, faster-eaten foods delay satiety and dramatically increase intake.
  • Adults unintentionally eat 500-800 extra calories per day on UPF diets.
  • Some additives may disrupt the gut microbiome and increase cravings.

If a product is formulated to promote overconsumption, it should fall under the UPF definition.

What Should Not Count as UPF

To keep the definition fair and grounded, some food categories should be formally exempt:

  • Raw agricultural commodities
  • Unprocessed locally grown or raised foods
  • Minimally processed items (i.e., cut, canned, dried, pasteurized, etc.)
  • Class 1 milk

Any other exemption must undergo a rigorous two-year scientific review, ensuring no loopholes open up over time.

How a Federal UPF Definition Can Be Used

A strong UPF definition could guide policies that meaningfully improve public health. Some examples:

  • School Lunch Standards

Limit UPFs in school meals and vending; prioritize real, whole food procurement.

  • Front-of-Package Warning Labels

Similar to the 44 countries already doing this, giving consumers clear, fast guidance.

  • Marketing Restrictions to Children

Modeled on Nordic, UK, and Latin American policies that reduced youth exposure to unhealthy foods.

  • Food Additive Oversight

FDA could require safety data for additives used in UPFs, much like other countries already do.

  • Agricultural & Research Funding Priorities

Redirect subsidies and grants toward whole foods, instead of toward commodity crops used for UPFs.

  • State and Federal Consistency

Support states already taking action and prevent patchwork standards.

Why This Matters

The U.S. has one of the highest UPF consumption rates in the world. At the same time:

  • 3 in 4 adults are overweight or obese.
  • 1 in 2 adults and 1 in 4 teenagers have diabetes or prediabetes.
  • Only 7% of adults are metabolically healthy.
  • Diet-related diseases cost the nations hundreds of billions annually.

We cannot fix this without defining the problem.

Establishing a federal UPF definition is the first essential step toward giving Americans, especially children, access to real, whole foods.

FoodFight USA is proud to stand with researchers, parents, physicians, and school leaders in supporting this historic effort. To stay informed with UPF definition updates, future FDA actions, and our work to improve the safety and transparency of America’s food system, subscribe to the FoodFight USA newsletter.

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