FDA and USDA Launch Joint Effort to Create Federal Definition for 'Ultra-Processed Foods'
The FDA and USDA have unveiled a proposed regulatory framework to legally define ultra-processed foods, targeting products that combine industrial additives with poor nutrient profiles. The definition will serve as the foundation for future front-of-package warning labels and school lunch restrictions.
By Factlen Editorial Team
- Public Health Advocates
- Argue that strict, legally binding definitions are necessary to curb the chronic disease epidemic and force manufacturers to reformulate products.
- Food Manufacturers
- Contend that the proposed definition demonizes safe, FDA-approved ingredients essential for shelf life, affordability, and food security.
- Nutrition Scientists
- Focus on the biological mechanisms, debating whether physical processing inherently harms health or if UPFs are simply vehicles for poor macronutrients.
What's not represented
- · Low-income consumers reliant on shelf-stable foods
- · Public school cafeteria administrators
Why this matters
This federal definition will fundamentally reshape the $1 trillion U.S. food industry by dictating which products receive mandatory warning labels and which are allowed in public schools. For consumers, it marks a historic shift from tracking individual nutrients to evaluating how heavily their food is industrially engineered.
Key points
- The FDA and USDA have proposed a legally binding federal definition for ultra-processed foods (UPFs).
- The framework uses a two-prong test requiring both an industrial additive and a poor nutrient profile.
- The definition will trigger mandatory front-of-package warning labels and restrict items in school lunches.
- Food manufacturers warn the rules will raise grocery prices and increase food waste by demonizing safe preservatives.
- Public health advocates argue the nutrient thresholds contain loopholes that will allow companies to simply reformulate products.
The U.S. Food and Drug Administration (FDA) and the Department of Agriculture (USDA) have officially launched a joint regulatory effort to establish the first legally binding federal definition of "ultra-processed foods" (UPFs).[1]
The proposed framework, unveiled Monday, marks a historic shift in American nutrition policy. For decades, federal guidelines focused primarily on individual nutrients—advising Americans to limit sodium, sugar, and saturated fat. Now, regulators are targeting the industrial manufacturing processes themselves.[2][5]
The stakes are massive. An estimated 70% of packaged products in the U.S. food supply currently fall under the colloquial umbrella of ultra-processed foods. Furthermore, these highly engineered products account for more than 60% of the daily calories consumed by American children.[1]
Establishing a uniform definition is the critical first step in a broader regulatory cascade. Once codified, this definition will serve as the legal foundation for mandatory front-of-package warning labels and will dictate which products are eligible for the $20 billion National School Lunch Program.[4]

The push for a federal standard follows a year of intense information gathering. In July 2025, the agencies issued a joint Request for Information (RFI) to evaluate how to classify these foods. The resulting framework heavily reflects the broader agenda to combat diet-related chronic diseases championed by federal health officials.[1]
But defining "ultra-processed" in a legally enforceable way is notoriously difficult. Until now, global researchers have largely relied on the "NOVA" classification system, developed by Brazilian scientists in 2009.[3][5]
NOVA categorizes foods into four groups based on the extent of their physical and chemical alteration. Group 4, the ultra-processed category, is defined broadly as industrial formulations made with substances extracted from foods and cosmetic additives designed to enhance palatability.[3]
However, U.S. regulators concluded that NOVA is too ambiguous for federal rulemaking. Critics argue that NOVA groups nutritionally distinct items—like artificially sweetened zero-calorie yogurt and deep-fried cheese snacks—into the same high-risk category simply because both contain industrial emulsifiers or flavorings.[2][3]
regulators concluded that NOVA is too ambiguous for federal rulemaking.
To solve this, the FDA and USDA have proposed a novel "two-prong" matrix, heavily inspired by California's landmark AB 1264 legislation passed in late 2025, which banned certain UPFs from state public schools.[4]
Under the proposed federal mechanism, a product is legally classified as a UPF only if it meets two distinct conditions. First, it must contain at least one industrial additive with a defined technical effect—such as artificial colors, non-nutritive sweeteners, emulsifiers, or modified starches that are rarely used in home kitchens.

Second, the product must cross a specific nutritional threshold. This includes deriving more than 10% of its total calories from saturated fat, containing a 1:1 ratio of milligrams of sodium to calories, or exceeding strict limits on added sugars.
This hybrid approach attempts to bridge a fierce debate within the scientific community regarding the true danger of UPFs: Are they harmful because the physical processing destroys the "food matrix," or simply because they are highly palatable vehicles for empty calories?[2][3]
By requiring both an industrial additive and a poor nutrient profile, the agencies are targeting foods that are engineered to be hyper-palatable and easily overconsumed, while sparing minimally processed items that happen to use a preservative for safety.[2][5]
The food industry has mounted a swift defense against the proposal. Trade groups representing major manufacturers argue that the definition demonizes safe, FDA-approved ingredients that are essential for food safety, shelf life, and affordability.[4]
Industry lobbyists warn that stripping emulsifiers and preservatives from the supply chain could drastically increase food waste and raise grocery prices for low-income families who rely on shelf-stable products. They also point out that many fortified foods, including certain infant formulas and plant-based meat alternatives, could be inadvertently caught in the UPF net.[4]

Conversely, public health advocates argue the two-prong test includes too many loopholes. Some researchers warn that manufacturers will simply reformulate their products to sit just below the sodium or sugar thresholds, allowing them to keep using cheap industrial additives while dodging the UPF label entirely.[2][5]
The uncertainty surrounding the exact health mechanisms of UPFs remains a sticking point. While observational studies consistently link high UPF consumption to cardiovascular disease, obesity, and type 2 diabetes, randomized controlled trials isolating the exact biological cause are still ongoing.[2][3]
To address these gaps, the FDA and the National Institutes of Health (NIH) are currently funding a joint Nutrition Regulatory Science Program to study the metabolic effects of specific food processing techniques and how they alter human digestion.
How we got here
2009
Brazilian researchers introduce the NOVA classification system, coining the term 'ultra-processed foods'.
July 2025
The FDA and USDA issue a joint Request for Information to gather public and scientific input on defining UPFs.
October 2025
California passes AB 1264, becoming the first U.S. state to legally define and restrict UPFs in public schools.
January 2026
The 2025-2030 Dietary Guidelines for Americans are released, explicitly advising a dramatic reduction in highly processed foods.
July 2026
The FDA and USDA officially launch the proposed regulatory framework to establish a uniform federal definition for UPFs.
Viewpoints in depth
Public Health Advocates
Pushing for strict regulations to combat diet-related chronic diseases.
Public health organizations argue that the American food supply has been fundamentally altered by industrial engineering, creating hyper-palatable products that bypass the body's natural satiety signals. They view the two-prong federal definition as a necessary first step to mandate front-of-package warning labels and remove these items from school cafeterias. However, some advocates worry the nutrient-threshold loophole will allow companies to simply swap out sugar for artificial sweeteners to dodge the UPF classification, rather than returning to whole-food ingredients.
Food Manufacturers & Trade Groups
Defending the role of food processing in safety, affordability, and scale.
Industry representatives argue that the term 'ultra-processed' is scientifically meaningless and unfairly demonizes safe, FDA-approved ingredients. They emphasize that emulsifiers, preservatives, and modified starches are critical for preventing foodborne illness, extending shelf life, and keeping grocery prices low. Trade groups warn that stripping these ingredients from the supply chain could drastically increase food waste and disproportionately harm low-income families who rely on affordable, shelf-stable products.
Nutrition Scientists
Investigating the exact biological mechanisms linking UPFs to poor health.
While observational data strongly links high UPF diets to obesity and cardiovascular disease, researchers remain divided on the exact biological cause. One camp argues that extreme physical processing destroys the 'food matrix'—the physical structure of the food—causing it to be absorbed too quickly and disrupting the gut microbiome. Another camp suggests the processing itself is a red herring, arguing that UPFs are harmful simply because they are dense in calories, sodium, and sugar, and lack essential fiber.
What we don't know
- Whether the physical processing of food or its poor nutrient profile is the primary driver of negative health outcomes.
- How quickly the food industry will reformulate products to dodge the new UPF thresholds.
- Whether the final rule will include exemptions for fortified foods like infant formula and plant-based meats.
Key terms
- Ultra-Processed Food (UPF)
- Industrial formulations of food that contain additives rarely used in home kitchens, engineered for hyper-palatability and long shelf life.
- NOVA Classification
- A globally recognized four-tier system developed in Brazil that categorizes food based on the extent and purpose of its physical and chemical processing.
- Food Matrix
- The complex physical and chemical structure of a whole food, which dictates how its nutrients are digested and absorbed by the body.
- Emulsifier
- A food additive used to stabilize processed foods by preventing ingredients like oil and water from separating.
- Technical Effect
- The specific functional purpose an additive serves in a food product, such as preserving freshness, enhancing flavor, or modifying texture.
Frequently asked
What exactly is an ultra-processed food?
Under the proposed federal definition, it is a product that contains both an industrial additive (like artificial colors or emulsifiers) and high levels of sodium, saturated fat, or added sugar.
Will ultra-processed foods be banned?
No. The federal definition will not ban these foods from grocery stores, but it will likely trigger mandatory front-of-package warning labels and restrict their use in federal programs like the National School Lunch Program.
Why is the government doing this now?
The effort is part of a broader initiative to combat diet-related chronic diseases, driven by data showing that 70% of the U.S. packaged food supply is ultra-processed and linked to rising rates of obesity and diabetes.
How does this differ from the NOVA classification?
The widely used NOVA system categorizes foods based purely on the extent of their processing. The new U.S. proposal adds a nutritional threshold, meaning a processed food must also have a poor nutrient profile to be labeled a UPF.
Sources
[1]ReutersNutrition Scientists
FDA, USDA launch joint effort to define ultra-processed foods, targeting 70% of grocery items
Read on Reuters →[2]STAT NewsNutrition Scientists
STAT+: One California politician’s unexpected crusade against ultra-processed food
Read on STAT News →[3]American Journal of Public HealthPublic Health Advocates
Evaluating the Shift from NOVA to Nutrient-Additive Matrices in US Policy
Read on American Journal of Public Health →[4]The Wall Street JournalFood Manufacturers
Food Industry Braces for New Federal Rules on Ultra-Processed Foods
Read on The Wall Street Journal →[5]NPRPublic Health Advocates
As U.S. government looks to leverage food aid, producers seek other delivery methods
Read on NPR →
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