FDA and USDA kick off an effort to define ultra-processed foods

The U.S. government has begun the process of figuring out what, exactly, ultra-processed foods are — the first step toward potentially doing something about them.


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Happy Friday, and welcome to Food Fix. I had a hard time settling on the topic for today’s newsletter because there is so much going on. Agriculture Secretary Brooke Rollins announced Thursday that USDA staff would be largely moving out of DC, a move that shakes up and likely shrinks that department. Also, advocates within the “Make America Healthy Again” movement are reeling after House Republicans advanced a bill that would grant pesticide companies sweeping liability protection. Today, however, we’re going to dive into something else cooking: the U.S. government’s first attempt to define ultra-processed foods.

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FDA and USDA kick off an effort to define ultra-processed foods

The federal government is setting out to do something it’s never done: Come up with a definition for ultra-processed foods (UPFs). 

The FDA and USDA on Thursday announced a joint Request for Information (RFI) to “gather information and data to help establish a federally recognized uniform definition” for UPFs, calling it “a critical step in providing increased transparency to consumers about the foods they eat.” (Btw, Food Fix was first to report this was going to happen back in June.)

“Ultra-processed foods are driving our chronic disease epidemic,” said HHS Secretary Robert F. Kennedy Jr. “We must act boldly to eliminate the root causes of chronic illness and improve the health of our food supply. Defining ultra-processed foods with a clear, uniform standard will empower us even more to Make America Healthy Again.”

Now this all may sound a bit strange to someone not steeped in food and nutrition policy: How do we not have a definition for ultra-processed foods? They now make up the majority of the American diet, and we hear constantly about how they’re associated with numerous poor health outcomes.

It’s a bit more complicated than it seems at first blush. I think most people would agree that flavored chips, brightly colored cereals and many frozen meals would qualify as ultra-processed — like you’d know a UPF if you saw one. But it gets murky quickly: What about whole-wheat bread? Flavored yogurt? Pickles? Are they all ultra-processed, and should they be avoided? Are some UPFs healthy? Is it more about their nutrient profile? Is it the level of processing? Are there certain ingredients that are driving poor outcomes more than others? These are all key questions as the government begins this process. 

Harder than it seems: Figuring out how to draw lines around UPFs is not easy, but it matters if the federal government or state governments are going to seek policies to reduce their consumption. (California has already started down this path as the state legislature looks to restrict certain ultra-processed foods in school meals, for example.)

The nutrition world has been in a raging debate about how to define UPFs for some time. Much of the research uses what’s known as the Nova classification system, which was created by leading researchers in Brazil. (Here’s a good breakdown of the various levels of processing, if you’re interested in reading more.)

Nova defines UPFs as: Industrially manufactured food products made up of several ingredients (formulations) including sugar, oils, fats and salt (generally in combination and in higher amounts than in processed foods) and food substances of no or rare culinary use (such as high-fructose corn syrup, hydrogenated oils, modified starches and protein isolates).

While the Nova classification system is the most widely used, a lot of people (and particularly the food industry) really do not like it. Critics argue that it oversimplifies things by focusing on the degree of processing rather than the nutritional value of the food. Some also worry it demonizes entire categories of foods that may be health-promoting (yogurt is often brought up as an example).

“If we come up with a good definition, there could be a lot of implications of having that definition,” FDA Commissioner Marty Makary told Politico’s Dasha Burns, who noted the definition could impact what’s offered in school meals and the Supplemental Nutrition Assistance Program eventually. 

“Now maybe we won’t get it right on the first definition — because there’s no perfect definition,” Makary said. “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.’”

Reading the tea leaves: The move to try to define UPFs indicates a serious step toward potentially cracking down on them, but there are still a lot of questions here: How long will this process take? Will it get bogged down in relentless lobbying? Once the government has a definition, what does it do with it? 

Federal levers: I feel like a broken record here, but we’re still very much waiting to see what the MAHA policy agenda is going to be at the federal level (aside from GRAS reform). We know what the vibes are: RFK Jr. is constantly saying we are all being “poisoned” by UPFs, HHS is seeking a multi-million dollar PR campaign against them and the forthcoming dietary guidelines are expected to urge us to consume less of them. But the government has many levers that could be used here. RFK Jr. also likes to compare Big Food to Big Tobacco, which the federal government eventually did bring down the hammer on (and dramatically reduced smoking).

We know what the MAHA agenda is from the states: States are seeking additive bans and warning labels, and they’re cracking down on what ingredients can be in school meals. What this all might look like at the federal level remains to be seen. I’m anxiously awaiting to see what’s in this MAHA Commission recommendations report next month. 

Bad vibes: In the meantime, we still have a lot of bad vibes against UPFs coming from this administration. On Thursday, the official HHS X account posted a video of Hulk Hogan body slamming another pro-wrestler, André the Giant. Hogan, who died this week, was labeled “MAHA” and André the Giant was labeled “ultra processed foods.” 

“HHS is giving ultra-processed foods a BIG leg drop this summer,” the post said.

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What I’m reading

Cooperation is the key to MAHA (Wall Street Journal). “The Food and Drug Administration and the Consumer Brands Association have reached an agreement to phase artificial colors out of the food and beverage industry by the end of 2027. Kraft Heinz, WK Kellogg, General Mills, J.M. Smucker, Hershey and Nestlé have already made the same public commitments in recent weeks. Sunsetting the ultra-processed food staple didn’t happen because the FDA went on a regulatory spree—instead the agency used its convening authority,” write FDA Commissioner Marty Makary and CMS Administrator Mehmet Oz. “As we continue our work to Make America Healthy Again, we are seeing areas where our regulatory authorities are a blunt instrument that should be held in reserve. We can better serve the public by using our convening power to drive meaningful change that is nimble, durable and faster. We not only reserve our right, but remain committed, to use our regulatory authority to ensure that change endures.”

SNAP incentives can change behavior and lives (Agri-Pulse). “While SNAP restrictions on ‘unhealthy’ foods have received all the headlines in the quest for better health outcomes on a modest $6-per-day benefit, SNAP incentives of nutrient-dense foods offer much greater returns on investment for American taxpayers and shoppers,” write Michael Dykes, Greg Ferrara, Cathy Burns and Leslie Sarasin in an opinion piece. “The justification for incentives is straightforward: SNAP incentives are proven to change behavior for the better. Elected officials in Washington continue to focus on making SNAP more efficient, less prone to fraud and waste, and an instrument to encourage work, self-sufficiency and healthier eating—something we can all agree is in the public interest. In this climate, SNAP incentives offer a powerful and practical solution. Rather than simply imposing restrictions, incentives can foster long-term behavioral changes, promote a culture of healthy eating and support the American farmer. And by collaborating with leaders of the MAHA movement, members of Congress, leaders in the Trump administration, and the private sector, we can ensure these programs contribute to a healthier America.”

Doctors are biased against higher-weight patients. Can nutrition education help them change? (STAT). “Everyone agrees that diet is important to good health. And yet fewer than a third of medical students receive the recommended minimum of 25 hours of nutrition education, and more than half report receiving no formal education on the topic at all,” writes Sarah Todd. “That’s why health secretary Robert F. Kennedy Jr. may be pushing on an open door with his plans to require medical schools to include nutrition education in their curricula or else lose federal funding. Many nutrition and food policy experts have been calling for this kind of change for years. A 2022 House of Representatives resolution on the need for better nutrition education also won bipartisan support. And some medical schools have already taken steps to strengthen their offerings on the subject.”

No, there’s no such thing as ‘natural Ozempic’ (Seattle Times). “I receive a lot of emails from so-called ‘media insight’ companies offering me use of a pre-written article if I include a link to the writer’s product website. A few weeks ago, I received one with the subject line, ‘I am an expert nutritionist, and these grocery items work like Ozempic.’ I needed to write about it,” Carrie Dennett says. “First, no food can act as a replacement for a pharmaceutical drug. Second, if a dietary supplement did have the same actions as a pharmaceutical drug, it would have to be regulated like one. Promoting the idea that certain foods or supplements can act like these pharmaceutical drugs could falsely suggest that someone with type 2 diabetes doesn’t need to take medication if they just eat the ‘right’ food. Many people have lost weight on the higher doses prescribed for weight loss. Peanut butter and quinoa won’t help with that.” 

Canada to re-implement temporary import requirements for US romaine for fall 2025. (GAIN) “Beginning September 25, 2025, Canada will once again require additional import requirements for U.S. origin romaine lettuce. These temporary requirements will be in effect until December 17, 2025. During this time, the conditions for import of U.S. leafy greens will require that any imported romaine lettuce and/or salad mixes containing romaine lettuce must contain either a Proof of Origin that the romaine lettuce was grown outside the Salinas Valley counties of Santa Clara, Santa Cruz, San Benito, or Monterey, or conduct CFIA approved sampling and testing with a negative E. coli result. Any California-grown romaine lettuce exported to Canada must be handled by a certified member of the California Leafy Greens Marketing Agreement. Any Arizona-grown romaine lettuce exported to Canada must be handled by a certified member of the Arizona Leafy Greens Marketing Agreement.”

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