How Do You Define Ultra-Processed Food? FDA And USDA Issue RFI To Establish Definition

On July 23, 2025, the U.S. Department of Agriculture (USDA) and Food and Drug Administration (FDA) jointly released a request for information (RFI), to gather information to assist the federal government in establishing a uniform definition for ultra-processed foods (UPFs) for the U.S. food supply. It is estimated that 70% of packaged products in the U.S. food supply are considered ultra-processed and present concerns of numerous adverse health outcomes, including cancer, Type 2 diabetes and neurological disorders. As noted in the RFI, an established definition of UPF would "allow for consistency in research and policy to pave the way for addressing health concerns associated with the consumption of UPFs." The RFI was issued as part of the Trump Administration's broader "Make America Health Again (MAHA)" initiative, including the issuance of the "Make Our Children Healthy Again: Assessment."

Why it Matters:

Currently, there is no universally accepted definition of UPFs either within the U.S. or elsewhere in the world. The most commonly used definition is the "Nova" system developed by Brazilian researchers, which ranks foods into four categories depending on the degree to which the food is processed. As the RFI notes, previous efforts to define UPFs have been challenged due to the need to capture only UPFs that pose risks to health, such as those foods that are high in added sugars, sodium and saturated fats, and to distinguish such foods from ones that are beneficial to health but might still be considered "ultra-processed," like yogurt.

The RFI explains that a primary goal for establishing a uniform definition for UPF in the U.S. is to enable consistency in the research and policy that is key to addressing the known health risks associated with UPFs.

A consistent definition of UPFs could have important short- and long-term implications for the nation's food supply and numerous federal food-related programs. When asked about the UPF RFI in a recent interview, FDA Commissioner Dr. Martin Makary acknowledged that a uniform definition of UPF could have important implications for school lunch programs and USDA's Supplemental Nutrition Assistance Program (SNAP). He noted that "we haven't seen movement on SNAP moving to healthier options" for years and that the existence of "waivers at the state level, a recognition and awareness that sugary drinks and ultra-processed junk food doesn't make sense for taxpayer dollars." While USDA has approved several waivers for states seeking to target the removal of certain foods from SNAP programs, a consistent, federal definition that makes its way into the dietary guidelines—which many federal food programs abide by—would promote widespread change. Notably, Kennedy announced yesterday that the release of the guidelines would be delayed until later this fall.

RFI at a Glance:

The RFI outlines six key areas for public comment:

1. Classification Systems: Input is sought on existing classification systems and their applicability to the U.S. context, including benefits and limitations.
2. Ingredient Labeling: Comments are requested on how ingredient prominence and function (e.g., flavorings, colorings, preservatives) should influence UPF classification.
3. Processing Methods: The RFI explores how physical, biological and chemical processing techniques (e.g., extrusion, fermentation, pH adjustment) may define UPFs.
4. Terminology: Stakeholders are asked whether "ultra-processed" is the most appropriate term or if alternatives would better capture public health concerns.
5. Nutritional and Sensory Attributes: The agencies seek views on incorporating factors like energy density, palatability, and nutrient composition into a UPF definition.
6. Operationalization: The RFI requests ideas on how to systematically apply a UPF classification in food labeling, research, and policy.

Recent Federal Activity Related to UPFs

The RFI is the latest in a series of recent and anticipated actions taken by FDA and USDA in furtherance of the goals of the MAHA Commission. Such actions include:

• Ban on Petroleum-Based Synthetic Dyes and Color Additives: On April 22, 2025, FDA announced a series of actions to phase out all petroleum-based synthetic dyes from the nation's food supply.
• GRAS Reform: On March 10, 2025, HHS Secretary Robert F. Kennedy, Jr. directed FDA to explore rulemaking options to revise the Substances Generally Recognized as Safe (GRAS) Final Rule in an effort to close a "loophole that has allowed new ingredients and chemicals, often with unknown safety data, to be introduced into the U.S. food supply without notification to the FDA or the public."
• Front-of-Package Nutrition Labeling: In May 2025, FDA extended the comment period for a Biden Administration proposed rule on front-of-package (FOP) nutrition labeling which, if finalized, would "require a FOP nutrition label on most packaged foods to provide accessible, at-a-glance information to help consumers quickly and easily identify how foods can be part of a healthy diet."
• FDA-NIH Joint Nutrition Regulatory Science Program: On May 9, 2025, FDA and the National Institutes of Health (NIH) announced a joint research partnerships to better understand UPF impact.
• USDA SNAP Waivers: Since May, USDA has approved six state waivers amending the statutory definition of food for purchase in SNAP, allowing states to impose restrictions on certain UPFs.
• USDA Partnership with Farmers: USDA has stated its intention to work with farmers as part of the solution to eliminating UPFs.

FDA/USDA will accept comments on the UPF RFI until September 23, 2025.

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