Strengths: Widely validated in research, internationally recognized
Weaknesses: Subjective criteria, treats all UPFs equally
FDA Ultra-Processed Food Definition: Current Status
The FDA has no official definition of ultra-processed food. Here is where things stand, what the FDA/USDA Request for Information means, and why establishing a federal definition is more complicated than it sounds.
8 min read-Policy-Federal Regulation
Information current as of February 2026
Federal rulemaking evolves over time. Check the FDA and USDA websites for the latest developments on ultra-processed food policy.
The FDA Has No Official Definition of Ultra-Processed Food
Despite growing scientific consensus that ultra-processed foods are associated with negative health outcomes, the United States Food and Drug Administration has never established an official definition of the term. As of February 2026, "ultra-processed food" has no legal or regulatory meaning under federal law.
This means that food manufacturers face no restrictions on using terms like "minimally processed" or "made with simple ingredients" on packaging. There is no federal standard governing what counts as ultra-processed, no required disclosure of processing level, and no regulatory framework for distinguishing between a product with three ingredients and one with thirty industrial additives.
The absence of a definition has practical consequences. Federal nutrition programs like SNAP and WIC cannot restrict purchases based on processing level because there is nothing to measure against. School meal programs lack a standard for evaluating whether products meet processing thresholds. And consumers have no government-backed system for understanding how their food was manufactured.
0
federal definitions of "ultra-processed food" in U.S. law
~60%
of American calories come from ultra-processed food
2025
year the FDA/USDA issued its first RFI on UPF definitions
The FDA/USDA Request for Information
In 2025, the FDA and USDA jointly issued a Request for Information (RFI) seeking public input on how to define ultra-processed food for federal regulatory purposes. This was the first formal acknowledgment by U.S. regulatory agencies that food processing level may warrant official classification.
The RFI was prompted in part by recommendations from the MAHA commission, which called on federal agencies to develop a standardized definition as a foundation for labeling, dietary guidance, and food program reform. The RFI asked for comment on several key questions: whether the NOVA classification system is appropriate for regulatory use, how borderline cases should be handled, whether a binary or tiered classification would be more practical, and what evidence links processing level to health outcomes.
Thousands of comments were submitted during the public comment period from researchers, food industry groups, registered dietitians, consumer advocates, and individual citizens. The agencies are currently reviewing these submissions. No timeline has been announced for next steps.
Important: An RFI Is Not a Proposed Rule
A Request for Information is one of the earliest stages of the federal regulatory process. It gathers input before any formal action is proposed. Many RFIs lead to further study or voluntary guidance rather than binding regulation. Even if the FDA and USDA proceed toward a formal definition, the rulemaking process typically takes several years and involves multiple rounds of public comment, legal review, and potential congressional oversight.
Why Defining Ultra-Processed Food at the Federal Level Matters
A standardized federal definition would unlock several policy levers that are currently unavailable. Without an agreed-upon definition, agencies cannot set thresholds, enforce standards, or measure progress. Here are the areas where a definition would have the most immediate impact.
Food Labeling and Consumer Transparency
Current nutrition labels focus on individual nutrients -- calories, fat, sodium, sugar -- but say nothing about the degree of industrial processing a product has undergone. A federal definition could enable front-of-package labels that communicate processing level, similar to warning labels implemented in Chile and Mexico. This would help consumers make informed decisions when reading food labels at the grocery store.
Dietary Guidelines for Americans
The Dietary Guidelines for Americans, updated every five years, currently do not address food processing as a category. A federal definition would allow the Dietary Guidelines Advisory Committee to make specific recommendations about processing levels, just as they currently make recommendations about sodium, added sugars, and saturated fat.
SNAP and WIC Program Reform
SNAP currently places almost no restrictions on which foods participants can purchase. A federal UPF definition could enable either restrictions on the most highly processed products or incentive structures that make minimally processed foods more affordable within these programs, as some state-level legislation has already proposed.
School Meal Programs
Federally funded school meal programs serve millions of children daily. A definition would provide the legal basis for setting processing-level standards in these programs, building on the approach pioneered by California's AB 1264, which phases out ultra-processed food in school cafeterias.
What a Federal Definition Could Look Like
The RFI specifically asked for input on the framework a federal definition should follow. Three broad approaches have emerged from the public comments and academic literature.
NOVA-Based Approach
Adopt or adapt the NOVA classification directly. Products would be classified into four groups based on the extent and purpose of industrial processing.
Ingredient-Based Approach
Define ultra-processed food by the presence of specific industrial ingredients: artificial colors, flavors, emulsifiers, hydrogenated oils, high-fructose corn syrup, and similar additives not used in home cooking.
Strengths: Objectively measurable, enforceable
Weaknesses: Requires maintaining an ingredient list, may miss novel additives
Hybrid / Tiered Approach
Combine processing assessment with nutritional evaluation, similar to the AHA three-tier system. Products would be classified on a spectrum rather than receiving a binary label.
Strengths: More nuanced, distinguishes between UPF types
Weaknesses: More complex to implement and communicate
Our Approach
The Processing Score used on this site follows the ingredient-based approach. It assigns a numeric score based on the presence of specific industrial additives, the total number of ingredients, and the types of processing indicators found in each product. This produces a continuous scale rather than a binary classification, giving consumers more granular information about where a product falls on the processing spectrum.
Why Defining Ultra-Processed Food Is Harder Than It Sounds
The concept of ultra-processed food is intuitively clear to most people -- everyone recognizes the difference between an apple and a brightly colored fruit snack. But translating that intuition into a precise, legally enforceable definition raises several difficult questions.
NOVA Classification Is Not Always Clear-Cut
The NOVA system classifies foods based on the "extent and purpose" of industrial processing, but these criteria involve judgment calls. Is store-bought hummus with added citric acid ultra-processed? What about canned beans with calcium disodium EDTA as a preservative? Researchers using NOVA frequently disagree on borderline cases, which is problematic for a regulatory framework that must be applied consistently across millions of products.
Some Ultra-Processed Foods Are Nutritionally Beneficial
Fortified whole-grain breads, plant-based milks with added calcium and vitamin D, and iron-fortified cereals all qualify as ultra-processed under NOVA. Yet for millions of Americans -- particularly those in food deserts or on limited budgets -- these products are important sources of essential nutrients. A definition that treats these products the same as candy and soda risks discouraging consumption of foods that genuinely improve diet quality, a concern highlighted by the AHA's three-tier classification.
Industry Uses Different Definitions
Food manufacturers, trade associations, and industry-funded research groups have proposed their own definitions of ultra-processed food, some of which are significantly narrower than NOVA. The International Food Information Council, for example, has argued that processing level should be evaluated alongside nutritional content rather than as an independent criterion. Any federal definition will face intense lobbying and potential legal challenges from industry groups with competing frameworks.
Enforcement Complexity
Unlike nutrient content, which can be measured in a laboratory, processing level is determined by manufacturing methods that may not be visible in the final product. Verifying that a product meets or exceeds a processing-level threshold would require the FDA to audit manufacturing processes, review supply chains, and develop entirely new inspection protocols -- a significant expansion of the agency's current regulatory capacity.
Timeline of U.S. Federal Actions
2014
Brazil Adopts NOVA in Dietary Guidelines
Brazil becomes the first country to incorporate the NOVA classification into official dietary recommendations, advising citizens to avoid ultra-processed foods.
2020
Dietary Guidelines Committee Acknowledges UPF Research
The U.S. Dietary Guidelines Advisory Committee notes the growing body of research on ultra-processed food but declines to make processing-based recommendations due to lack of a standardized definition.
2025 Q1
MAHA Commission Recommends Federal Definition
The Make America Healthy Again commission formally recommends that the FDA and USDA develop a standardized federal definition of ultra-processed food.
2025 Q3
FDA/USDA Issue Request for Information
The agencies jointly publish an RFI seeking public comment on how to define ultra-processed food for regulatory purposes -- the first formal step toward a potential federal definition.
2025 Q4
Public Comment Period Closes
Thousands of submissions are received. The agencies begin internal review with no announced timeline for next steps.
2026 Q1
Review Ongoing -- No Definition Yet
The FDA and USDA continue reviewing RFI comments. No proposed definition, voluntary guidance, or formal rulemaking has been announced.
How Other Countries Handle UPF Definitions
While no country has established a legally binding regulatory definition of ultra-processed food, several have incorporated processing-based frameworks into public health policy.
Brazil
Pioneer of the NOVA-based approach. Brazil's 2014 dietary guidelines explicitly advise avoiding ultra-processed foods. The framework has influenced public health campaigns, school meal policies, and food marketing restrictions. Several other Latin American countries have followed Brazil's lead.
European Union
The EU has funded extensive research into ultra-processed food through its Joint Research Centre. France's Nutri-Score label incorporates some processing indicators alongside nutritional criteria. The European Food Safety Authority has reviewed the evidence but has not recommended a formal definition.
United Kingdom
The UK Scientific Advisory Committee on Nutrition commissioned a review of ultra-processed food evidence in 2023. The UK government has indicated interest in processing-based policy but has not adopted an official definition. The UK's existing traffic-light labeling system focuses on nutrients rather than processing level.
What This Means for Consumers Right Now
The lack of a federal definition does not leave consumers without options. While government action may take years, the tools for evaluating your own food choices are available today.
Read Ingredient Lists, Not Just Nutrition Labels
Nutrition facts panels tell you about calories and macronutrients but reveal nothing about processing. The ingredient list is where you will find industrial additives like artificial colors, flavors, emulsifiers, and preservatives. Our ingredients-to-avoid guide identifies the most common markers of ultra-processing.
Use Available Tools and Databases
Our database of nearly 2 million products includes Processing Scores that classify foods on a continuous spectrum from minimally processed to ultra-processed. This provides the kind of product-level transparency that a federal definition would eventually enable, available to you right now.
Focus on the Big Wins
You do not need a federal definition to make meaningful changes. Reducing consumption of the most heavily processed products -- sugar-sweetened beverages, processed meats, and industrial snack foods -- offers the clearest health benefits regardless of how the FDA eventually draws the line.
The Bottom Line
A federal definition of ultra-processed food would be a significant milestone for U.S. food policy. But the absence of one does not prevent you from making informed choices. The science on ultra-processing is clear enough to act on, even while the regulatory framework catches up. Use ingredient lists, processing scores, and common sense as your guides while the FDA deliberates.
Frequently Asked Questions
Does the FDA currently define ultra-processed food?
No. As of February 2026, the FDA has no official definition of "ultra-processed food." The term has no legal or regulatory meaning in the United States. The FDA regulates food labeling through defined terms like "organic," "natural," and nutrition claims, but processing level has never been part of its regulatory vocabulary. The FDA/USDA Request for Information issued in 2025 is the first formal step toward potentially establishing such a definition.
What is the FDA/USDA Request for Information on ultra-processed food?
The Request for Information (RFI) is a formal solicitation of public comment published jointly by the FDA and USDA in 2025. It asks researchers, food manufacturers, consumer groups, and the public to weigh in on how ultra-processed food should be defined for federal purposes, whether the NOVA classification is an appropriate framework, and what scientific evidence links processing level to health outcomes. An RFI is not a proposed rule -- it is an information-gathering step that may or may not lead to regulation.
Why is it so difficult to define ultra-processed food for regulatory purposes?
Several factors make a federal definition challenging. The NOVA classification, which is the most widely used research framework, relies on subjective judgments about the "purpose" of processing rather than measurable criteria. Borderline cases abound: a fortified whole-grain cereal and a candy bar are both classified as ultra-processed under NOVA, despite vastly different nutritional profiles. Any regulatory definition must be specific enough to enforce consistently, broad enough to capture genuinely problematic products, and defensible against legal challenges from the food industry.
How do other countries define ultra-processed food?
Brazil incorporated the NOVA framework into its national dietary guidelines in 2014, advising citizens to avoid ultra-processed foods. Several Latin American countries have followed suit. The European Union has funded research into processing-based classification but has not adopted an official definition. The United Kingdom has commissioned studies on UPF consumption patterns. No country has yet established a legally binding regulatory definition of ultra-processed food for labeling or food program purposes, though several use NOVA as a policy guidance tool.
What should consumers do while waiting for a federal definition?
Consumers do not need to wait for government action to make informed choices. Reading ingredient lists remains the most practical tool: products with long lists of unfamiliar additives, artificial colors, flavors, and preservatives are generally more heavily processed. Resources like our Processing Score and ingredient database can help identify where specific products fall on the processing spectrum. Focus on whole and minimally processed foods as the foundation of your diet, and use ultra-processed products selectively rather than as dietary staples.
Continue Learning
MAHA Report on UPF →
How the federal MAHA commission is approaching ultra-processed food policy and the recommendations that prompted the FDA/USDA RFI
NOVA Food Classification →
Understand the four-group NOVA system that most UPF research is built on and how it classifies all foods by processing level
What Are Ultra-Processed Foods? →
The science behind ultra-processing, what makes a food ultra-processed, and why it matters for your health
Disclaimer: All tools and data visualizations are provided for educational and informational purposes only. They are not intended as health, medical, or dietary advice. Product formulations change frequently — always check the actual label for current ingredients and nutrition facts before making purchasing decisions. Consult healthcare professionals for personalized dietary guidance.