States Addressing Ultra-Processed Food: A Legislative Tracker
A growing number of U.S. states are introducing legislation that targets ultra-processed food through school meal standards, labeling proposals, public health studies, and food program reforms. This tracker follows where those efforts stand.
Information current as of February 2026
Legislative developments change frequently. Check official state legislature websites for the latest bill status and text.
A New Wave of State-Level Interest in Ultra-Processed Food
For decades, food policy in the United States has focused almost exclusively on nutrients -- calories, sodium, fat, sugar. State and federal regulations set thresholds for what schools can serve, what labels must disclose, and what qualifies as "healthy." The question of how a food is manufactured -- the degree of industrial processing involved -- has largely been absent from the regulatory conversation.
That is changing. Since 2024, a growing number of state legislatures have introduced bills, resolutions, and study commissions that explicitly reference ultra-processed food, the NOVA classification system, or the concept of food processing level as a regulatory criterion. The triggers vary by state -- rising childhood obesity rates, growing public awareness driven by media coverage and books like Ultra-Processed People, and the precedent set by California's AB 1264 -- but the direction is consistent: legislators are beginning to treat processing level as a factor worth addressing in food policy.
These efforts remain in early stages in most states. California is the only state to have enacted a law, and even its implementation timeline extends to 2035. Elsewhere, proposals range from study commissions and labeling pilot programs to school meal standards and resolutions urging federal action. The landscape is fragmented but active, and the trajectory suggests that more states will engage with these questions in the coming legislative sessions.
12+
states with introduced or proposed UPF-related measures
1
state with enacted legislation (California)
4
primary legislative approaches being pursued
State-by-State Legislative Tracker
The following table tracks states that have introduced or enacted legislation, resolutions, or formal study efforts related to ultra-processed food. Status reflects the most recent publicly available information as of February 2026.
| State | Bill / Initiative | Focus Area | Status | Last Updated |
|---|---|---|---|---|
| California | AB 1264 (Real Food Healthy Kids Act) | School meal standards | Enacted | Jan 2026 |
| Arizona | HB 2387 (Healthy School Foods Act) | School meal restrictions | In Committee | Feb 2026 |
| Pennsylvania | SB 812 (Food Transparency Act) | Processing-level labeling | In Committee | Jan 2026 |
| Massachusetts | H. 3201 (School Nutrition Modernization Act) | School nutrition standards | In Committee | Dec 2025 |
| Florida | SB 1045 (Childhood Nutrition Protection Act) | School meals and vending | Introduced | Jan 2026 |
| Louisiana | SCR 48 (Ultra-Processed Food Study Commission) | Public health study | Adopted | Nov 2025 |
| New York | A. 4512 (Processed Food Disclosure Act) | Labeling requirements | Introduced | Feb 2026 |
| Illinois | HB 1187 (School Food Modernization Act) | School meal standards | Introduced | Jan 2026 |
| Oregon | SB 355 (Food Processing Transparency Act) | Labeling pilot program | In Committee | Feb 2026 |
| Colorado | HJR 26-1003 (Diet and Chronic Disease Study) | Public health study | Introduced | Jan 2026 |
| Washington | HB 1694 (Healthy School Meals Act) | School meal standards | Introduced | Feb 2026 |
| Minnesota | SF 892 (Food Program Reform Study) | SNAP/food program reform | Introduced | Jan 2026 |
About This Tracker
This table reflects publicly available information from state legislature databases, media reports, and policy tracking services. Bill numbers and titles are included where available. "In Committee" indicates a bill has been assigned to a legislative committee for review. "Introduced" means a bill has been filed but not yet assigned or heard. Statuses can change rapidly during active legislative sessions.
Four Types of Legislative Approaches
State proposals addressing ultra-processed food generally fall into four categories. Understanding these approaches provides context for evaluating what each bill would actually do if enacted.
1. School Meal Standards
The most common approach. These bills restrict or phase out ultra-processed foods from school cafeterias, often modeled on California's AB 1264. They typically target the National School Lunch Program and School Breakfast Program, requiring schools to meet processing-level criteria in addition to existing USDA nutritional standards.
States: California (enacted), Arizona, Massachusetts, Florida, Illinois, Washington
2. Labeling Requirements
These proposals would require food products sold in the state to carry labels indicating their processing level or disclosing specific industrial additives. Labeling bills face significant legal questions about federal preemption, since the FDA governs food labeling nationally. Some states have structured their proposals as voluntary pilot programs to avoid preemption challenges.
States: Pennsylvania, New York, Oregon
3. Public Health Studies
Rather than imposing requirements directly, some states are creating study commissions or directing health departments to investigate the connection between ultra-processed food consumption and chronic disease rates within their population. These studies often serve as precursors to substantive legislation in future sessions.
States: Louisiana (adopted), Colorado
4. SNAP/Food Program Reforms
A smaller number of states have introduced measures related to food assistance programs. Because SNAP is federally administered, state action is typically limited to resolutions urging Congress to study UPF-related reforms or to creating state-funded incentive programs that complement SNAP benefits for purchases of minimally processed foods.
States: Minnesota
These categories are not mutually exclusive. A state may pursue multiple approaches simultaneously, and bills sometimes combine elements -- for example, a school meal bill that also directs the state health department to conduct a study on the health effects of ultra-processed food consumption among children.
Common Themes Across State Proposals
Despite differences in scope and approach, several patterns emerge from the legislation introduced across states. These themes reflect the shared concerns driving state-level interest in ultra-processed food policy.
Children Are the Primary Focus
The majority of introduced bills target school meals or children's nutrition specifically. Legislators appear to view children as a population with less agency over food choices and greater vulnerability to long-term health effects. School meal programs also represent a setting where the state has direct procurement authority, making regulation more straightforward than restricting retail food sales.
NOVA Is the Default Framework
Nearly every bill that defines ultra-processed food references the NOVA classification system or its Group 4 category. Some proposals reference NOVA directly in the bill text, while others direct regulatory agencies to develop definitions "consistent with" or "based on" NOVA. This de facto standardization around a single classification framework could simplify future coordination between states and any eventual federal definition.
Phased Timelines Are Standard
Following California's model, most school meal proposals include multi-year implementation timelines that give districts, food service providers, and manufacturers time to adapt. This phased approach addresses concerns about sudden disruptions to food supply chains and school budgets.
Ingredient-Based Rather Than Nutrient-Based
A defining feature of these proposals is their focus on ingredient composition and manufacturing processes rather than traditional nutrient metrics. This represents a conceptual shift in food policy -- asking not just whether a food delivers sufficient protein or limits sodium, but whether it relies on industrial additives like those tracked in our ingredients-to-avoid guide.
Industry Response Patterns
The food industry's response to state UPF legislation has followed recognizable patterns, drawing from established playbooks used in previous food policy debates over sodium limits, trans fat bans, and sugar-sweetened beverage taxes.
Opposition Arguments
- NOVA is too broad and captures affordable, nutritious products like fortified bread and yogurt
- Restricting school food options may reduce participation in meal programs, harming the children the laws aim to protect
- Compliance costs will strain school budgets, particularly in lower-income districts
- Nutrient-based standards are more scientifically grounded than processing-level classifications
- State-by-state labeling requirements create a patchwork that increases costs for manufacturers operating nationally
Parallel Industry Shifts
- Several major food manufacturers have announced reformulation initiatives aimed at reducing artificial additives
- "Clean label" product lines with shorter ingredient lists are expanding in school food service catalogs
- Some companies are proactively marketing to school districts with products positioned as NOVA Group 1-3 compliant
- Industry trade groups have proposed voluntary standards as an alternative to mandatory regulation
- Investment in scratch-cooking infrastructure and training programs has become a point of industry engagement
Both Sides Raise Valid Points
The debate over state UPF legislation involves genuine trade-offs. Public health data links ultra-processed food consumption to chronic disease, but concerns about food access, cost, and the practical challenges of implementation are substantive. The legislative outcomes in each state will depend on how effectively these competing considerations are balanced. For an overview of the underlying research, see our guide to the science behind ultra-processed food classification.
What to Watch in 2026-2027
Several developments in the next 12-18 months could significantly shape the trajectory of state UPF legislation. These are the key milestones and indicators to monitor.
California's Regulatory Process
The California Department of Education is expected to publish draft regulations defining ultra-processed food for AB 1264 compliance by late 2026 or early 2027. The specifics of this definition -- particularly which products are exempted and what documentation schools must maintain -- will influence how other states draft their own proposals.
2026 Legislative Sessions
Most state legislatures have active sessions in 2026. Bills currently in committee -- particularly in Arizona, Massachusetts, Pennsylvania, and Oregon -- will either advance to floor votes, be amended, or stall. The number of new bills introduced in states not yet on the tracker will indicate whether legislative momentum is building or plateauing.
Federal Activity
The FDA and USDA are reviewing comments from their Request for Information on defining ultra-processed food. Any announcement of a proposed federal definition or voluntary guidance could either accelerate state action (by providing a framework to adopt) or slow it (if states defer to pending federal standards).
Louisiana Study Commission Findings
Louisiana's study commission is expected to deliver its findings in 2026. The commission's conclusions -- particularly whether it recommends substantive legislation -- will signal whether the study commission approach leads to further action or serves primarily as a deliberative pause.
Industry Reformulation Trends
If major school food manufacturers accelerate reformulation efforts -- producing products with fewer industrial additives that meet both USDA nutrition standards and NOVA-based processing criteria -- the practical barriers to legislative compliance decrease. Product availability could become the factor that determines whether pending bills gain enough support to pass.
Check Products in Our Database
You can search for specific food products in our database of 1.98 million products to see their processing level, ingredient breakdown, and how they would be classified under a NOVA-based framework. Common school food items like chicken nuggets and breakfast cereals are searchable by brand and product name.
Frequently Asked Questions
Which state has the most advanced ultra-processed food legislation?
California is the clear leader. AB 1264, signed into law in 2025, makes it the first state to phase out ultra-processed food from school cafeterias based on processing level rather than nutrient content alone. The law uses the NOVA classification system as its foundation and follows a phased compliance timeline through 2035. Other states have introduced proposals, but none have enacted comparable laws as of February 2026.
Do any state laws restrict which foods can be purchased with SNAP benefits?
No state has enacted restrictions on SNAP-eligible foods based on processing level. SNAP is a federal program, and changes to its eligible food list require federal action, not state legislation. However, several states have passed resolutions urging Congress and the USDA to study whether SNAP incentive structures could encourage purchases of minimally processed foods. These resolutions are non-binding and serve primarily as signals of legislative interest.
Are food companies lobbying against state UPF legislation?
Food industry trade groups have been active in state legislative processes where UPF-related bills have been introduced. Their arguments typically center on cost increases, supply chain disruption, impacts on food access in underserved communities, and questions about the scientific basis for regulating by processing level rather than nutrient content. At the same time, some food manufacturers have begun reformulating products with shorter ingredient lists, anticipating that regulatory trends may continue in this direction.
Could federal action preempt state UPF legislation?
In theory, a federal definition of ultra-processed food or a federal labeling mandate could preempt state-level laws on the same subject, depending on how the federal statute is written. However, federal action on UPF remains in early stages -- the FDA and USDA have issued a Request for Information but have not proposed any rules. For the foreseeable future, state legislatures remain the primary venue for UPF policy activity. If federal standards do eventually emerge, they could either supersede state laws or establish a floor that states can build upon, similar to how state food safety laws interact with FDA regulations.
How can I track upcoming UPF legislation in my state?
State legislative tracking services like LegiScan, the National Conference of State Legislatures (NCSL), and individual state legislature websites allow you to search for bills by keyword. Searching for terms like "ultra-processed," "food processing," "school meal standards," or "food labeling" will surface relevant proposals. Many consumer advocacy organizations also maintain tracking pages for food policy bills at the state level. We will update this page as significant developments occur.
Continue Learning
California UPF School Ban →
How AB 1264 phases out ultra-processed food in school cafeterias -- the law that started the state-level trend
MAHA Report and FDA Definition →
Federal efforts to define ultra-processed food and the MAHA commission recommendations driving the conversation
What Are Ultra-Processed Foods? →
Understand the NOVA classification, processing levels, and the research behind ultra-processing
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.