By Julie Holt, Global Advisory Services Director, and Kathy Van Zyl, Regulatory Consultant
FoodChain ID experts in Regulatory and Scientific Consulting offer global guidance to meet the evolving demands of the food and beverage marketplace.
Ultra-processed foods (UPFs) refer to food products that undergo significant industrial processing and often contain ingredients not typically used in home cooking, such as modified starches, colorants, flavor enhancers and preservatives. These products are engineered for consistency, shelf life and flavor, making them a mainstay of modern diets across both developed and emerging markets.
One system used to categorize food processing is the NOVA classification, which sorts foods into four groups. Group 4, representing UPFs, includes items formulated primarily through industrial processes, often with multiple added substances to enhance taste and stability. A newer system, Wisecode, introduces a fifth category called “super-ultra-processed,” though it remains under review and lacks broad adoption.
Federal Action in the United States: A Regulatory Turning Point
While discussions around UPFs have existed for several years in academic and public health circles, the United States (US) federal government is now taking concrete steps toward a regulatory framework. The US Food and Drug Administration (FDA), in coordination with the US Department of Agriculture (USDA), is developing an official definition of ultra-processed food. This development follows broader calls for clearer guidance of the role of UPFs in school meal programs, nutrition assistance policy and national dietary guidelines.
The proposed federal definition is expected to build on the existing knowledge of nutrients to avoid—such as products high in refined sugars, unhealthy fats and salt, and typically low in essential nutrients. According to FDA Commissioner Marty Makary, the aim is not to ban UPFs, but to encourage transparent labeling and promote competition based on nutrient profiles. He noted that such a framework could drive the food industry to adopt labels like “non-ultra-processed,” akin to current practices around “no added sugar” marketing claims.
Public engagement will play a key role, with the FDA and USDA planning a public comment period before finalizing any regulatory language.
Health Research: Associations and Uncertainties
Research has explored associations between high consumption of UPFs and a range of health conditions. Studies have identified correlations with Parkinson Disease, cardiovascular diseases, certain cancers and mental health challenges.
While causation remains difficult to establish, these associations are prompting further investigation. For example, the FDA and US National Institutes of Health (NIH) have launched a joint research initiative to study the nutritional and metabolic impacts of UPFs on long-term health outcomes. The US federal administration through the Make America Healthy Again (MAHA) Commission is also pushing for food additives, like colorants, be obtained from natural sources.
In Europe, agencies such as the French Agency for Food, Environmental and Occupational Health and Safety are conducting similar evaluations. Globally, governments are exploring measures such as health taxes on sugar- and fat-rich products to discourage excess consumption and raise consumer awareness.
Labeling and Communication Strategies
Front-of-pack labeling systems continue to play a pivotal role in helping consumers identify products based on nutritional composition. Widely used systems include:
– Nutri-Score
– Nutri-Grade
– Health Star Rating
– Nutri-Mark
These tools highlight content such as sugar, fat and salt levels but stop short of indicating the degree of processing. The absence of a unified standard for defining UPFs complicates labeling efforts and underscores the potential value of the FDA’s upcoming framework.
A US federal definition could also open the door for warning labels or marketing restrictions, similar to policies being implemented in countries like the UK, where a junk food advertising ban is scheduled to take effect.
Functional Role and Benefits of UPFs
While scrutiny of UPFs grows, it’s important to acknowledge their functional value in modern food systems such as:
– Infant formulas and medical nutrition products often fall into the UPF category and are essential for vulnerable populations.
– UPFs support food access, affordability, and logistics, especially in underserved communities.
– Long shelf life and ease of storage make them integral to disaster preparedness, military operations, and even space travel.
Moreover, not all UPFs are created equal. Advances in food technology are enabling the reformulation of ultra-processed products to reduce additives, improve nutrient profiles, and enhance packaging to mitigate contamination risks.
Industry Takeaway: Preparing for Change
For food industry professionals, the key takeaway is that change is underway. A formal US federal definition of ultra-processed food could impact:
– Product labeling and marketing claims
– Ingredient sourcing and formulation
– Eligibility for institutional food programs
– Consumer perception and brand strategy
Producers, retailers and policymakers should closely monitor regulatory developments, participate in public comment opportunities and assess their portfolios for alignment with emerging health and transparency standards.