The FDA Is About to Define “Ultra‑Processed”—and Your ‘Healthy’ Grocery Haul Might Suddenly Count: The 5 Ingredients That Decide It
The U.S. still has no official definition of “ultra‑processed”—but that’s changing via a federal RFI and a 2026 priority deliverable. Once the government draws the line, research, policy, and what you think of as “healthy” could shift overnight.
By TheMurrow Editorial
April 9, 2026
Key Points
- 1Key fact: The U.S. still lacks an official “ultra‑processed” definition, but FDA/USDA launched an RFI and list a 2026 deliverable.
- 2Track the stakes: Ultra‑processed foods provide about 55% of calories overall and 61.9% for youth in recent CDC/NCHS data.
- 3Follow the evidence: An NIH inpatient trial found higher intake and ~two-pound gain on ultra‑processed diets even with calories and macros matched.
The most controversial word on American food labels right now isn’t “natural,” “healthy,” or even “protein.” It’s a word that, technically, doesn’t appear on most packages at all: ultra‑processed.
For years, the term has done heavy cultural work. It has anchored bestsellers and viral TikToks, driven diet advice, and helped explain why a pantry full of “low‑fat” snacks can still leave people heavier and hungrier. It has also become the shorthand for a growing public-health worry: a food supply dominated by products engineered for convenience and constant eating.
Here’s the twist: despite the volume of headlines, the U.S. government still has no official definition of “ultra‑processed foods.” That may be about to change—slowly, bureaucratically, and with major consequences for research, regulation, and consumer trust.
On July 24, 2025, the FDA and USDA jointly issued a Request for Information (RFI) to collect data and public input toward a uniform definition of ultra‑processed foods in the U.S. food supply. The comment period was later extended to October 23, 2025, and the FDA’s Human Foods Program lists “develop a federal government definition of UPFs” as a 2026 priority deliverable, with work continuing as agencies analyze RFI comments and gather data.
“America’s food debate is stuck on a basic question: what counts as ultra‑processed—officially?”
— — TheMurrow Editorial
Key Points
Key fact: The U.S. government still lacks an official definition of “ultra‑processed,” but FDA/USDA are now building one via an RFI.
Track the stakes: Ultra‑processed foods supply about 55% of U.S. calories overall—and 61.9% for youth—making the definition more than semantics.
Watch the evidence: An NIH inpatient trial found people ate more and gained weight on an ultra‑processed diet—even with calories and macros matched.
Track the stakes: Ultra‑processed foods supply about 55% of U.S. calories overall—and 61.9% for youth—making the definition more than semantics.
Watch the evidence: An NIH inpatient trial found people ate more and gained weight on an ultra‑processed diet—even with calories and macros matched.
Why the FDA and USDA are trying to define “ultra‑processed” now
The FDA’s public framing is straightforward: without a uniform definition, the U.S. can’t reliably compare studies, track trends, or design coherent policy aimed at diet‑related chronic disease. The agencies are asking for evidence and perspectives precisely because existing approaches don’t always line up with health outcomes in predictable ways.
The current problem: research without a shared ruler
Most U.S. research and public conversation rely on the NOVA system, a food classification framework developed by Brazilian researchers. NOVA has been influential partly because it offers something rare in nutrition: a clear, operational way to group foods by processing level. Yet federal agencies have signaled concern that existing definitions may not consistently capture which foods matter most for health.
A definition that works for epidemiology might not work for labeling. A definition that works for labeling might be too crude for clinical research. When people argue about ultra‑processed foods, they often argue past each other because they’re using different yardsticks.
A definition that works for epidemiology might not work for labeling. A definition that works for labeling might be too crude for clinical research. When people argue about ultra‑processed foods, they often argue past each other because they’re using different yardsticks.
The key timeline—and what it does *not* promise
- July 24, 2025: FDA/USDA issue a joint RFI seeking input toward a uniform U.S. definition for ultra‑processed foods.
- Comment period extended to October 23, 2025: indicating a longer runway for stakeholder feedback.
- 2026 deliverable: FDA’s Human Foods Program lists development of a federal definition as a 2026 priority, describing work as ongoing—gathering data and analyzing comments.
The public should read that carefully. The government is building a definition, but no final date is promised in the material cited. The process is active, not finished.
- Comment period extended to October 23, 2025: indicating a longer runway for stakeholder feedback.
- 2026 deliverable: FDA’s Human Foods Program lists development of a federal definition as a 2026 priority, describing work as ongoing—gathering data and analyzing comments.
The public should read that carefully. The government is building a definition, but no final date is promised in the material cited. The process is active, not finished.
“The FDA isn’t declaring a verdict yet; it’s assembling the case file.”
— — TheMurrow Editorial
Ultra‑processed foods already dominate American diets
The definitional fight isn’t academic because ultra‑processed foods account for a majority of calories in the U.S.—and the shares are highest among children and teens.
The headline number: more than half of calories
According to CDC/NCHS data covering Aug 2021–Aug 2023, about 55% of calories for Americans age 1+ came from ultra‑processed foods. For youth, the average was 61.9%, a decline from 65.6% in 2017–2018.
Those are not fringe numbers. They describe the mainstream American diet—school lunches, snacks between activities, quick breakfasts, and “easy” dinners after work.
Those are not fringe numbers. They describe the mainstream American diet—school lunches, snacks between activities, quick breakfasts, and “easy” dinners after work.
55%
Share of calories from ultra‑processed foods for Americans age 1+ (CDC/NCHS, Aug 2021–Aug 2023).
61.9%
Average share of calories from ultra‑processed foods for U.S. youth (CDC/NCHS, Aug 2021–Aug 2023).
Youth trends: a long arc, small recent dip
Another analysis using NHANES 1999–2018 found youth energy share from ultra‑processed foods increased from 61.4% to 67.0% over that period. Put beside the more recent CDC/NCHS estimate (61.9% for youth in 2021–2023), the story looks less like a simple linear climb and more like a high plateau with some fluctuation.
The practical implication is stark: any national health strategy that avoids the ultra‑processed category is likely avoiding the bulk of what Americans—especially kids—actually eat.
The practical implication is stark: any national health strategy that avoids the ultra‑processed category is likely avoiding the bulk of what Americans—especially kids—actually eat.
Why this matters to readers
When a food category supplies most of a nation’s calories, small shifts can have outsized effects. Even modest reductions—if sustained—could change daily intake patterns more than most people realize. That potential is exactly why a government definition carries weight: it can shape measurement, messaging, and policy levers at scale.
The strongest evidence isn’t a survey—it’s a controlled NIH study
Nutrition research often struggles to show causality because people don’t eat in controlled settings for long periods. That’s why one NIH‑summarized study has become a cornerstone in the ultra‑processed debate: Kevin Hall’s inpatient randomized trial at the NIH Clinical Center.
What the study found, in plain English
Participants were fed either an ultra‑processed diet or an unprocessed diet in a controlled, inpatient environment. The key point: the diets were matched for major factors such as calories, sugar, fat, and fiber. Despite that, participants ate more when given the ultra‑processed diet and gained about two pounds on average. On the unprocessed diet, they ate fewer calories and lost weight.
That finding doesn’t prove every ultra‑processed food is harmful in every context. It does, however, show something central: the level of processing can change how much people eat, even when the nutrition label looks similar on paper.
That finding doesn’t prove every ultra‑processed food is harmful in every context. It does, however, show something central: the level of processing can change how much people eat, even when the nutrition label looks similar on paper.
“When calories were matched, processing still changed behavior: people ate more and gained weight.”
— — TheMurrow Editorial
Why it changed the conversation
The study’s power comes from its design. Epidemiological studies can show correlations between ultra‑processed intake and health outcomes, but critics can argue that lifestyle factors—income, stress, sleep, physical activity—explain the relationship. A controlled feeding trial narrows those escape hatches.
For readers, the takeaway is less about panic and more about humility. The body appears to respond to foods as systems—texture, speed of eating, palatability, and satiety cues—not just as macronutrient math.
For readers, the takeaway is less about panic and more about humility. The body appears to respond to foods as systems—texture, speed of eating, palatability, and satiety cues—not just as macronutrient math.
≈2 lb
Average weight gain reported on the ultra‑processed diet arm in Kevin Hall’s controlled NIH inpatient randomized trial (NIH summary).
What “ultra‑processed” usually means today (and why ingredients matter)
Because consumers can’t see factory methods from a package, most public-facing definitions rely on markers visible on labels—especially ingredient lists. The most widely used framework, NOVA, classifies Group 4 foods as ultra‑processed.
NOVA’s core concept: industrial formulations
NOVA describes ultra‑processed foods as industrial formulations made “entirely or mostly” from:
- Substances extracted from foods (oils, fats, sugar, starch, proteins)
- Derived constituents (for example, hydrogenated fats, modified starches)
- Synthesized substances (such as flavor enhancers, colors, and other additives)
The logic is not that “processing” is automatically bad. Bread is processed. Yogurt is processed. Freezing vegetables is processing. NOVA’s emphasis is different: it flags products whose structure and sensory appeal are built from refined components and additive systems rather than from recognizable whole-food matrices.
- Substances extracted from foods (oils, fats, sugar, starch, proteins)
- Derived constituents (for example, hydrogenated fats, modified starches)
- Synthesized substances (such as flavor enhancers, colors, and other additives)
The logic is not that “processing” is automatically bad. Bread is processed. Yogurt is processed. Freezing vegetables is processing. NOVA’s emphasis is different: it flags products whose structure and sensory appeal are built from refined components and additive systems rather than from recognizable whole-food matrices.
The label-visible markers NOVA tends to flag
- ✓Substances extracted from foods (oils, fats, sugar, starch, proteins)
- ✓Derived constituents (e.g., hydrogenated fats, modified starches)
- ✓Synthesized substances (flavor enhancers, colors, other additives)
Why this becomes controversial fast
Ingredient-list logic can feel like a morality play—short list good, long list bad—and that’s where debates ignite.
Critics argue the approach risks lumping together foods with very different nutritional profiles. Supporters respond that the pattern is the point: ultra‑processed dietary patterns correlate with poorer health outcomes, and ingredient markers are one of the few scalable tools consumers and researchers can use.
The FDA/USDA RFI signals the government understands both sides. A federal definition will need to be precise enough for research, practical enough for policy, and fair enough to withstand intense scrutiny from industry, advocates, and scientists.
Critics argue the approach risks lumping together foods with very different nutritional profiles. Supporters respond that the pattern is the point: ultra‑processed dietary patterns correlate with poorer health outcomes, and ingredient markers are one of the few scalable tools consumers and researchers can use.
The FDA/USDA RFI signals the government understands both sides. A federal definition will need to be precise enough for research, practical enough for policy, and fair enough to withstand intense scrutiny from industry, advocates, and scientists.
Key Insight
The fight isn’t just over a word—it’s over a tool that has to work for research, labeling, policy, and real grocery decisions at the same time.
What a federal definition could change: research, policy, and the supermarket aisle
A uniform definition sounds bureaucratic until you imagine where it could land. Definitions determine what gets counted—and what gets targeted.
Research consistency and public messaging
If federal agencies adopt a uniform definition, studies may become more comparable across time and across institutions. That matters for public trust. Right now, one study’s “ultra‑processed” might not perfectly match another’s, leading to confusing headlines and polarized interpretations.
A federal definition could also influence how federal agencies communicate dietary advice. Even without new rules, definitions shape guidelines, educational materials, and public-health campaigns.
A federal definition could also influence how federal agencies communicate dietary advice. Even without new rules, definitions shape guidelines, educational materials, and public-health campaigns.
Policy tools—some obvious, some subtle
The FDA has tied the initiative to reducing diet‑related chronic disease. The USDA, with its role in food programs and dietary guidance, has its own stakes in classification. A definition could influence:
- How foods are discussed or categorized in federal nutrition programs
- What researchers measure when evaluating interventions
- How policymakers frame proposals (even before any regulation changes)
None of that requires a new label on the front of a box. Definitions often reshape policy quietly—through procurement standards, research funding priorities, and the language of official guidance.
- How foods are discussed or categorized in federal nutrition programs
- What researchers measure when evaluating interventions
- How policymakers frame proposals (even before any regulation changes)
None of that requires a new label on the front of a box. Definitions often reshape policy quietly—through procurement standards, research funding priorities, and the language of official guidance.
Legal and political pressure is rising
The definitional push is also happening in a louder environment. In December 2025, San Francisco sued major food manufacturers over alleged harms of ultra‑processed foods. Litigation is not a scientific verdict, but it reflects escalating pressure to translate the ultra‑processed debate into accountability, damages, and discovery.
When lawsuits and policymaking begin to orbit a term, the term has to be defined—or the fight becomes a battle over semantics.
When lawsuits and policymaking begin to orbit a term, the term has to be defined—or the fight becomes a battle over semantics.
The best arguments on both sides—and what readers should watch for
A federal definition will not end debate. It will relocate it—from social media to docket comments, from think pieces to technical criteria.
The case for a tighter definition
Supporters of a federal definition argue that the U.S. needs:
- A shared standard for measuring exposure in diet studies
- A clearer basis for potential policy action
- A way to reduce confusion caused by competing classifications
They also point to the scale of exposure (majority of calories) and the NIH-controlled evidence suggesting processing affects intake.
- A shared standard for measuring exposure in diet studies
- A clearer basis for potential policy action
- A way to reduce confusion caused by competing classifications
They also point to the scale of exposure (majority of calories) and the NIH-controlled evidence suggesting processing affects intake.
The case for caution
Skeptics worry about overreach and oversimplification. They argue:
- “Ultra‑processed” can blur meaningful differences between foods
- Additives and industrial methods are not inherently harmful in all uses
- A blunt definition could stigmatize accessible, shelf-stable foods that many families rely on
These concerns are not trivial. Any definition that effectively tells Americans “avoid most of what you eat” will provoke backlash, not behavior change.
- “Ultra‑processed” can blur meaningful differences between foods
- Additives and industrial methods are not inherently harmful in all uses
- A blunt definition could stigmatize accessible, shelf-stable foods that many families rely on
These concerns are not trivial. Any definition that effectively tells Americans “avoid most of what you eat” will provoke backlash, not behavior change.
What to watch in the FDA/USDA process
Readers should pay attention to whether the eventual definition:
- Relies mainly on ingredients and additives, or incorporates processing methods too
- Distinguishes between ultra‑processed “treats” and ultra‑processed “staples”
- Can be applied consistently in research without collapsing nuance
The goal should be clarity without caricature: a definition that helps people make sense of the food supply rather than simply scolding them for living in it.
- Relies mainly on ingredients and additives, or incorporates processing methods too
- Distinguishes between ultra‑processed “treats” and ultra‑processed “staples”
- Can be applied consistently in research without collapsing nuance
The goal should be clarity without caricature: a definition that helps people make sense of the food supply rather than simply scolding them for living in it.
Editor's Note
The most consequential choice may be what the definition optimizes for: epidemiology, labeling, program policy, or litigation-proof specificity.
Practical takeaways: how to use the idea of “ultra‑processed” without turning it into a religion
Even before the government finalizes anything, readers still have to eat. The most useful approach treats ultra‑processed as a pattern signal, not a purity test.
A workable consumer checklist (without pretending ingredients tell the whole story)
Use packaging cues as prompts, not commandments:
- Scan the ingredient list for multiple industrial markers (modified starches, hydrogenated fats, flavor enhancers, colors)
- Notice hyper-palatable combinations (sweet + fat + salt) that encourage automatic overeating
- Track your own satiety: do you feel full after eating it, or primed to keep grazing?
None of these rules requires perfection. They help you identify which products behave like “calorie accelerators” in your life.
- Scan the ingredient list for multiple industrial markers (modified starches, hydrogenated fats, flavor enhancers, colors)
- Notice hyper-palatable combinations (sweet + fat + salt) that encourage automatic overeating
- Track your own satiety: do you feel full after eating it, or primed to keep grazing?
None of these rules requires perfection. They help you identify which products behave like “calorie accelerators” in your life.
Consumer checklist (prompts, not commandments)
- ✓Scan the ingredient list for multiple industrial markers (modified starches, hydrogenated fats, flavor enhancers, colors)
- ✓Notice hyper-palatable combinations (sweet + fat + salt) that encourage automatic overeating
- ✓Track your satiety: do you feel full, or primed to keep grazing?
Case study: the “matched macros” trap
Kevin Hall’s NIH study is a reminder that two diets can look similar by macro numbers yet lead to different eating behavior. For a real-world example, consider two lunches with comparable calories and fiber on paper—one built from minimally processed components and one built from ultra‑processed items. If the latter is easier to eat quickly and less filling, you may drift upward in calories without noticing.
The best response is not fear. It’s friction: choose meals that slow you down and leave you satisfied.
The best response is not fear. It’s friction: choose meals that slow you down and leave you satisfied.
A realistic approach for busy households
Given that youth get about 61.9% of calories from ultra‑processed foods (Aug 2021–Aug 2023), family strategies matter. Practical shifts that don’t demand a total lifestyle overhaul:
- Swap one daily snack for a less processed option you actually like
- Keep one “default dinner” that’s simple and minimally processed
- Treat ultra‑processed foods as intentional choices rather than background noise
A future federal definition may sharpen the category. Your daily choices can still move ahead of the paperwork.
- Swap one daily snack for a less processed option you actually like
- Keep one “default dinner” that’s simple and minimally processed
- Treat ultra‑processed foods as intentional choices rather than background noise
A future federal definition may sharpen the category. Your daily choices can still move ahead of the paperwork.
Conclusion: a definition is coming—so the food argument is about to get more precise
America has argued about ultra‑processed foods as if the term were self-evident. It isn’t. That’s why the FDA and USDA have opened a formal process to define it—starting with a July 2025 RFI, extended comments through October 2025, and ongoing work listed among the FDA Human Foods Program’s 2026 deliverables.
The stakes are bigger than vocabulary. Ultra‑processed foods supply about 55% of calories for Americans overall and 61.9% for youth. Controlled NIH evidence suggests processing can drive higher intake and weight gain even when conventional nutrition targets appear matched. Meanwhile, litigation and policy pressure are pushing the term from theory into enforcement.
A federal definition won’t automatically make the food supply healthier. It can, however, make the debate more honest—forcing everyone to specify what they mean, what they’re measuring, and what they want to change. That kind of clarity is rare in nutrition. It’s also overdue.
The stakes are bigger than vocabulary. Ultra‑processed foods supply about 55% of calories for Americans overall and 61.9% for youth. Controlled NIH evidence suggests processing can drive higher intake and weight gain even when conventional nutrition targets appear matched. Meanwhile, litigation and policy pressure are pushing the term from theory into enforcement.
A federal definition won’t automatically make the food supply healthier. It can, however, make the debate more honest—forcing everyone to specify what they mean, what they’re measuring, and what they want to change. That kind of clarity is rare in nutrition. It’s also overdue.
T
About the Author
TheMurrow Editorial is a writer for TheMurrow covering lifestyle.
Frequently Asked Questions
Does the U.S. government currently have an official definition of “ultra‑processed food”?
No. As of the federal materials referenced here, no official U.S. government definition exists. Many studies and headlines rely on the NOVA classification system, but FDA and USDA have signaled a desire for a uniform U.S. definition to support consistent research and policy.
What did the FDA and USDA do in July 2025?
On July 24, 2025, the FDA and USDA issued a joint Request for Information (RFI) seeking data and public input to develop a uniform definition of ultra‑processed foods for products in the U.S. food supply. The agencies framed this as foundational work for research consistency and chronic disease prevention.
Is the FDA about to finalize the definition?
The public record cited does not promise a final date. The FDA’s Human Foods Program lists developing a federal definition as a 2026 priority deliverable, describing ongoing work such as gathering data and analyzing RFI comments. That suggests the process is active, but not completed.
How much of the American diet is ultra‑processed?
Using CDC/NCHS data from Aug 2021–Aug 2023, ultra‑processed foods accounted for about 55% of calories for Americans age 1+. For youth, it was 61.9%, down from 65.6% in 2017–2018. These figures underscore why the term matters in public health.
What’s the strongest evidence that ultra‑processed foods affect health?
One of the most cited causal pieces is Kevin Hall’s NIH Clinical Center inpatient randomized trial, summarized by NIH. With diets matched for key factors like calories, sugar, fat, and fiber, participants ate more on the ultra‑processed diet and gained about two pounds on average. That suggests processing can influence intake behavior.
What does “ultra‑processed” typically mean under NOVA?
NOVA’s ultra‑processed category (Group 4) generally refers to industrial formulations made mostly from extracted or refined ingredients (oils, fats, sugars, starches, proteins) plus derived constituents (like hydrogenated fats, modified starches) and synthesized additives (such as flavor enhancers and colors). The focus is formulation markers often visible on labels.
