The Government Wants a Single Definition of ‘Ultra‑Processed.’ Your Pantry Is About to Get Reclassified—And One Food You Think Is ‘Junk’ Might Not Be.

Q: Does the U.S. government currently have an official definition of “ultra‑processed foods”?

No. HHS has stated there is **no single, authoritative U.S. government definition** of ultra‑processed foods today. That gap is why FDA and USDA issued a joint Request for Information to develop a uniform federal definition that could be used consistently across agencies and programs.

Q: What is the FDA–USDA RFI, and when did it happen?

The FDA and USDA published a **joint Request for Information (RFI)** in the Federal Register on **July 25, 2025**, under **Docket FDA‑2025‑N‑1793**. The agencies asked for data and recommendations to help craft a “federally recognized uniform definition” of UPFs across the U.S. food supply.

Q: What’s the deadline for public comments?

The original deadline was **September 23, 2025**, and it was later **extended to October 23, 2025**, according to an HHS/FDA/USDA update. The extension reflects the complexity of the issue and the breadth of interest from stakeholders.

Q: What is NOVA, and why does it matter in the U.S. debate?

**NOVA** is the most commonly used research framework for classifying foods by processing, developed by Brazilian researchers (often linked with **Carlos A. Monteiro**

On July 25, 2025, FDA and USDA launched a joint push to standardize “ultra‑processed.” Once that definition becomes official, it could ripple into guidance, procurement, school meals, and labeling—while sweeping in foods like yogurt and whole‑grains that people think of as healthy.

By TheMurrow Editorial

April 26, 2026

The Government Wants a Single Definition of ‘Ultra‑Processed.’ Your Pantry Is About to Get Reclassified—And One Food You Think Is ‘Junk’ Might Not Be.

Key Points

1Track the clock: FDA and USDA opened Docket FDA‑2025‑N‑1793 on July 25, 2025, with comments extended to Oct. 23.
2Expect ripple effects: a federal ultra‑processed definition could steer nutrition messaging, procurement rules, school meals, and future labeling initiatives.
3Watch the edge cases: broad rules could tag yogurt and whole‑grain products as UPFs, risking confusion, stigma, and unintended consequences.

The word “ultra‑processed” has become a kind of nutritional Rorschach test. For some, it’s shorthand for everything that’s gone wrong with modern eating—sugary cereals, neon snacks, shelf-stable meals engineered for maximum craving. For others, it’s an imprecise label that risks condemning foods people rely on, including items that can fit into healthy diets.

Now the U.S. government is stepping into the argument. On July 25, 2025, the FDA and USDA published a joint Request for Information—Docket FDA‑2025‑N‑1793—to help develop a uniform federal definition of ultra‑processed foods (UPFs). The agencies are blunt about the current state of play: there is no single, authoritative U.S. government definition of the term, even as it dominates research papers, policy debates, and social media discourse.

The comment period was initially set to close September 23, 2025, then was extended to October 23, 2025, giving industry, scientists, advocacy groups, and ordinary consumers more time to weigh in. The stated goal is a “federally recognized uniform definition” that could support “increased transparency” and future policy actions—without specifying what those actions might be.

A definition sounds technical. It isn’t. The moment Washington standardizes what “ultra‑processed” means, the term can migrate from academic studies into the machinery of government—nutrition guidance, procurement standards, school meals, and potentially labeling initiatives. A fight over a definition can become, very quickly, a fight over which foods get stigmatized, which get subsidized, and which get served.

“The federal government is trying to turn a research concept into something enforceable, predictable, and visible to consumers.”
— — TheMurrow Editorial

The federal push: why a definition now, and why it matters

The FDA–USDA RFI reads like a document written by agencies who know they’re walking into a live debate. It seeks “data and information” to create a uniform definition that can apply across the U.S. food supply. That matters because UPFs have been discussed for years as if the term were self‑evident, yet U.S. policy has largely operated without a standardized way to identify them.

The timeline, in plain terms

The government’s move is recent and specific:

Key dates

✓July 25, 2025: FDA and USDA publish the joint RFI in the Federal Register (Docket FDA‑2025‑N‑1793).
✓September 23, 2025: original deadline for public comments.
✓October 23, 2025: deadline extended by HHS/FDA/USDA.

Those dates matter because they signal intent: agencies aren’t merely “monitoring” the UPF conversation; they’re soliciting input to formalize it.

Where a definition can travel

The RFI does not promise specific downstream policies. Still, a federal definition can change how foods are categorized in official contexts. Even without new bans or mandates, a standard can influence:

Downstream policy areas

✓Public-health messaging (what government campaigns warn against)
✓Procurement standards (what institutions buy and serve)
✓School food policy (what qualifies as acceptable in meal programs)
✓Potential labeling initiatives (if agencies decide consumers should see UPF status)

A reader doesn’t need to follow federal dockets to feel the impact. Once a definition exists, “ultra‑processed” can shift from a vague cultural critique to an administrative category.

“A definition is not a verdict—but it can become one when it enters policy.”
— — TheMurrow Editorial

The core problem: “processing” isn’t one measurable thing

The RFI’s most revealing feature is not what it asserts, but what it asks. The agencies are essentially admitting that “ultra‑processed” is difficult to pin down because processing has multiple dimensions, and not all of them are easily observable or measurable.

Ingredient signals: additives, flavors, and the edge cases

The notice points to commonly cited UPF markers such as emulsifiers, bulking agents, and thickeners, along with industrial techniques and “sophisticated packaging” used to produce highly palatable foods. It also asks specific, thorny questions that show how quickly the concept breaks into complications:

Questions the RFI raises

✓Should flavors and colors count differently depending on whether they are natural vs. artificial, or certified vs. non‑certified?
✓How should small‑percentage ingredients be treated—ignored, weighted, or treated as disqualifying?

Those questions matter because real products often contain tiny amounts of stabilizers, anti-caking agents, or colors. A definition that treats all such ingredients as equal could label a huge share of the grocery store “ultra‑processed” without distinguishing meaningful differences.

Process signals: extrusion vs. fermentation

The RFI also asks whether to define UPFs by the methods used to make them, listing examples across categories:

Processes mentioned

✓Physical processes like extrusion
✓Biological processes such as fermentation and enzymatic treatment
✓Chemical processes like pH adjustment

The inclusion of fermentation is telling. Fermentation is ancient, often associated with foods people consider wholesome. Yet it is also a form of processing. Any rule that treats “processing” as inherently suspect risks collapsing important distinctions.

The practical constraint: consumers can’t see processing

A crucial barrier sits between the theory and implementation: manufacturers often aren’t required to disclose processing information on food labels. Ingredient lists exist; detailed process disclosures generally do not.

That means a consumer-facing definition must rely heavily on what’s observable—ingredients, product form, perhaps categories—unless agencies create new disclosure requirements. The RFI’s subtext is clear: a workable definition needs to be implementable, not merely philosophically satisfying.

NOVA: the leading framework—and why it divides experts

If the U.S. government adopts an existing system, the most likely candidate is NOVA. The RFI calls NOVA the “most common” classification, developed by Brazilian researchers often associated with Carlos A. Monteiro, dividing foods into four groups, with Group 4 designated as ultra‑processed.

What NOVA tries to do

NOVA’s appeal is that it aims to classify foods by the extent and purpose of industrial processing—not merely by nutrient levels. In practice, that means UPFs aren’t just foods high in sugar, salt, or saturated fat. UPFs are foods whose processing and formulation produce a product that is typically convenient, hyper-palatable, and unlike foods made in a standard home kitchen.

That’s also what makes NOVA controversial. The framework suggests the problem is not only “bad nutrients,” but an industrial category of food.

The criticism: nutrition and processing don’t always align

The RFI itself highlights a politically explosive tension: UPFs often overlap with foods high in added sugars, sodium, and saturated fat—nutrients the Dietary Guidelines already advise limiting. Yet the category can also include foods recommended in healthy dietary patterns. The notice even names whole‑grain products and yogurt as examples of foods that can land in the UPF bucket.

That’s not a minor quibble. If a definition labels broadly consumed, often-recommended foods as “ultra‑processed,” the public may treat “UPF” as a synonym for “unhealthy,” even when the nutritional profile is favorable. Agencies explicitly warn of unintended consequences if the definition is too broad.

“If ‘ultra‑processed’ becomes synonymous with ‘bad,’ the classification will do more than describe food—it will stigmatize it.”
— — TheMurrow Editorial

Why the definition debate isn’t just semantics

Policy fights often start with language. Once a term hardens into a standard, it shapes what can be measured, what can be targeted, and what can be enforced. The RFI frames the goal as supporting “increased transparency,” but the practical stakes run deeper.

A label can become a lever

A federal definition could become a lever in multiple arenas:

- Researchers could align studies using a single standard rather than patchwork definitions.
- Regulators could use the category when evaluating nutrition communications and consumer understanding.
- Agencies and institutions could adopt UPF thresholds in purchasing rules or nutrition standards.

None of those outcomes are guaranteed. The RFI does not announce a policy package. Still, a definition is often the first step toward policy, because it creates a shared reference point.

The risk of blunt instruments

The agencies explicitly acknowledge the risk that a broad definition could sweep in foods that help people meet dietary recommendations. The notice’s examples—whole‑grain products and yogurt—capture the uncomfortable reality: some widely eaten foods sit at the intersection of industrial production and nutritional value.

A workable approach may require more nuance than a binary label. Yet public discourse tends to flatten nuance. In real life, “UPF” will likely be heard as “avoid.” That interpretive gap should shape how the definition is drafted.

Four numbers that frame the moment

Even without national consumption figures in the RFI, the government’s own docket provides a set of concrete markers for where this effort sits:

The number of authoritative, single federal definitions of UPFs in the U.S. today (per HHS).

One joint federal effort: FDA and USDA issuing a unified RFI rather than separate inquiries.

July 25, 2025

The publication date that begins the formal process.

October 23, 2025

The extended deadline that signals substantial public interest and complexity.

Those numbers don’t tell you whether UPFs are “good” or “bad.” They do tell you the U.S. government is preparing to make the term operational.

What a practical definition might look like—and what it can’t do

The RFI suggests agencies are searching for a definition that is not only scientifically plausible, but administratively workable. That requires tradeoffs.

Ingredient-based rules are enforceable—up to a point

Ingredient lists are standardized, widely available, and legible to both regulators and consumers. A definition that flags certain additive classes—emulsifiers, thickeners, bulking agents—has the advantage of being relatively easy to apply.

The downside is overreach. Many additives serve technical functions that do not neatly map onto health outcomes, and many foods with similar ingredients are nutritionally and culturally distinct. The RFI’s questions about flavors, colors, and small-percentage ingredients show agencies are aware of the risk: ingredient triggers can produce arbitrary outcomes at the margins.

Process-based rules may be closer to the concept—but hard to verify

Defining UPFs by techniques like extrusion, pH adjustment, and specific forms of enzymatic treatment could better reflect what “ultra‑processed” is meant to convey.

A consumer-facing definition, however, runs into the RFI’s constraint: processing methods are typically not disclosed on labels. A process-based regime might be feasible for internal government use—e.g., industry reporting, audits, or supply-chain documentation—but harder for consumers to apply without new disclosure requirements.

A hybrid may be the only workable compromise

The RFI’s structure hints at a hybrid approach: ingredients as proxies, processes as supporting criteria, and perhaps exceptions to prevent nutritionally beneficial foods from being swept in without thought.

That path is messy, but the alternative is worse: a definition so abstract it can’t be implemented, or so blunt it misleads.

The yogurt and whole‑grain problem: unintended consequences in real life

The RFI’s mention of yogurt and whole‑grain products is more than a footnote. It’s a warning from the agencies that the UPF category can collide with nutrition policy goals.

Case study: yogurt as both “processed” and recommended

Yogurt often appears in dietary patterns as a protein-rich, nutrient-dense option. Yet many yogurts are also industrial formulations with stabilizers, flavors, and sweeteners. A UPF definition that focuses on additive presence could label many yogurts “ultra‑processed,” even when the product helps people meet dietary needs.

The policy question becomes awkward: if a school meal program or procurement guideline later uses a UPF definition, would yogurt be discouraged broadly, or would the rule distinguish between product types?

Case study: whole‑grain products and industrial reality

Whole grains are consistently promoted, but many whole‑grain breads, cereals, and crackers are produced using industrial processes, additives, and packaging designed for long shelf life.

The RFI underscores a central truth about the modern food supply: industrial processing and nutritional benefit can coexist in the same item. A definition that fails to accommodate that reality could push consumers away from foods that help them meet dietary recommendations—especially when cost, availability, and convenience drive decisions.

The equity dimension—implicit but unavoidable

The RFI doesn’t frame the issue as equity, but readers will recognize the pressure point. If “ultra‑processed” becomes a broad stigma, it can land hardest on people who rely on packaged foods because of time, budget, geography, or disability. A definition that simply condemns industrial foods without offering workable alternatives can function as moralizing rather than guidance.

What the comment process is really asking: evidence, not vibes

RFIs are often misunderstood as bureaucratic box-checking. In practice, they’re a way to build a record: to gather evidence, surface disputes, and learn what will break when a concept becomes a standard.

What FDA and USDA want commenters to address

The RFI’s questions reveal the agencies are trying to solve several practical puzzles at once:

- How to identify UPFs using observable criteria
- How to handle flavors, colors, and minor ingredients
- How to incorporate physical, biological, and chemical processing
- How to avoid a definition that conflicts with foods recommended in healthy patterns
- How to deal with the reality that processing information is often not labeled

The agencies’ own language—seeking “data and recommendations”—signals a preference for evidence-backed proposals over rhetorical claims. That matters because UPFs are already a cultural flashpoint. The government is asking, in effect: if we are going to use this term, how do we make it coherent?

Expert voices—what the government is already signaling

The most direct “expert quote” available from the provided record is the government’s own characterization of the task. The RFI states a core tension plainly: UPFs overlap with nutrients we are advised to limit, yet also include foods like whole‑grain products or yogurt that appear in recommended patterns—creating risk of unintended consequences if the definition is too broad (FDA/USDA Federal Register notice, July 25, 2025).

HHS also frames the goal as a “federally recognized uniform definition” to support “increased transparency” (HHS press materials linked to the RFI). Those phrases are diplomatic, but they’re also a clue: agencies see definitional chaos as a barrier to consistent communication and policy.

Practical takeaways for readers right now

Until a definition exists, consumers can still use the debate productively—without turning it into purity culture.

- Treat “ultra‑processed” as a signal, not a verdict. The label is contested for a reason.
- Watch for added sugars, sodium, and saturated fat, which the Dietary Guidelines already address and the RFI notes often overlap with UPFs.
- Pay attention to whether a food is doing a job in your diet—protein, fiber, calories, affordability—rather than assuming “processed” equals “bad.”

The most responsible reading of the RFI is not “the government is coming for your snacks.” It’s “the government is trying to define a term that has outgrown its scientific origins.”

Key Insight

Once a federal definition exists, “ultra‑processed” can move from a cultural insult to an administrative category with real policy consequences.

Conclusion: the definition will shape the debate more than the debate will shape the definition

The FDA and USDA are attempting something deceptively hard: to translate “ultra‑processed” from a flexible research concept into a federal standard that can survive policy, compliance, and public interpretation. The RFI shows agencies know the hazards—especially the risk of classifying foods like yogurt and whole‑grain products as UPFs in ways that confuse consumers and undermine nutrition goals.

A uniform definition could bring clarity. It could also create a blunt new label that becomes a proxy for virtue and vice. The outcome depends on whether the final standard is narrow enough to be meaningful, practical enough to be applied, and nuanced enough to avoid punishing foods that help people eat well in the world as it is.

The comment window—extended to October 23, 2025—is the quiet part of a loud cultural argument: the moment when a word that has shaped headlines may finally be pinned to an official meaning. Once that happens, “ultra‑processed” won’t just describe food. It will help decide what counts as responsible eating in American public life.

About the Author

TheMurrow Editorial is a writer for TheMurrow covering food & recipes.

Frequently Asked Questions

Does the U.S. government currently have an official definition of “ultra‑processed foods”?

No. HHS has stated there is no single, authoritative U.S. government definition of ultra‑processed foods today. That gap is why FDA and USDA issued a joint Request for Information to develop a uniform federal definition that could be used consistently across agencies and programs.

What is the FDA–USDA RFI, and when did it happen?

The FDA and USDA published a joint Request for Information (RFI) in the Federal Register on July 25, 2025, under Docket FDA‑2025‑N‑1793. The agencies asked for data and recommendations to help craft a “federally recognized uniform definition” of UPFs across the U.S. food supply.

What’s the deadline for public comments?

The original deadline was September 23, 2025, and it was later extended to October 23, 2025, according to an HHS/FDA/USDA update. The extension reflects the complexity of the issue and the breadth of interest from stakeholders.

Why is it so hard to define “ultra‑processed”?

“Processing” isn’t a single measurable attribute. The RFI discusses ingredient markers (like emulsifiers, bulking agents, and thickeners) and process markers (like extrusion, fermentation, and pH adjustment). Another obstacle: processing methods usually aren’t disclosed on labels, making consumer-facing rules harder to implement.

What is NOVA, and why does it matter in the U.S. debate?

NOVA is the most commonly used research framework for classifying foods by processing, developed by Brazilian researchers (often linked with Carlos A. Monteiro

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