The U.S. Is About to Define “Ultra‑Processed”—and Your ‘Healthy’ Grocery List May Flip Overnight
FDA and USDA are trying to lock down a single federal definition of “ultra‑processed.” What sounds like semantics could reshape guidance, labels, school meals—and which “healthy” staples get side‑eyed.
By TheMurrow Editorial
March 11, 2026
Key Points
- 1Track the federal move: FDA and USDA opened Docket FDA‑2025‑N‑1793 to create a uniform definition of ultra‑processed foods.
- 2Know the scale: NHANES 2021–2023 shows about 55% of U.S. calories come from UPFs—nearly 62% for kids and teens.
- 3Expect ripple effects: A standardized definition could reshape guidance, school procurement, research, labeling fights, and even what counts as a “healthy” swap.
The fight over America’s food is about to get strangely specific.
For years, “ultra-processed” has been the kind of phrase that floats through public health reports, Instagram captions, and dinner-table debates—vivid, accusatory, and frustratingly slippery. People nod along as if everyone agrees on what it means. Researchers publish entire careers’ worth of work using the term. Parents scan ingredient lists with the intuition that they’ll know it when they see it.
Now the federal government is trying to pin the word to the page.
In July 2025, the FDA and USDA opened a joint Request for Information—a formal call for evidence meant “to help establish a federally recognized uniform definition” of ultra-processed foods (UPFs) in the U.S. food supply. The docket—FDA‑2025‑N‑1793—ran through Regulations.gov, with the comment deadline extended from September 23, 2025 to October 23, 2025.
The definitional question sounds academic until you look at what Americans eat. According to the CDC’s National Center for Health Statistics, data from NHANES (Aug 2021–Aug 2023) shows Americans ages 1 and up get about 55% of daily calories from UPFs. For kids and teens, it’s 61.9%. For adults, 53%. Ultra-processed isn’t a niche category. It’s the baseline.
Ultra-processed isn’t a fringe category in America. It’s the default calorie source—especially for kids.
— — TheMurrow Editorial
55%
NHANES (Aug 2021–Aug 2023): Americans ages 1+ get about 55% of daily calories from ultra-processed foods.
61.9%
NHANES (Aug 2021–Aug 2023): Kids and teens (1–18) get 61.9% of daily calories from UPFs.
53%
NHANES (Aug 2021–Aug 2023): Adults (19+) get 53% of daily calories from UPFs.
The federal government is building a definition—and it could reshape policy
The United States currently lacks a single, authoritative federal definition of ultra-processed foods used consistently across agencies and programs. The term is everywhere; the standard is not. That gap is exactly what the FDA and USDA say they’re trying to address through their joint RFI published in July 2025.
The mechanics matter. A federal definition can function like a master key. Once a term is standardized, it becomes easier to write rules, craft guidance, and compare research findings without arguing over vocabulary. Even if the definition doesn’t directly ban anything, it can still influence decisions in:
- Nutrition guidance and public education campaigns
- Research standards (what gets measured, and how)
- School meal and food assistance policies
- Labeling debates and consumer-facing claims
- State legislation that looks to federal language for models
The federal process is also continuing. The FDA’s Human Foods Program lists UPFs as a 2026 priority deliverable, noting ongoing work to analyze RFI comments and collaborate with USDA and other partners to develop a government definition.
The mechanics matter. A federal definition can function like a master key. Once a term is standardized, it becomes easier to write rules, craft guidance, and compare research findings without arguing over vocabulary. Even if the definition doesn’t directly ban anything, it can still influence decisions in:
- Nutrition guidance and public education campaigns
- Research standards (what gets measured, and how)
- School meal and food assistance policies
- Labeling debates and consumer-facing claims
- State legislation that looks to federal language for models
The federal process is also continuing. The FDA’s Human Foods Program lists UPFs as a 2026 priority deliverable, noting ongoing work to analyze RFI comments and collaborate with USDA and other partners to develop a government definition.
The paperwork signals the stakes
The RFI’s existence is a tacit admission: the term has outgrown its informal status. When federal agencies invite evidence under an official docket—FDA‑2025‑N‑1793—they’re preparing for a long-lived definition that could travel into rulemaking, guidance, and program design.
A definition may sound like semantics. In Washington, definitions are infrastructure.
A definition may sound like semantics. In Washington, definitions are infrastructure.
In Washington, definitions are infrastructure.
— — TheMurrow Editorial
Why “ultra-processed” is hard to define without collateral damage
Processing is not a single act. It’s a spectrum that runs from washing and freezing vegetables to engineering shelf-stable snack cakes. The definitional problem is that “processing” can describe both how a food is made and what ends up in it—two related ideas that don’t always align neatly.
The FDA and USDA acknowledge this instability directly. Their RFI notes that definitions of ultra-processed foods vary considerably over time, and that classification systems differ in what they label “ultra-processed” or “highly processed.” The agencies are not starting from a settled scientific consensus; they’re stepping into an ongoing dispute.
The FDA and USDA acknowledge this instability directly. Their RFI notes that definitions of ultra-processed foods vary considerably over time, and that classification systems differ in what they label “ultra-processed” or “highly processed.” The agencies are not starting from a settled scientific consensus; they’re stepping into an ongoing dispute.
NOVA dominates the research world—but it’s not universally intuitive
The most commonly cited framework, according to the agencies’ own summary, is NOVA, a system that originated with Brazilian researchers in 2009. NOVA places foods into four groups, with Group 4 designated as ultra-processed.
NOVA’s emphasis goes beyond calories or macronutrients. The FDA/USDA description highlights several factors used to identify ultra-processed foods, including:
- Certain ingredients/substances such as emulsifiers, bulking agents, and thickeners
- Industrial processing technologies
- Sophisticated packaging that helps produce a highly palatable product
That orientation helps explain why the UPF debate can feel mismatched to the way most Americans are taught to shop. People often think in terms of “too much sugar,” “too much salt,” or “too much saturated fat.” NOVA asks a different question: what kind of industrial formulation and processing made the food possible?
NOVA’s emphasis goes beyond calories or macronutrients. The FDA/USDA description highlights several factors used to identify ultra-processed foods, including:
- Certain ingredients/substances such as emulsifiers, bulking agents, and thickeners
- Industrial processing technologies
- Sophisticated packaging that helps produce a highly palatable product
That orientation helps explain why the UPF debate can feel mismatched to the way most Americans are taught to shop. People often think in terms of “too much sugar,” “too much salt,” or “too much saturated fat.” NOVA asks a different question: what kind of industrial formulation and processing made the food possible?
The “healthy foods” problem
The agencies flag a core tension: UPFs overlap heavily with foods high in added sugar, sodium, and saturated fat—nutrients Americans are already advised to limit. Yet ultra-processed categories can also include foods many consumers and clinicians view as beneficial, such as some whole grain products or yogurt. A broad brush definition could create “unintended consequences,” the RFI warns.
That’s not hand-wringing. If a federal definition ends up labeling some widely recommended foods as “ultra-processed,” guidance could become confusing fast—especially for families trying to follow mainstream nutrition advice while managing budgets and time.
That’s not hand-wringing. If a federal definition ends up labeling some widely recommended foods as “ultra-processed,” guidance could become confusing fast—especially for families trying to follow mainstream nutrition advice while managing budgets and time.
What Americans actually eat: UPFs are the majority of calories
The most sobering data point in the current debate is also the simplest: the typical American diet is already dominated by ultra-processed foods as researchers define them.
The CDC’s National Center for Health Statistics reports that, in NHANES data from Aug 2021 to Aug 2023, people ages 1+ consumed about 55% of their daily calories from UPFs. The age breakdown is even sharper:
- Youth (1–18): 61.9% of calories from UPFs
- Adults (19+): 53% of calories from UPFs
The CDC also notes a decline compared with 2017–2018:
- Youth: 65.6% → 61.9%
- Adults: 55.8% → 53%
The direction is encouraging; the level remains striking. A food category supplying more than half of national calories is not easily quarantined by advice like “just avoid it.” Any policy response has to reckon with scale.
The CDC’s National Center for Health Statistics reports that, in NHANES data from Aug 2021 to Aug 2023, people ages 1+ consumed about 55% of their daily calories from UPFs. The age breakdown is even sharper:
- Youth (1–18): 61.9% of calories from UPFs
- Adults (19+): 53% of calories from UPFs
The CDC also notes a decline compared with 2017–2018:
- Youth: 65.6% → 61.9%
- Adults: 55.8% → 53%
The direction is encouraging; the level remains striking. A food category supplying more than half of national calories is not easily quarantined by advice like “just avoid it.” Any policy response has to reckon with scale.
The categories tell a story of modern convenience
The CDC highlights common UPF categories people eat, including:
- Sandwiches (including burgers)
- Sweet baked goods
- Salty snacks
- Sugary drinks
Read that list as a time-use survey as much as a nutrition profile. Ultra-processed food often functions as America’s meal plan: portable, cheap per calorie, and engineered for consistency.
- Sandwiches (including burgers)
- Sweet baked goods
- Salty snacks
- Sugary drinks
Read that list as a time-use survey as much as a nutrition profile. Ultra-processed food often functions as America’s meal plan: portable, cheap per calorie, and engineered for consistency.
Any definition that ignores convenience and cost will describe America’s diet without explaining it.
— — TheMurrow Editorial
The nutrient debate: is UPF just a proxy for sugar, salt, and saturated fat?
A central disagreement sits beneath the definitional project: does “ultra-processed” capture a distinct health risk, or is it mainly a shorthand for foods already known to be high in added sugars, sodium, and saturated fat?
Federal agencies frame the issue carefully. The RFI acknowledges substantial overlap between UPFs and those “limit these nutrients” categories. That overlap matters because it raises a blunt question: if a food is high in added sugar and sodium, do we need a new label—ultra-processed—to tell us what to do?
Proponents of processing-based definitions argue that focusing solely on nutrients can miss the point. A food can be low in one nutrient and still be an industrial formulation designed for maximal palatability and easy overconsumption. Critics counter that a processing lens can be too sprawling—capturing items people rely on for health goals, dietary restrictions, or affordability.
Federal agencies frame the issue carefully. The RFI acknowledges substantial overlap between UPFs and those “limit these nutrients” categories. That overlap matters because it raises a blunt question: if a food is high in added sugar and sodium, do we need a new label—ultra-processed—to tell us what to do?
Proponents of processing-based definitions argue that focusing solely on nutrients can miss the point. A food can be low in one nutrient and still be an industrial formulation designed for maximal palatability and easy overconsumption. Critics counter that a processing lens can be too sprawling—capturing items people rely on for health goals, dietary restrictions, or affordability.
What a federal definition could change in everyday guidance
The public may experience the definition through guidelines and programs, not through a legal code. A federal definition could influence:
- The wording of dietary advice (what gets singled out)
- How public health messaging distinguishes “processed” from “ultra-processed”
- What counts as “better” options within a category (bread, yogurt, cereals)
The agencies themselves acknowledge the risk of misfiring. A definition that sweeps too broadly could discourage foods that are convenient ways to eat fiber-rich grains or fermented dairy—examples the RFI explicitly raises.
The strongest version of the federal project would bring clarity without turning “ultra-processed” into a blunt moral category. That will require a definition that respects how Americans actually eat—and why.
- The wording of dietary advice (what gets singled out)
- How public health messaging distinguishes “processed” from “ultra-processed”
- What counts as “better” options within a category (bread, yogurt, cereals)
The agencies themselves acknowledge the risk of misfiring. A definition that sweeps too broadly could discourage foods that are convenient ways to eat fiber-rich grains or fermented dairy—examples the RFI explicitly raises.
The strongest version of the federal project would bring clarity without turning “ultra-processed” into a blunt moral category. That will require a definition that respects how Americans actually eat—and why.
Key Insight
A federal UPF definition may not ban foods—but it can still steer guidance, procurement rules, research standards, and what “healthy” claims survive scrutiny.
The policy ripple effects: school meals, labeling, and state action
A uniform federal definition doesn’t need to be a prohibition to have consequences. In practice, definitions become tools that institutions reach for—especially in environments where food choices are made at scale.
School meals and food programs: where definitions become procurement rules
If UPF gets defined in federally recognized language, the definition could influence how people evaluate foods in settings like schools and other public programs. The reason is simple: large systems need categories that can be audited. A cafeteria can’t run on vibes. It runs on purchasing specs.
Even the prospect of such a definition can shift behavior. Manufacturers anticipate standards. Administrators anticipate scrutiny. Researchers anticipate that future studies may hinge on which foods officially fall into the UPF bucket.
Even the prospect of such a definition can shift behavior. Manufacturers anticipate standards. Administrators anticipate scrutiny. Researchers anticipate that future studies may hinge on which foods officially fall into the UPF bucket.
Labeling debates: a new frontier for consumer understanding
The definition also could become a reference point in labeling disputes. If a food can be formally described as “ultra-processed,” advocates may push for disclosure or warning-style labels. Industry groups may push back by arguing that nutrient content and dietary patterns matter more than processing labels.
The RFI does not promise a label. It signals that the federal government is preparing a shared vocabulary. The labeling wars—if they come—will likely happen downstream of that vocabulary.
The RFI does not promise a label. It signals that the federal government is preparing a shared vocabulary. The labeling wars—if they come—will likely happen downstream of that vocabulary.
States will watch what Washington writes
State legislatures often borrow federal language when crafting laws or regulations. A federal definition could offer ready-made text for states interested in restricting certain items in public settings or refining nutrition standards. It could also serve as a shield for states that prefer not to act, arguing they will wait for federal guidance.
Either way, a federal definition would not stay in a federal binder. It would travel.
Either way, a federal definition would not stay in a federal binder. It would travel.
Real-world shopping: where “ultra-processed” gets messy fast
Outside of research, the term “ultra-processed” lives in grocery aisles, lunchboxes, and exhausted weeknight routines. The danger of a simplistic definition is that it can turn into a purity test that punishes normal life.
The federal agencies’ own caution about “unintended consequences” is worth taking seriously. Consider the everyday foods the RFI points to as potentially swept into UPF categories—some whole grain products or yogurt. Many families buy those specifically to improve diet quality: more fiber, more protein, fewer desserts, fewer sugary drinks.
The federal agencies’ own caution about “unintended consequences” is worth taking seriously. Consider the everyday foods the RFI points to as potentially swept into UPF categories—some whole grain products or yogurt. Many families buy those specifically to improve diet quality: more fiber, more protein, fewer desserts, fewer sugary drinks.
Case study: the “healthy swap” paradox
A parent tries to swap a sugary breakfast pastry for a whole-grain packaged option. A teenager replaces a candy-like snack with a yogurt cup. These are the ordinary micro-decisions public health messaging has long encouraged.
A broad UPF definition could tell those consumers, in effect, that their “better” choice is still suspect. That may be scientifically defensible in some contexts, but it is politically and behaviorally risky. People do not move from convenience foods to perfectly home-cooked diets overnight. They move in steps.
A broad UPF definition could tell those consumers, in effect, that their “better” choice is still suspect. That may be scientifically defensible in some contexts, but it is politically and behaviorally risky. People do not move from convenience foods to perfectly home-cooked diets overnight. They move in steps.
Practical takeaway: treat UPF as a signal, not a verdict
Until the federal definition arrives, readers can use the debate as a sharper lens rather than a new rulebook. A sensible approach:
- Look for foods that are engineered for constant snacking (highly palatable, easy to overeat)
- Watch the usual suspects—added sugars, sodium, saturated fat—since the agencies note overlap
- Keep an eye on ingredient functions (emulsifiers, thickeners, bulking agents) without assuming they automatically make a food “bad”
- Consider your pattern: a diet where UPFs supply most calories will behave differently than one where they’re occasional
Ultra-processed is a category built for population-level thinking. Personal decisions still have to be livable.
- Look for foods that are engineered for constant snacking (highly palatable, easy to overeat)
- Watch the usual suspects—added sugars, sodium, saturated fat—since the agencies note overlap
- Keep an eye on ingredient functions (emulsifiers, thickeners, bulking agents) without assuming they automatically make a food “bad”
- Consider your pattern: a diet where UPFs supply most calories will behave differently than one where they’re occasional
Ultra-processed is a category built for population-level thinking. Personal decisions still have to be livable.
A sensible way to use the UPF debate (for now)
- ✓Look for foods engineered for constant snacking (highly palatable, easy to overeat)
- ✓Watch added sugars, sodium, and saturated fat since agencies note overlap
- ✓Notice ingredient functions (emulsifiers, thickeners, bulking agents) without assuming they automatically mean “bad”
- ✓Step back and evaluate your overall pattern, not one product at a time
What to watch next: the 2026 timeline and the questions commenters raised
The RFI comment period ended in October 2025 after a 30-day extension from the original September deadline. That tells you the agencies expected significant interest and wanted more time to collect evidence. The FDA’s Human Foods Program listing UPFs as a 2026 priority deliverable suggests the definitional work is now in the stage where comments are being analyzed and translated into usable policy language.
The most important questions are not rhetorical. They are technical, and they will shape the final outcome:
The most important questions are not rhetorical. They are technical, and they will shape the final outcome:
Will the definition be ingredient-based, process-based, or outcome-based?
NOVA leans on ingredients and industrial techniques—emulsifiers, bulking agents, thickeners, certain technologies, and packaging that supports a highly palatable product. A federal definition could follow that model. It could also incorporate nutrient thresholds, or attempt a hybrid.
Each approach has tradeoffs:
- Ingredient/process focus risks catching foods people rely on for health and convenience.
- Nutrient focus risks duplicating existing guidance and missing what makes UPFs distinctive.
- Hybrid approaches can become complicated to enforce and explain.
Each approach has tradeoffs:
- Ingredient/process focus risks catching foods people rely on for health and convenience.
- Nutrient focus risks duplicating existing guidance and missing what makes UPFs distinctive.
- Hybrid approaches can become complicated to enforce and explain.
Will the definition align research with policy—or widen the gap?
Researchers already publish with UPF classifications. Policymakers need standards that can be implemented across massive food systems. A federal definition could bridge those worlds, but only if it is both scientifically defensible and administratively workable.
One clue is the agencies’ own framing: the RFI emphasizes variability across definitions and the possibility of unintended consequences. That is the language of institutions trying to write something that holds up in real life, not just in journals.
A federal definition of UPFs won’t answer every nutrition question. It will decide which questions get asked next.
One clue is the agencies’ own framing: the RFI emphasizes variability across definitions and the possibility of unintended consequences. That is the language of institutions trying to write something that holds up in real life, not just in journals.
A federal definition of UPFs won’t answer every nutrition question. It will decide which questions get asked next.
Editor's Note
The comment deadline for Docket FDA‑2025‑N‑1793 was extended from September 23, 2025 to October 23, 2025, signaling heavy interest—and high stakes.
Conclusion: a word becomes a tool—and tools change behavior
Ultra-processed has functioned for years as an indictment without a statute: a term that sounded official enough to persuade, but flexible enough to mean different things in different hands. The federal government is now trying to give it a stable shape.
The timing is not accidental. With Americans getting about 55% of calories from UPFs—and children approaching 62%—the category has become too central to ignore. The CDC’s small decline since 2017–2018 offers a thin thread of optimism, but it does not change the scale of the issue.
The hardest part will be writing a definition that clarifies more than it confuses. The FDA and USDA have already signaled the central risk: a broad label that sweeps in foods like some whole grain products or yogurt could undermine the incremental improvements most people actually make.
A good definition will not merely sort foods into moral bins. It will help the public and policymakers distinguish between the modern conveniences that support decent diets and the industrial formulations that quietly become the diet. Once the government decides what “ultra-processed” means, the next argument—what to do about it—will have a shared starting point.
The timing is not accidental. With Americans getting about 55% of calories from UPFs—and children approaching 62%—the category has become too central to ignore. The CDC’s small decline since 2017–2018 offers a thin thread of optimism, but it does not change the scale of the issue.
The hardest part will be writing a definition that clarifies more than it confuses. The FDA and USDA have already signaled the central risk: a broad label that sweeps in foods like some whole grain products or yogurt could undermine the incremental improvements most people actually make.
A good definition will not merely sort foods into moral bins. It will help the public and policymakers distinguish between the modern conveniences that support decent diets and the industrial formulations that quietly become the diet. Once the government decides what “ultra-processed” means, the next argument—what to do about it—will have a shared starting point.
T
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. The federal government has not had a single authoritative definition used consistently across agencies and programs. That gap is why the FDA and USDA launched a joint effort in July 2025 to gather evidence toward a federally recognized uniform definition.
What did the FDA and USDA do in 2025, exactly?
In July 2025, the FDA and USDA opened a joint Request for Information (RFI) to collect data and evidence that could support a uniform federal definition of UPFs. Comments were submitted under Docket FDA‑2025‑N‑1793, and the deadline was extended to October 23, 2025.
How much of the American diet is ultra-processed?
CDC/NCHS NHANES data from Aug 2021–Aug 2023 estimates that people ages 1+ got about 55% of daily calories from UPFs. Kids and teens (1–18) got 61.9%, and adults (19+) got 53%—making UPFs the majority calorie source for many Americans.
Is ultra-processed just another way to say “high in sugar and salt”?
Not exactly. The FDA/USDA note that UPFs often overlap with foods high in added sugar, sodium, and saturated fat, but UPF classifications may also include foods that many consider beneficial. The debate is whether “processing” captures additional concerns beyond nutrient amounts.
What is the NOVA system, and why does it matter?
NOVA is a widely used research framework originating in 2009 that groups foods into four categories; Group 4 is ultra-processed. FDA/USDA describe NOVA as emphasizing industrial formulations—often involving ingredients like emulsifiers, bulking agents, thickeners, processing technologies, and packaging that supports highly palatable products.
When might a federal definition be finalized?
A final date is not established in the available information, but the FDA’s Human Foods Program lists UPFs as a 2026 priority deliverable, describing continued analysis of RFI comments and collaboration with USDA and partners to develop a federal definition.
