Has the U.S. Government Finally Defined "Ultra-Processed Food"?
If it feels like "ultra-processed food" has been showing up in your news feed more often lately, it’s not your imagination. What was once a niche term in nutrition science journals has become a fixture of mainstream headlines, congressional hearings, and dinner-table conversation, as researchers, regulators, and consumers alike try to make sense of a food category that now makes up more than half of the average American's diet.
The surge in attention reflects a fast-moving area of scientific inquiry. Large population studies have turned up correlations between higher ultra-processed food intake and a range of health outcomes, from obesity and type 2 diabetes to cardiovascular disease. But correlation is not causation, and science is still working to understand what it all means. Which of those associations hold up? Which processing methods or ingredients might actually be to blame? And how much of what's observed is explained by other factors like income, overall diet quality, or access to fresh food? Only a handful of controlled trials have tested the question directly, and even those, including a 2025 UK study that produced results researchers are still debating, offer a mixed and still-developing picture.
That uncertainty is why a formal definition matters so much. Before regulators can label a product, restrict it from school cafeterias, or study its effects with any precision, they first have to agree on what "ultra-processed" even means, and that effort is playing out in Washington right now.
What was promised and what was delivered
On August 10, 2026, HHS Secretary Robert F. Kennedy Jr. announced that the FDA and USDA had submitted the federal government's first proposed definition of ultra-processed foods to the Office of Management and Budget (OMB) for final review. "Nearly 60% of the American diet is made up of ultra-processed foods, and childhood obesity now affects more than one in five American children," Kennedy said. "We cannot reverse America's chronic disease epidemic without transforming our food system."
But the document FDA and HHS sent to the White House on August 3rd met scrutiny for two reasons: firstly, it arrived four months after it was promised, and secondly, it is a white paper, a position document that lays out the government’s thinking without the legal force of a regulation; in other words it can shape the conversation and guide future policy, but doesn’t by itself create any type of restriction or requirement. Whether this becomes an enforceable rule, the kind that could dictate food labels or school lunch menus, still depends on what the FDA and USDA do next.
Why a definition matters
Right now, "ultra-processed" doesn't have one agreed-upon meaning. The most common approach, called NOVA, was created by Brazilian researchers in 2009. It sorts food by how much it's been altered, reserving "ultra-processed" for products with ingredients you'd never find in a home kitchen, certain preservatives, artificial flavors, or highly refined sweeteners.
Critics, however, point to certain flaws: NOVA lumps a sugary soda in with fortified whole-grain bread, even though those foods aren't nutritionally alike. Studies have found that some items like whole-grain "ultra-processed" products don't carry the same health risks as sugary drinks or processed meats.
What Does the Evidence Actually Show?
Two experiments stand out because researchers carefully matched what was on offer, same calories, fat, sugar, and other nutrients on paper, while letting people eat as much or as little as they wanted. That design sought to isolate the effect of processing itself.
In a 2019 NIH study, 20 adults were offered an ultra-processed diet for two weeks and an unprocessed diet for two weeks, both matched for calories and nutrients, and told to eat as much as they liked. On the ultra-processed diet, people ate about 500 extra calories a day without trying to and gained about two pounds; on the other diet, they lost the same amount. It's a small study, but it's the closest thing scientists have to proof that processing itself can drive people to overeat.
A 2025 UK study, using the same ad libitum approach, found people lost about twice as much weight eating minimally processed food versus ultra-processed food over eight weeks, even though both diets followed the same healthy-eating guidelines. Some researchers have since challenged how those results were calculated, so they are far from conclusive.
What the food industry is saying
Big food companies argue that regulators should define "ultra-processed" using nutrient content, sugar, sodium, fat, calories, rather than how a food was made. But this means relying on the same kind of metrics already used on the Nutrition Facts label, which has told shoppers about sugar, fat, sodium, and calories for thirty years, rather than creating a new standard based on growing evidence.
The Consumer Brands Association called the incoming definition fundamentally flawed and "politically motivated," warning it could sweep up nearly 80% of the food supply and raise grocery costs.
However, it's also worth knowing who's funding the pushback: the Consumer Brands Association backs a lobbying campaign whose members include Coca-Cola, General Mills, Kraft Heinz, Nestlé, and PepsiCo, companies with a direct financial stake in the final definition being as narrow as possible.
Congress and California Aren't Waiting for a Third Definition
California already passed its own law defining ultra-processed foods and phasing them out of school meals by 2035. Congress is moving too: a Senate bill advanced in July would require warning labels on ultra-processed products, though it leaves the actual definition to be written later. That means at least three different definition efforts, federal, state, and congressional, are underway at once, with no guarantee they'll agree. For food companies and shoppers alike, that risks a set of mixed messages instead of one clear standard.
How Should Shoppers Think About Processing Now?
You do not need to wait for Washington to eat well today:
Focus on the worst offenders first. The categories where the cohort evidence is strongest, sugary drinks, processed meats, sweet baked goods, savory snacks, are also where the CDC says most ultra-processed calories actually come from.
Use the kitchen test. If an ingredient list is full of substances you would never find in a home kitchen, NOVA would call it ultra-processed.
Don't equate "processed" with "unhealthy." Harvard's guidance is to emphasize minimally processed foods, which “have been slightly altered so they can be more easily stored, prepared, and eaten; this processing level does not substantially change the nutritional content of the food. Examples include cleaning and removing inedible or unwanted parts, grinding, refrigeration, pasteurization, fermentation, freezing, and vacuum-packaging.”
Read ingredient lists, not just front-of-pack claims. Our guide to decoding food labels covers which claims are regulated and which are marketing.
What CRFB Recommends
A definition is an essential measurement tool; you cannot research, label, or litigate what you cannot define. This is exactly why the definition must be built to survive scrutiny. We recommend that FDA and USDA:
Clarify the legal path forward. Government agencies should state plainly whether and when the white paper will be converted into binding regulation, and commit to a public comment period before finalization.
Keep the process visible. For months, there was no public way to confirm this proposal was even under White House review since the only information came from officials' own announcements. Now that it has been formally filed, anyone can check its status on the government's public regulatory tracker rather than waiting on press releases. FDA and USDA should keep building on that transparency, disclosing the meetings and input that shaped the definition, especially given the documented industry effort to narrow it.
Ground the definition in the strongest evidence, distinguishing nutrient-poor ultra-processed categories from healthful foods that are a product of more minimal processing.
Shield the science from industry influence. The scientists whose work underpins this definition, inside and outside government, must be able to publish findings that cut in any direction.
Align to expedite progress. With Congress advancing its own UPF-definition mandates and California enforcing its own statutory definition, a federal standard that doesn't reconcile with either one adds another conflicting rulebook instead of resolving the confusion it was meant to fix.
In a country with significant rates of food-related chronic disease, the stakes are high, and so is the risk of getting the definition wrong, or leaving it toothless, a dynamic we have examined in how the food and pharmaceutical industries reinforce each other. A rigorous, transparent, and enforceable definition would serve consumers, companies, and science alike. A politicized or purely symbolic one will serve no one for long.