As we previewed in a recent post, ultra-processed foods (UPF) are about to take center stage in U.S. food policy. In June, the U.S. Food and Drug Administration (FDA) announced it would soon publish a Request for Information (RFI) on how to define UPF – a move with potentially sweeping implications for the food industry. The RFI was submitted to the Office of Management and Budget on June 30, and FDA Commissioner Marty Makary confirmed its imminent release (along with a forthcoming industry roundtable) in a July 10 statement.
This action comes amid growing momentum: the 2025–2030 Dietary Guidelines for Americans are widely expected to advise limiting UPF, and the newly announced FDA–NIH Nutrition Regulatory Science Program is set to investigate how and why UPFs may impact health. In short, the barriers to federal regulatory action around these foods are quickly falling away.
For food and beverage leaders, this is a critical moment — and a unique opportunity — to help shape how UPF are defined and understood. The FDA’s eventual position could more broadly impact food and nutrition policy by:
- Preempting or influencing state legislation that seeks to restrict UPF in schools
- Informing the FDA’s front-of-pack labeling (FOPL) final rule and other nutrition and health claim updates
- Affecting product eligibility for inclusion in nutrition programs like school meals, the Supplemental Nutrition Assistance Program (SNAP), and the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
- Setting the stage for future marketing and food reformulation limits (voluntary or mandatory)
The FDA’s definition will matter. And food and beverage leaders need to be part of the conversation.
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What Could Happen — and How You Can Prepare
At Global Food IQ, we’ve been tracking this issue closely and offer the following ideas to guide your engagement. Whether you’re just beginning to assess the issue or already deeply involved, we are here to help with scenario planning, strategy development, and/or comment submissions.
Here’s how to get started:
- Assess Your Position
Begin by mapping how your portfolio is likely to be categorized under existing UPF definitions, such as NOVA or recent state bills. What ingredients or processes are commonly flagged? Where could reformulation make a difference? A clear-eyed view of risk and opportunity will help define your advocacy strategy.
- Evaluate Whether Existing Approaches Could Work
In some cases, current definitions might be workable with some adjustments. Consider whether previously developed frameworks from IFIC, Siga, or the newer Tufts Food Compass contain feasible elements. Could one of these be a reasonable foundation or a strategic reference point for FDA’s consideration?
- Explore the Case for a New Definition
Alternatively, it may be time to support the development of a more practical, science-based alternative. Consider engaging with ongoing projects supported by the Institute for Advancement of Food and Nutrition Sciences, the Novo Nordisk Foundation, the International Union of Food Science and Technology, or even starting from scratch.
Creating a better definition may seem daunting, but there’s some precedent set by nutrient profiling systems that have successfully informed global FOPL rules, marketing regulations, and reformulation programs. Key considerations for creating a new UPF definition might include:
- Nutrition quality and alignment with global dietary guidelines
- Policy coherence with existing food safety and nutrition labeling standards or definitions
- Evidence-based treatment of ingredients and processing methods, recognizing their importance and their proven benefits (including data on absence of harm)
- Complementary labeling enhancements that provide additional transparency and reflect clean label improvements already in place and in progress
- Highlight Evidence Gaps and Research Needs
Support your position with science. Several critiques of the NOVA system already exist, and recent studies — including research roadmaps — point to significant gaps in our understanding of how UPFs may relate to health outcomes. Highlighting what we truly understand and don’t, especially in relation to causality, will be key to grounding the FDA’s eventual approach in science rather than soundbites.
- Communicate Business and Consumer Impact
No matter your position, it’s essential to help FDA understand the real-world implications of any future decision. Estimates suggest that 60–70% of the U.S. food supply could be considered ultra-processed under the NOVA definition — including many products that are safe, nutritious, and aligned with core consumer needs.
Processing exists for good reasons: safety, shelf life, affordability, convenience, and nutrient delivery, to name a few. Make that case. Bring data. Share real examples. Clarify how sweeping restrictions could affect consumers and business viability alike.
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Why It Matters — and Why Now
What’s essential is not just criticism — but contribution. We don’t expect efforts to completely reject the concept of UPF to succeed. The term has gained traction among political leaders, public health groups, and consumers. Beyond pointing out flaws in current definitions, what’s needed is credible, constructive input that would help FDA make a smart, durable decision that is beneficial for public health and reflective of business realities.
Whatever your stance, don’t sit this one out. The FDA’s upcoming definition could become one of the most consequential U.S. nutrition policy decisions in decades — with ripple effects globally. For example, it may influence the World Health Organization’s forthcoming guideline on UPF consumption.
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If you need support evaluating your options or shaping your response, Global Food IQ is here to help. Reach out to explore how we can support your regulatory strategy, communications, and science-based positioning in this fast-evolving space.
