The Food and Drug Administration and U.S. Department of Agriculture are navigating a three-way divide among stakeholders over how to define ultra-processed foods, with more than 5,000 public comments submitted since the agencies issued a joint request for input nearly a year ago.
The two agencies announced the Request for Information to gather expert and public input on establishing a federal standard for identifying ultra-processed foods. The effort reflects growing interest within the federal government in understanding the role of food processing in diet-related chronic disease, a priority area for the Trump administration’s health agenda.
Three Camps Emerge Over Framework
Commenters have aligned into three broad positions on how the definition should work. One group, including the Environmental Working Group and the Crohn’s & Colitis Foundation, backs adoption of the NOVA classification system, a processing-focused framework developed internationally. The NOVA system categorizes foods by the degree and purpose of processing they undergo, rather than by nutrient content alone.
A second contingent argues for a hybrid approach that combines processing assessment with nutritional metrics. The American Academy of Pediatrics proposed that any definition account for both how foods are processed and their levels of sodium, saturated fat, added sugars, artificial colors and flavors, and energy density. The New York City Department of Health and Mental Hygiene similarly recommended that the agencies weigh ingredients, nutrient levels, and processing methods together.
The third camp disputes the premise that processing alone signals nutritional concern. Industry groups including the USA Rice Federation, National Sorghum Producers, National Pork Board, American Meat Science Association, and International Food Information Council have raised objections to aspects of NOVA, contending that the framework does not fairly account for nutritional quality in processed foods.
Processing Versus Nutrients
The underlying tension centers on whether a definition should prioritize how foods are made or what they contain. The NOVA system focuses on manufacturing processes and their relationship to disease patterns; research linking high ultra-processed food consumption to obesity, diabetes, and other diet-related conditions often uses processing-based metrics.
Consumer Reports raised a specific concern about categorical exemptions, noting that infant formula and medical foods warrant careful review rather than blanket treatment. The UK Department of Health and Social Care referenced its own Scientific Advisory Committee on Nutrition reviews in its submission, underscoring international attention to the issue.
Legal analyst Brian Sylvester noted the challenge facing regulators: “As FDA and USDA recognized in their 2025 Request for Information, there is no single accepted framework for defining ultra-processed foods.”
Implications for Federal Food Policy
A federal definition could influence multiple policy areas, including dietary guidelines, nutrition labeling, school meal standards, and the Supplemental Nutrition Assistance Program. The MAHA movement has prioritized food-system transparency and the reduction of synthetic additives and ultra-processed products in American diets, making this definitional work relevant to the administration’s broader health agenda.
The FDA and USDA have not announced a timeline for synthesizing the comments or publishing a proposed definition. The agencies face pressure to craft a standard that is scientifically defensible, operationally clear for food manufacturers and retailers, and acceptable to stakeholders with competing interests in how foods are classified and regulated.
Learn more about federal food and nutrition policy developments by reviewing recent congressional testimony on SNAP program integrity and the administration’s executive order on regenerative agriculture.