Fruit Loops, photograph by Ted Kyle

Defining Ultra-Processed Foods: Will FDA Do It Better?

FDA Commissioner Marty Makary believes that defining ultra-processed foods is the key to overcoming the health problems these products produce. He recently told the New York Times:

“We do not see ultra-processed foods as foods to be banned. We see them as foods to be defined so that markets can compete based on health.”

So nope. FDA will not be taking away your Fruit Loops. Instead, the agency will define them as ultra-processed (or not) and let you decide if you want to keep feeding them to your kids.

The real question is: Will FDA do a better job with defining ultra-processed foods than scores of nutrition scientists who are already trying?

Dissatisfaction with NOVA

The most common tool for defining ultra-processed foods is the NOVA classification system. On the surface, it seems simple enough. But dissatisfaction is easy to find. In a new perspective for the New England Journal of Medicine, Darius Mozaffarian explains the core problem:

“Harms have been more consistently identified for sugar-sweetened beverages, processed meats, ready-to-eat or ready-to-heat meals, refined breads, and sauces and condiments than other UPF (ultra-processed food). In contrast, UPF made with more healthful, less-processed ingredients – such as whole grains, fruits, vegetables, legumes, or yogurt – generally have neutral or positive health associations.

So if the goal is to tell people how to eat more healthfully, simple advice to avoid ultra-processed food has some real issues. Simply because the definitions are slippery.

No Obvious Replacement

In Food & Nutrition Research, Anine Christine Medin and colleagues have published a new systematic review and evaluation of alternatives to the NOVA system. They found five potential alternatives, but concluded that even the best of them – a system called Siga – has issues.

So perhaps FDA can do better than NOVA does for defining ultra-processed foods. But issues will likely remain.

Click here for more from the Times, here for Mozaffarian’s commentary, and here for Medin’s systematic review.

Fruit Loops, photograph by Ted Kyle / ConscienHealth

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July 7, 2025

One Response to “Defining Ultra-Processed Foods: Will FDA Do It Better?”

  1. July 07, 2025 at 6:38 am, Charles Benbrook said:

    Yes, the NOVA system is flawed. It does differentiate with reasonable accuracy between fresh foods and highly processed foods, but it does not get to the core of how food manufacturing and processing alters food nutritional quality and safety. HHRA (hh-ra.orf), in comments that will be submitted to the FDA in a week or so, is recommending a definition of UPF food grounded in two key aspects of food nutritional quality and safety impacted by processing and recipes: (1) what the manufacturing/cooking process does to the nutrients in the raw ingredients required to make a sering of a given finished food product, and (2) what is added to the food product in the manufacturing/cooking process. A better approach can be developed drawing on the food processing metrics in the proposed NuCal system (see the open access paper in Foods by Benbrook and Mesnage, https://www.mdpi.com/2304-8158/13/21/3377). The metrics include the % of the essential nutrients in a serving of food that come from the raw ingredients needed to make the serving (higher is better), the % of the essential nutrients in a serving of food that come from supplements and additives (lower is better), and the number, volume, and potential toxicity of additives. Overtime, research will need to quantify the impact of food manufacturing processes (e.g. oil extraction methods) on food quality and safety. But FDA needs to begin a serious, science-driven process leading to methods to quantify both food nutritional quality per serving, and the degree of processing, to support its new front-of-pack labeling scheme. The current proposal from the FDA/last administration is not going to make much difference (and they admit it), it just repeats well known facts re salt, sugar, and fat. Just another billboard won’t move that mountain. Chuck Benbrook