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US industry panel recommends new UPF policy definition

US-based Healthy Eating Research has proposed an ingredient-based approach to defining ultra-processed foods (UPFs) to make them easier to identify for policy purposes.

The Healthy Eating Research (HER) team set up an expert panel to discuss the latest insights into ultra-processed foods (UPFs) with the aim of developing a clear, easy-to-use definition of UPFs for policy purposes.

Its proposal – an ingredient-based approach – is designed to make it easier to identify UPFs in policy and programme settings while helping policymakers take action to reduce the availability and consumption of UPFs.

UPFs have no definition

Despite growing interest in UPFs among leading health groups, policymakers and the general public, there is still no consensus on how to define UPFs. These foods contain few or no whole-food ingredients and undergo intensive physical and chemical processing to achieve a long shelf life and high sensory appeal.

“Achieving agreement on a clear, evidence-informed UPF definition is especially important for designing effective policies to lower exposure to and consumption of UPFs, and ultimately improving health,” Megan Lott, deputy director of Healthy Eating Research, told Ingredients Network.

The US Secretary of Health and Human Services (HHS), Robert Kennedy, recently said that UPFs may be too complicated to define, following a request for information on UPFs issued in July 2025.

Current UPF-related policies use inconsistent definitions.

“Defining UPFs for policy is very nuanced,” said Lott. “Many of these are not grounded in science and require detailed analyses of all packaged foods and beverages that are impractical for widespread policy implementation.”

The NOVA classification system remains the only validated definition of UPFs, originally developed for research to categorise foods by degree of processing.

“However, this definition cannot be used directly for policy because packaged foods do not include information about processing on their labels,” Lott said.

Panel suggests an ingredient-based approach

Healthy Eating Research’s recommended definition uses ingredient markers to operationalise the NOVA definition, in lieu of details on the level of processing packaged foods and beverages undergo.

The panel’s recommended policy definition states that a food is ultra-processed if it contains cosmetic additives – such as flavours, sweeteners, and colours – or ingredients of non-culinary use, like high-fructose corn syrup, that are not typically found in home kitchens.

In addition, the panel recommends exempting UPF products from policy regulation if they meet a modified version of the Food and Drug Administration’s (FDA) definition of “healthy”.

The Administration’s “healthy” definition refers to foods that contain adequate amounts of recommended food groups, remain below nutrient thresholds for added sugar, sodium and saturated fat, and do not contain non-sugar sweeteners.

The exemption helps avoid capturing UPFs that are often recommended by health professionals or nutrition guidelines as healthy choices, such as some whole-grain breads, tofu, or yoghurt.

By adopting this definition and approach, the panel hopes it will reliably identify the foods it is intended to capture, such as UPFs, while excluding those outside its scope, such as less-processed foods like canned or frozen fruits and vegetables.

“This approach is also practical to implement, without requiring burdensome, product-by-product expert review and is transparent, relying on publicly documented and available data,” Lott said.

Shaping UPF policy in the US

The panel also recommended strategies to reduce the availability and consumption of UPFs. These policies aim to lower exposure to UPFs by influencing their affordability, acceptability and accessibility across different settings and populations.

While policies to reduce the availability and consumption of UPFs are an important strategy for improving the healthfulness of the food supply, the panel emphasised that whether a food or beverage is a UPF reflects one dimension of a food’s overall healthfulness.

“UPF policies are intended to complement, not replace, traditional nutrient- and food group-based approaches to nutrition policy,” Lott added.

Panellists identified how independent policies can work together to shape the overall food and drink sector.

An identity labelling policy, for example, would require all packaged UPFs in stores to bear a label stating, “This product is ultra-processed”.

“This policy is more inclusive and captures all UPFs, as the goal is to provide consumers with important product information,” said Lott.

Other policies could restrict the number of UPFs that consumers can purchase and the number that food operators provide in publicly funded settings, such as schools, childcare sites and government facilities. Governments could also impose excise taxes on selected UPFs, such as soda, which could increase the shelf price of taxed products, reduce sales and lower consumption.

Trading uncertainty for transparency

The panel hopes these recommendations will also encourage more transparency in product labelling and reformulation. New product development is extensive in the industry, with producers consistently creating new ingredients and manufacturers often substituting new cosmetic additives, such as natural flavours and colours.

“But these changes do not reduce the level of processing a product goes through,” said Lott.

Panellists encouraged all ingredients to be listed on food labels and that the US considers requiring the technical functions of ingredients to be listed on product packaging, like they are in the UK.

“As consumer demand for less-processed options increases, we hope the food industry will consider eliminating unnecessary ingredients,” said Lott.

Doing so in healthier products like wholegrain breads and yoghurts would, for example, prevent them from being classified as UPFs in the first place.