Written by: Yasmine Wehbi, HER Student Worker

Ultraprocessed foods (UPFs) have become a growing focus of public health research and policy due to an increasing body of evidence suggesting that diets high in UPFs are associated with poor health outcomes. Yet, despite increased attention, there is no widely accepted definition of UPFs that can be operationalized for policy purposes. Establishing a clear, evidence-based definition is an important first step toward developing effective policies aimed at reducing consumption of UPFs and improving public health.

To help address this gap, Healthy Eating Research (HER) convened an expert panel, led by Drs. Jim Krieger and Lindsey Smith Taillie, to develop evidence-based recommendations for policymakers and advocates to consider as they advance policy actions to limit UPF exposure and consumption. The panel included 14 experts in nutrition, food science, epidemiology, nutrition policy, food law, policymaking, and advocacy. The panel’s Technical Report provides a comprehensive review of the evidence and methodology behind the recommended UPF definition and outlines policy options that can help lower UPF exposure and support healthier food environments.

For policy use, the panel recommends a science-based, transparent, and practical definition. The panel recommends using the Nova Classification system as the scientific basis for a policy because almost all studies linking UPFs to adverse health outcomes use the Nova Classification system. As such, a product is a UPF if it contains at least one ingredient marker for Nova Category 4 (i.e., a cosmetic additive and/or an ingredient of non-culinary use).

Here, we answer five frequently asked questions about UPFs, our report, and what it means for researchers, advocates, and policymakers:

What makes a food ultraprocessed?

Ultraprocessed foods are industrial formulations that contain few or no whole-food ingredients and have undergone intense chemical and/or physical processing methods, such as hydrolysis, molding, and pre-frying. They are designed for profit because of their long shelf life, low cost, sensory appeal, and convenience. Examples include sugar-sweetened beverages, instant noodles, and processed meats.

UPFs are often high in added sugars, fats, and salts and also contain ingredients of exclusive industrial use (i.e., not used in home kitchens) and cosmetic additives that enhance the sensory quality of products.

Classic definitions of UPFs do not always align with what we consider healthy. For example, some whole-grain breads are classified as UPFs because they contain ingredients such as emulsifiers, flavors, or even non-sugar sweeteners, yet, plain potato chips are not considered UPFs because they contain only potatoes, oil, and salt. Once flavors or colors are added, such as in BBQ potato chips, they are considered ultraprocessed.

Why are ultraprocessed foods a public health concern?

A growing body of research links UPF consumption with an increased risk of adverse health outcomes, including cardiovascular disease, all-cause mortality, type 2 diabetes, obesity, depression, and anxiety. The U.S. has one of the highest levels of UPF consumption in the world, making this issue a public health concern.

Many UPFs also contain nutrients of concern such as added sugars, saturated fat, sodium, and refined carbohydrates. Consuming these nutrients in excess is also linked to an increased risk of diet-related chronic conditions. Furthermore, UPFs meet scientific criteria for addictive substances by triggering intense cravings, altering mood through reward pathways, and leading to compulsive intake. Cosmetic additives likely amplify this effect.

Research on the mechanisms by which UPFs affect health is still developing; however, existing data indicate UPFs affect the body via multiple pathways. In addition to the nutrient content, factors such as the way foods are industrially formulated, changes to their natural food structure, and the use of certain additives may also contribute to health outcomes.

How does HER’s recommended definition differ from previous approaches?

HER’s recommended UPF definition is based on the Nova Classification System, providing a clear, scientific foundation for a definition that can be applied across a variety of policy contexts and settings.

The panel recommends that a product is ultraprocessed if it contains at least one ingredient marker linked to Nova Category 4, such as a cosmetic additive and/or an ingredient of non-culinary use. These ingredient markers are listed in detail in the full technical report. This ingredient-based approach is practical, accurate, easy, transparent, and science-based, making it preferable to other techniques for identifying ultraprocessed foods.

The panel also recommends a unified framework for exempting “better for you” products from policies targeting UPFs if they meet a modified version of FDA’s definition for “Healthy” claims. In order to be exempt from UPF policies, products must (1) contain sufficient amounts of recommended food groups, (2) stay below limits for added sugar, sodium, and saturated fat, and (3) not contain non-sugar sweeteners.

This exemption helps avoid capturing UPFs that are recommended by dietitians or nutrition guidelines as healthy choices, such as some whole-grain breads, ready-to-eat breakfast cereals, tofu or yogurt. Some products can be both UPF and FDA “Healthy” because the two systems assess different qualities: processing level versus nutrient profile. For example, whole-grain bread can meet FDA’s established nutrient criteria and contain the minimum ounces of whole grains per serving for the “Healthy” designation, yet still include emulsifiers or dough thickeners, which are UPF ingredient markers.

Can this definition work for policy?

HER’s definition was designed with policy implementation in mind. The expert panel sought to create a definition that is evidence-based, consistent, and practical for real-world use. The resulting definition performs well across a range of policy-relevant criteria, including alignment with scientific evidence, diagnostic accuracy, reproducibility, transparency, practicality, independence from conflicts of interest, and flexibility for use across different policy contexts.

The panel also recommends a range of policy options to target different sets of UPFs, acknowledging that not all settings require the same regulatory approach. For instance, a labeling policy may aim to be inclusive and capture all UPFs, with the goal of providing consumers with information about the product. In contrast, a tax policy, such as a sweetened beverage tax, may result in higher prices, leading to fewer purchases. A consistent definition allows these policies to be developed using the same scientific foundation while adapting to different policy objectives.

The panel also considered practical challenges of implementation, such as the need to create, maintain, and update ingredient lists in a large and rapidly evolving food supply, and to address potential industry reformulation to evade classification as UPF. The Technical Report outlines strategies to address these challenges and to support the implementation of a strong UPF definition.

What comes next?

Defining ultraprocessed foods for policy is an important step towards creating healthier food environments. Our Technical Report outlines a range of policy options that could help reduce UPF exposure, while recognizing that different approaches vary in their potential impact and feasibility. The report also emphasizes the importance of considering equity when developing policies. While some policies can help reduce inequities in UPF exposure and consumption, others might have unintended effects if they are not carefully designed.

UPF-focused policies are intended to complement, not replace, traditional nutrient- and food group-based approaches to nutrition policy. Together, these approaches can help create healthier food environments and make nutritious choices easier for everyone.

At this time, the first proposed federal definition of ultraprocessed food is under review at the White House Office of Management and Budget and could be released any day. This presents an opportunity to enact policies backed by science and improve consumer understanding of UPFs.

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Ultraprocessed foods (UPFs) make up a substantial share of the U.S. diet, and a growing body of research has linked higher UPF consumption to a range of adverse health outcomes. As interest in UPFs continues to grow among researchers, policymakers, and the public, the lack of a clear and consistent definition has posed challenges for policy development and evaluation.

Developing a practical, evidence-informed definition of UPFs for policy is an important step toward creating a common framework for understanding and addressing these foods within the food system. The HER expert panel’s recommendations are intended to support greater consistency and transparency in how UPFs are identified and studied across policy contexts.

As the evidence base evolves, the panel’s recommendations can help inform ongoing discussions about how UPFs are defined, measured, and incorporated into research, policy, and practice.

To learn more, check out HER’s Technical Report, Webinar Recording, and additional resources such as this new fact sheet for consumers, AJPH’s Special Issue on Ultraprocessed Foods, and the Fed Up! Movement.