Ultraprocessed Foods and Their Proposed FDA Definition

From health advocacy to policy proposals, the spotlight on ultraprocessed foods (UPFs) has been intensifying. Long the subject of nutritional debate, ultraprocessed products are now in the crosshairs of U.S. regulators aiming to formally define them for the first time. This move is expected to shape everything from food labeling to federal nutrition programs, with wide-reaching implications for food and beverage manufacturers.

Federal Agencies Move to Define Ultraprocessed Foods

On June 10, 2025, FDA officials, in collaboration with the USDA and other agencies, signaled they are closing in on a definition for ultraprocessed foods. Rather than banning these products, regulators see defining UPFs as a first step toward discouraging their consumption and potentially restricting them in federally funded programs like school lunches and SNAP.

“We do not see ultraprocessed foods as foods to be banned… We see them as foods to be defined so that markets can compete based on health.”
— FDA Commissioner Dr. Marty Makary

Makary predicts that a clear definition will spur companies to market products as “non-ultraprocessed,” much like the current use of “no added sugar” claims.

According to the National Law Review, a public comment period will likely precede any finalized rulemaking. The FDA noted that “obvious areas” of focus will include ingredients like synthetic dyes, emulsifiers, and shelf-life-extending additives. While a final definition has yet to be proposed, regulators may look to commonly used academic and international standards, which often flag ingredients that “wouldn’t be found in your own kitchen,” such as artificial sweeteners, high-fructose corn syrup, and hydrolyzed proteins.

The impact could be far-reaching. A federal definition might influence:

• Labeling standards (e.g., “ultraprocessed” or “non-ultraprocessed” callouts)
• Dietary Guidelines and school nutrition requirements
• Eligibility for public food programs like SNAP or WIC
• Marketing claims related to health and ingredient transparency

The FDA’s work follows recommendations from the Make America Healthy Again Commission, which called for a formal UPF definition to support public health policy and reduce chronic disease risk.

Industry Reacts: Anticipating Change Amid Concerns

Manufacturers across the food, beverage, and supplement space are watching closely. Many already face a patchwork of state legislation targeting UPFs and related ingredients.

For example:

• California introduced AB 1264, calling for the phasing out of UPFs from school meals starting in 2028.
• Louisiana introduced Senate Bill 117 calling for the elimination of UPFs from school meals by the 2027- 2028 school year.
• Texas’ Senate Bill 25 is in its final stage of approval and would require warning labels on foods with ingredients banned in other countries and requires deeper research and education on ultraprocessed foods and health impacts.
• Arizona passed House Bill 2164 which bans certain UPFs from school meals

These state-level actions often emphasize the same ingredient groups under federal scrutiny, including artificial colorants like Red 40, preservatives like BHA, and emulsifiers.

Still, many industry voices are urging caution. Critics argue that the UPF category is too broad and subjective, and that a poorly defined regulation could unintentionally target affordable, shelf-stable staples or demonize nutritionally adequate products.

As noted by Food Processing, industry groups are already preparing for pushback if a proposed definition feels overreaching or “ideologically driven.” However, some brands see a competitive opportunity in positioning their portfolios as “non-ultraprocessed”, particularly as consumer demand for cleaner labels continues to grow.

Reformulation is likely to accelerate across categories as manufacturers weigh how to future-proof their products against a potential UPF classification.

How ENTR Can Help

ENTR is designed to help food, beverage, and supplement manufacturers respond proactively to regulatory shifts like this one.

With ENTR, your team can:

• Identify high-risk ingredients — like synthetic dyes, emulsifiers, or artificial sweeteners — that could trigger a UPF classification.
• Track new definitions and legislation — including FDA guidance and state-level rules.
• Reformulate smarter — Test changes and instantly see how your new formula stacks up against evolving regulatory definitions and bans.

Whether you're anticipating federal action or responding to state reform (California, West Virginia, Arizona, and others), ENTR helps you build cleaner, compliant products with confidence and speed.

📩 Need help setting your UPF flags or building state-specific compliance filters?
Contact our team to get started with ENTR.