Ultra-processed food defined: not all that complicated

14/05/2026 - Marion Nestle
----------------------

Secretary Kennedy promised to define ultra-processed foods by April (after a call for input), but then said it may be too complicated to define these foods for policy purposes.

Apparently not.

Healthy Eating Research convened an expert panel.

It made three recommendations:

I. Definition

A food product is ultra-processed if it contains at least one

Cosmetic additive

Examples: flavors (natural or artificial), emulsifiers, sweeteners (both sugar and non-sugar), colors (natural or artificial), thickeners, bulking agents, gelling agents, glazing agents, carbonating agents, anti-foaming agents, and other additives recognized by FDA or Codex technical classifications.

And/or

Non-culinary ingredient

Examples: casein, dextrose, high-fructose corn syrup, maltodextrin, modified starch, protein isolates (e.g., soy or whey), hydrogenated or interesterified oils, mechanically separated meats, lactose, lecithin, and others.

II. Exempt ingredients

Some ingredients do not mark foods as ultra-processed:

• Vitamins
• Minerals
• Herbs
• Spices
• Yeast-derived ingredients

III. Exempt foods

Foods that meet the FDA’s definition for “Healthy” claims are not considered ultra-processed. These contain:

• Adequate amounts of recommended food groups
• Less than FDA thresholds for added sugar, sodium, and saturated fat
• No non-sugar sweeteners

Using this definition, the panel recommended a broad range of policies to deal with ultra-processed foods. These are worth a look and further discussion. See:

• Executive Summary
• Technical Report
• Partner Toolkit

FDA: take note. This ought to work. Now you can get started on some policy actions!