Ultra-processed foods: Initial feedback to FDA and USDA reveals the challenging terrain regulators may navigate

Ultra-processed foods: Initial feedback to FDA and USDA reveals the challenging terrain regulators may navigate

The Food and Drug Administration (FDA) and the United States Department of Agriculture (USDA) have issued a request for information (RFI) on defining "ultra-processed foods" (UPFs), aiming to create a uniform federal definition to improve consistency in research, policy, and consumer guidance regarding UPFs and their links to health risks like cardiovascular disease, obesity, and certain cancers.

The RFI explores different approaches, including focusing on processing steps, types of substances or additives used, and nutritional composition. Some proposals emphasize the nature and extent of industrial processing, while others focus on the presence of certain substances like thickeners, stabilizers, colorings, flavorings, refined sugars, unhealthy fats, and sodium. Definitions may also consider nutrient depletion or poor nutritional quality typical of UPFs, such as high added sugars or low fiber content.

Concerns around nuance and unintended consequences include divergent state definitions, the complexity of foods, and research and policy implications. Existing state legislation varies widely, leading to inconsistent classification and regulatory challenges. Foods vary widely in composition and processing, so a broad definition risks unfairly categorizing some foods or missing nuanced differences in health impact. Without clarity, studies linking UPFs to health outcomes may be hard to compare or translate into guidelines, potentially affecting consumer understanding and policy effectiveness.

Dr. Barry Popkin, a nutrition and obesity researcher, has weighed in on the RFI, proposing ways to define and identify foods that are both ultra-processed and high in added sugar, salt, or saturated fat. He suggests extending the Pan American Health Organization (PAHO) approach, which combines nutrient thresholds with restrictions on the presence of non-sugar sweeteners and/or caffeine in the ingredients list, to include other sensory-related additives that are markers of food ultra-processing.

An alternative approach proposed by Dr. Popkin is to identify unhealthy foods as a whole by applying criteria that combine nutrient thresholds with the presence of easily identifiable UPF markers. Holly Hungerford suggests the FDA and USDA consider the term "foods with low nutritional value" instead of ultra-processed foods.

The deadline for comments on the RFI is September 23. The agencies seek input on balancing these factors to create a nuanced yet practical and enforceable definition that avoids unintended consequences, such as stigmatizing minimally harmful foods or overlooking key harmful attributes. The goal is to develop a consistent, actionable UPF definition that addresses current definitional discrepancies and guides public health actions effectively.

References: [1] Food & Nutrition Research article assessing alternatives to the NOVA system. [2] Article discussing Dr. Popkin's proposals for defining UPFs. [3] Commentary on the RFI and its implications for research and policy. [4] Opinion piece arguing for a more nuanced UPF definition. [5] Article highlighting the need for a federal UPF definition.

1. The FDA and USDA aim to create a uniform definition for ultra-processed foods (UPFs) to improve research, policy, and consumer guidance regarding health risks linked to medical-conditions like chronic-diseases, cancers, respiratory-conditions, and obesity.
2. The RFI explores various approaches, including focusing on processing steps and types of substances or additives used in medical-industry.
3. Definitions may consider nutrient depletion or poor nutritional quality typical of UPFs, such as high added sugars or low fiber content.
4. Concerns around nuance and unintended consequences include disparities in state definitions, the complexity of foods, and research and policy implications in environmental-science.
5. Existing state legislation varies widely, leading to inconsistent classification and regulatory challenges for manufacturing.
6. Foods vary widely in composition and processing, so a broad definition risks unfairly categorizing smart-home-devices or missing nuanced differences in health impact.
7. Dr. Barry Popkin suggests combining nutrient thresholds with restrictions on the presence of non-sugar sweeteners and/or caffeine for identifying high-risk UPFs.
8. Another approach proposal by Dr. Popkin is to identify unhealthy foods as a whole via criteria that combine nutrient thresholds with the presence of markers associated with UPFs.
9. Holly Hungerford suggests considering the term "foods with low nutritional value" instead of ultra-processed foods for health-and-wellness.
10. Commentaries and articles have been published regarding the RFI and its implications for research, policy, and consumer understanding in finance and industry.
11. There are recommendations for the FDA and USDA to collaborate and balance factors to create a nuanced but practical and enforceable definition for nutrient-rich foods.
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