Member Matters
Defining ultra-processed foods: momentum builds in the US
21 July 2026
The review of the draft Australian Dietary Guidelines is expected in the second half of 2026. There is considerable interest from stakeholders in how foods may be classified within the revised guidelines, including whether and how concepts related to the NOVA food processing classification system may be incorporated. Against this backdrop, a recent article (1) in JAMA Health Forum provides interesting insight into policy developments in the United States, where governments are increasingly exploring definitions of ultra-processed foods (UPFs)* for use in public health policy.
Key developments in the US
At least 17 US states have proposed or introduced laws to define UPFs, especially for school food policies. The approaches differ widely and are inconsistent. Some states focus on specific additives, while others use broader definitions based on industrial ingredients and processing methods.
For example, Arizona’s law defines UPF as a food that contains any of 11 listed additives, including titanium dioxide and yellow dye 5. The authors describe this as a narrow approach because it may only capture a small share of UPFs, which could limit its public health impact.
Other states, including California and Pennsylvania, use broader definitions. These are mainly based on US Food Drug Administration (FDA) rules that cover ingredients added for cosmetic, physical or technical purposes. Additionally, both states include extra criteria. Pennsylvania focuses on ‘unhealthy’ UPFs by referring to the FDA rules for ‘healthy’ claims, which set minimum requirements for ingredients such as vegetables, fruit, whole grains, dairy and protein foods, and limits for added sugar, sodium and saturated fat. California takes a different approach. It adds only nutrient criteria (not food groups), so a product may be treated as UPF if it is also high in sodium, added sugar or saturated fat, or contains sugar alcohols.
Points of interest for the food industry
The debate is moving beyond traditional nutrient-based policy approaches and increasingly focusing on food processing and ingredient functionality. Policymakers are considering a range of criteria, including additives, emulsifiers, stabilisers, flavouring agents and other ingredients that perform technical functions in foods. Different definitions are creating varying regulatory obligations across jurisdictions, adding complexity for food manufacturers operating across multiple markets.
The authors argue that definitions that combine processing-based and nutrient-based criteria may create opportunities for product reformulation that would allow some products to fall outside a UPF definition while remaining highly processed. The article also raises concerns that inconsistent definitions could contribute to consumer confusion about what does and does not qualify as a UPF.
Why it matters
The article highlights a growing international policy focusing on food processing as a regulatory concept, rather than nutrient composition alone. While the paper is based on developments in the US, it provides a useful indication of the policy directions being explored globally and the challenges governments face when attempting to translate the NOVA** framework into legislation. These developments may be relevant to future discussions on dietary guidance, food classification systems and food policy in Australia.
*AFGC does not support the use of the term “ultra-processed foods”, or the view that a food’s nutritional profile should be assessed primarily by its level of processing rather than its nutrient composition.
** The NOVA food classification system groups foods according to the extent and purpose of processing, from unprocessed or minimally processed foods through to ultra-processed foods made using industrial formulations and processes.
Reference:
- Pomeranz JL and Mozaffarian D. “State Actions to Define Ultraprocessed Food for Policy—Opportunities and Challenges”, JAMA Health Forum, April 2026.
