Over the past five years, the national conversation around health and nutrition has become dominated by the term ‘ultra-processed foods.’ Most prominently, Health and Human Services Secretary Robert F. Kennedy Jr.’s MAHA movement blames these foods for a host of chronic health issues and has launched an often-contradictory campaign to remove some UPFs from the food supply.
But there’s a glaring problem: Nobody can agree on how, exactly, to define ultra-processed foods. The lack of a clear definition has stymied legislative and regulatory efforts to curb UPF consumption, and caused confusion for people evaluating their own diets.
This spring, a panel of 14 nutrition, food science, policy and legal experts gathered to create a more practical and operational definition. The panel’s final report, published in May, suggests an ingredient-based approach to identify ultra-processed foods, while also recommending a series of policies to reduce people’s exposure to them.
The panel was co-chaired by Jim Krieger, clinical professor emeritus of health systems and population health at the UW and executive director of the nonprofit group Healthy Food America. UW News sat down with Krieger to discuss the new definition, the debate around ultra-processed foods and how people can limit their consumption.
How have we traditionally defined ultra-processed foods, and where does that definition fall short?
Jim Krieger: The ultra-processed food concept was developed by Carlos Monteiro, who’s a physician and epidemiologist at the University of Sao Paolo in Brazil. He was trying to understand an increase in obesity and chronic disease rates, particularly in kids and young adults, and noticed some important changes in the diet that weren’t fully explained by just the usual nutrient profiling — like fat, sugar, salt. Monteiro came up with this concept of ultra-processed foods. The categorization system is called Nova, which means ‘new’ in Portuguese, and classifies foods across a spectrum beginning with unprocessed ingredients and ending in ultra-processed. Ultra-processed foods are the ones that are the most highly processed industrial products, basically.
The Nova definition is geared toward research, to really examine the effects of ultra-processed foods on a range of health outcomes. Using it, numerous studies have found ultra-processed foods to be associated with a whole host of health problems, like diabetes and heart disease and depression. That’s the basis to say, well, there’s probably sufficient evidence to figure out what we can do to reduce exposure to ultra-processed foods by reducing sales and consumption. That requires policy, and to have policy you need to have a definition of ultra-processed food that’s suitable for regulation or legislation, and that’s where the rub comes. The definition for research doesn’t really work in a policy context, because the Nova research definition uses multiple factors, including ingredients, processing techniques, and other factors to identify products as ultraprocessed. Applying Nova can require individual-level review of ambiguous products by skilled nutrition experts that may not be feasible in policy contexts.
You co-chaired a panel of 14 experts who came up with a new definition. What did that work look like, and what’s your new definition?
JK: We tried to come up with a simple definition that could be used in practice. We said the starting point, scientifically, is Nova, because that’s where there’s evidence linking UPFs to harms. But we wanted to come up with a way to identify products that would meet Nova classification using only ingredients on nutrition labels, which is a much more feasible approach compared to the method used in research studies.
We went through a fairly technical process. We got a database of all packaged foods in the U.S., looked at all the ingredients in there and cross-referenced them with technical functions that are listed in Nova’s definition — emulsifiers, coloring agents, sweeteners, things like that. We also considered a bunch of nonculinary ingredients, which are the ones you wouldn’t use in your kitchen, like hydrolyzed protein and modified starches. This let us develop a list of “marker” ingredients found in UPFs.
Under our definition, if a product has just one of these marker ingredients, then it is ultra-processed food. Now in reality, very few ultra-processed foods ended up having only one marker. Most had three, four, five or more. We also found that this approach successfully identified 98% of all UPFs.
One criticism of the movement against UPFs has been that some foods that are technically ultra-processed are actually quite nutritious. I’m thinking of products like yogurts, whole-grain breads and tofu. How does your definition account for that?
JK: You want your definition to be sensitive enough to pick up most UPFs, but also specific — that is, not capture foods that are not truly UPFs or even those that can be part of a healthy diet. The way we addressed that was the FDA, a couple years ago, developed criteria for what they call a ‘Healthy’ claim. If a company wants to say its products are healthy and put that on the package, it has to meet FDA-approved criteria.
We decided that even if a product is ultra-processed, if it meets the FDA’s criteria for a ‘Healthy’ food, then it should be exempted from policy. That cuts out edge cases — healthier foods that are also UPFs.
Your final report also dives into policy and makes recommendations for lawmakers to consider. What is the current status of ultra-processed food policy across the U.S.?
JK: Over the last couple of years there has been a flurry of activity, particularly at the state legislative level. Some states say they’re getting rid of ultra-processed foods in school meals, for example, but they have a somewhat random list of ingredients or additives they don’t like.
A few states have tried to take a more evidence-based approach. The best example of that is California, where they passed legislation to phase out ultra-processed foods in school meals. They used the same kind of ingredient-list approach that we recommend, simplified a little bit. However, for a food to be a UPF under California’s definition, it must also be high in fat, sugar or salt, which raises a problem — about 35% of all ultra-processed foods do not have those levels. Proposed legislation in states like Pennsylvania have avoided this problem by sticking with the Nova-based definition, as recommended by our expert panel, rather than adding on fat, sugar and salt criteria.
There’s also been a huge amount of movement in a couple of countries, especially in Latin America. Furthest along is Colombia, where the government just issued a regulation to require ultra-processed food labels on packages. They’re basically using the Nova definition as well.
There are policies moving now, which is why we felt it was important to say, use a good definition of ultra-processed for what you’re doing, and then think about certain policy ideas as the best bets for doing something about the problem. For us, those ideas include requiring labels on packages identifying a product as ultra-processed and removing UPFs from food served in schools, childcare and in government facilities.
Many of the factors that lead people to choose ultra-processed foods are systemic. As an example, food deserts leave some people without easy access to affordable fresh foods. How did the panel consider those factors in making your policy recommendations?
JK: Increasing access to healthy foods gets into another set of policies that are well-described and, to varying extents, are being put into place. Our panel focused specifically on UPF policies. We did assess whether any of our policy recommendations would have unintended consequences of making food less available or affordable for people with low incomes and then we figured out strategies for mitigating those effects.
A great example would be if you tax even a subset of ultra-processed foods, that’s going to make them less affordable, and that’s a challenge. We recommend that the tax revenues raised from these policies go toward vouchers or incentives for people with lower incomes that they can cash in for fruits and vegetables at a more affordable price.
We also rejected some policy ideas. One was restricting the use of SNAP (the Supplemental Nutrition Assistance Program, commonly known as food stamps) benefits for purchasing ultra-processed foods. We felt that would have too much of a negative impact on food affordability for people using SNAP, so we did not recommend that.
What comes next for this research?
JK: Our next step is to share this definition with as many policymakers as we can, and then offer them technical support if they want to figure out how to use this in legislation or regulation. The second thing is if any legislators, policymakers or advocates want to pursue policies, we’re available to provide technical support and assistance.
There’s also a bunch of additional research that would be useful. We have some of those recommendations at the end of the report, but as an example, there’s controversy right now over different subgroups of UPFs and whether some are more harmful than others. The research that’s been done so far has been somewhat confusing and flawed. There’s also research on how, exactly, ultra-processed foods cause all these problems. There are a lot of great, interesting hypotheses, but I wouldn’t say any of them are definitive.
As an expert in this field, how do you approach ultra-processed foods in your own life, and how would you recommend people think about reducing their own consumption?
JK: Right now, about 60% of the calories that Americans consume are ultra-processed foods. Starting there, small and incremental steps are great. You can’t totally change your diet overnight, so the bottom-line message is to think about small things you can do.
The first challenge is identifying UPFs, which is where we started this conversation. If there are ingredients in food that you don’t have in your kitchen, it’s likely going to be a UPF, and if it’s a long ingredient list that looks like a chemistry lab, it’s probably a UPF. Then you can consider what the food looks like. If it’s super bright, like Froot Loops or Doritos, that probably means it’s a UPF.
But then once you’ve identified ultra-processed foods, what do you do? Let’s think about one thing you want to do. Say you drink a lot of sweetened beverages. You can think of what you can swap in that works for you, like sparkling water that doesn’t have a lot of additives, or coffee or tea.
As for me, I don’t eat many ultra-processed foods. When I started doing this work, when my kids were younger, I fed them all sorts of UPFs. I certainly wouldn’t do that now and wish I had known better. But if I want to have something that’s ultra-processed, that’s fine, it’s not going to kill you to have just a little bit. As long as your overall dietary pattern is healthy, then that’s great.
The panel was co-chaired by Krieger and Lindsey Smith Taillie of the University of North Carolina at Chapel Hill and convened by Mary Story and Megan Elsener Lott of Duke University. A full list of panel members is included in the panel’s technical report. This work was funded by Healthy Eating Research and the Robert Wood Johnson Foundation.
For more information or to contact Krieger, email Alden Woods at acwoods@uw.edu.