Ultraprocessed Foods: What Are We Even Talking About?
Despite its ubiquity, the term ultraprocessed lacks a clear and widely accepted definition, which is necessary to have a meaningful discussion about the science and appropriate regulation.
In the immortal words of Inigo Montoya, “You keep using that word. I do not think it means what you think it means.” This aptly describes the current dialogue, in both the scientific and regulatory communities, regarding “ultraprocessed foods” (UPFs).
The term ultraprocessed has become commonplace across media, scientific publications and government pronouncements relating to food products in the U.S. and elsewhere. You know a term has become part of the modern lexicon when the established pillars of journalism like the New York Times, the Wall Street Journal and The Onion have all opined on it.
Despite its ubiquity, the term ultraprocessed still lacks a clear and widely accepted definition, which would be needed to have a meaningful discussion about the science and appropriate regulation.
Everyone in the field continues to discuss ultraprocessed foods as if they have a common understanding of the term, when there is no clear consensus. Last week’s “MAHA Report” made extensive comments about the dangers of UPF while noting that “there is no single, universally accepted definition of UPFs.”
This article provides a brief overview of how the term has been used and the various attempts by researchers, regulators and other commentators to arrive at a clear definition. A common understanding of the term is necessary to ensure that emerging scientific data and regulatory schemes concerning UPFs are intelligible, well-founded and reasonably consistent – much less actionable.
Common usage
The term ultraprocessed (adj.) is defined in the Oxford English Dictionary as follows:
Of food: subjected to a high degree of industrial processing during manufacture, and usually containing large quantities of additives such as salt, sugar, fat, preservatives or artificial colors and flavorings.
This definition, as it pertains to food, was only first adopted in 2024, while Oxford notes a steep increase in its usage starting in 2020. So where did it originate?
It bears mentioning that salt and fat are ingredients rather than “additives,” which speaks to the general misunderstandings underpinning these discussions, as certain articles and proposed definitions for UPF don’t relate to the processing of the food alone, but simply to whether they contain conventional food additives.
The term ultraprocessed food was coined by Carlos Monteiro, a Brazilian epidemiologist, in his novel 2009 paper. This was incorporated into a larger “NOVA” food classification system developed by Dr. Monteiro in a 2010 paper and later expanded upon. By 2019, Dr. Monteiro had issued a lengthy report on ultraprocessed foods, diet quality and health for the UN’s Food and Agriculture Organization (FAO). As noted in that report, “[u]ltra-processed foods is a concept and a term only used by the NOVA food system classification.”
The NOVA system seeks to classify all foods and food products into four groups that have since been modulated. The groups include the following (with my comments):
* Group 1 - Unprocessed and minimally processed foods: Edible parts of plants (e.g., fruits, seeds, roots) or from animals (e.g., meat, milk), fungi, algae, etc., and items minimally processed from such ingredients.
* Group 2 - Processed culinary ingredients: Oils, butter, lard, sugar and salt. All delicious.
* Group 3 - Processed foods: OK, now we’re talking. These include canned or bottled vegetables preserved in brine, whole fruit preserved in syrup, tinned fish preserved in oil, processed meats (e.g., ham, bacon, pastrami, smoked fish), freshly baked breads and simple cheeses with added salt. [Author pauses to dab the corners of his mouth.]
* Group 4 - Ultraprocessed foods: These are your grocery store center aisle offerings: carbonated soft drinks, packaged snacks and candies, various pastries, donuts, neon breakfast cereal, pizzas, chicken nuggets, sausages, burgers, hot dogs and similar foods that 3-year-olds willingly eat.
The groupings are sensible, but the primary importance hangs on the ability to determine whether a given food product is simply “processed” or “ultraprocessed.” With the increasing reports of “associations” and “links” between these ultraprocessed foods and all manner of illnesses — from Parkinson’s to cancer — industry needs to have some guideposts for assessing the classification status of their food products.
Without clearly defined categories, the self-reporting that serves as the basis for many of these studies is flawed, which raises questions about the overall reliability of the study findings.
NOVA: Not the only show in town
Despite the prevalence of Dr. Monteiro’s publications, the NOVA system is not the lone food classification system that accounts for ultraprocessed foods, and the definitions vary. Schemes also have been proposed by the International Agency for Research on Cancer, the International Food Policy Research Institute, the International Food Information Council Foundation and the University of North Carolina. It is unclear whether references to UPF and processed foods are consistently applying the NOVA scheme or others that address highly processed foods.
As recently as April 2025, a task force established by the International Union of Food Science and Technology (IUFoST) proposed its own rationale for defining the role of processing in food classification systems. The scheme evaluates foods using various key properties: nutritional value, safety, sustainability, palatability, affordability and convenience. The aim of the IUFoST approach is to mitigate some of the confusion that has arisen over the NOVA classification system.
The French Agency for Food, Environmental and Occupational Health & Safety published a report in January 2025 essentially indicating that it was too early to draw conclusions regarding UPF, and that more studies are required to analyze all risk factors, including chemicals resulting from processing.
Even the World Health Organization has joined the fray with a recent call for experts to “develop a guideline on consumption of ultraprocessed foods” with the first order of business being the establishment of a definition.
Do you feel like you’ve got a handle on this yet? No? Then let’s just move on.
What is FDA’s take?
Perhaps the FDA can clear things up. The term “processed food” is defined in the Food, Drug and Cosmetic Act to include “any food other than a raw agricultural commodity and includes any raw agricultural commodity that has been subject to processing (e.g., canning, cooking, freezing, dehydration or milling).” However, the agency has provided no definition for the term ultraprocessed.
Former FDA Commissioner Robert Califf and Deputy Commissioner for Human Foods Jim Jones authored a 2024 article calling for further research on UPF. The article made no mention of the NOVA classification system, but it noted that UPFs are “usually characterized by industrial processing, the presence of food additives such as flavors, colors and nutrients intended to make them appetizing (sodium, added sugars, saturated fat).”
Although the FDA officials cited research that “points to” UPF being “associated” with diet-related diseases, there was no legal definition or clarification by the agency on what these terms actually mean or how to properly classify a given food product.
In fact, discussions at a December 2024 Nutrition Regulatory Science Workshop, held jointly by FDA and the National Institutes of Health, presented myriad examples illustrating the murky distinctions that need to be made for a UPF determination. For example, more processing steps are used to produce cows milk than almond milk, but conventional milk is considered “minimally processed,” while almond milk might be deemed “ultraprocessed.”
One of the speakers, Kevin Hall, who pioneered research into the potential for UPF to be addictive, has since left the agency due to disagreements over his recent findings, which suggest that UPFs are not addictive in the way that many drugs are understood to behave.
Health & Human Services Secretary Robert F. Kennedy Jr. has spoken out strongly against chemicals in food (particularly color additives) and has denounced UPFs. Many of his statements suggest that the use of food additives or colorants alone is sufficient to render a food product ultraprocessed.
Anybody else want to chime in?
If the waters weren’t muddy enough, numerous U.S. states have suddenly announced food science expertise and are proposing legislation to restrict or ban ultraprocessed foods or certain food additives that are associated with UPFs (e.g., color additives). Despite public pronouncements that these efforts target ultraprocessed food, the bills typically focus only on food dyes and other additives.
California Governor Gavin Newsom also issued an executive order purporting to crack down on “ultraprocessed foods” and “food ingredients that pose a health risk to individuals.” Pennsylvania also recently introduced legislation to define UPFs and “unhealthy ultraprocessed foods.”
Both California and Pennsylvania have introduced bills that propose to define ultraprocessed foods with the exact same language, which suggests that the UPF classification relates only to the presence of food additives rather than any degree of actual processing.
With the various definitions arising across the U.S. and the patchwork of state legislation targeting UPFs, the thought that FDA would not step in to offer some clarity in the situation is … inconceivable.
Where does this process lead?
Emerging scientific studies highlight the potential health risks due to “links” or “associations” (not causation) between consumption of UPFs and negative health outcomes. That literature is widely broadcast and increasingly cited in litigation and legislation across the country.
But is it sensible to assert consensus regarding the harm(s) resulting from UPF if every entity under the sun is still trying to cobble together a workable definition? Is there somehow violent agreement that snozzberries are toxic?
It would seem that we should arrive at a clear legal or scientific definition for UPF before the legislation and litigation start flying. In the meantime, do not assume that anyone speaking to you about ultraprocessed foods knows exactly what they’re talking about.
This article is reprinted with the permission of Food Processing. It first appeared on May 28, 2025, in Food Processing.com.