In early August, the Department of Health and Human Services (HHS) sent a proposed definition of ultra-processed food (UPF) for final review and approval. Efforts by those in the Make America Healthy Again movement to regulate these foods have been going on for some time, and there are some reasons to be concerned by the effects of some foods in this broad food category on the health of Americans. However, not all of these foods are bad for you, and many Americans—particularly those of more limited means—rely on these lower cost foods to put meals on the table at a reasonable price. Simply changing labels can create consumer confusion and raise costs on food, particularly on foods deemed “more favorable” in the eyes of regulators. With this in mind, it seems appropriate for the government to prioritize sound science and policy rather than hastily trying to define what is an ultra-processed food.
Before trying to define and heavily regulate an entire food category, it is necessary to first understand where ultra-processed foods came from. Depending on how you define UPF, efforts to provide durable and palatable food products at a lower cost have been going on for well over a century. In particular, wartime advances in food preparation during World War II led to the increased availability of lower cost processed foods across the world. Processed foods are less expensive on a calorie basis than fresh foods, and have played a large role in increasing food and nutritional security.
Brazilian researchers in 2009 created the NOVA classification system, the most common current food classification system in use today. It divided foods into categories based on the level of processing: unprocessed or minimally processed foods (whole foods, fruit, vegetables, meat, pasta), culinary ingredients with some processing (oil, butter, salt, sugar) that are used as cooking ingredients, processed foods that are created by combining items from the first two categories, and “industrially created” UPF (chips, packaged breads, cereal, canned soups, etc.). While this food classification system is widely used, it has created confusion as to what foods are actually “bad” for you. Since the creation of the NOVA classification system, thousands of studies have examined UPF, with many reporting an association between eating them and adverse health effects like cancer, heart disease, and depression. However, causation between the two have yet to be definitely proven. Some studies have also suggested a connection between UPF and weight gain, but again with no proven causation.
Notably, many UPF products are not junk foods. For example, some packaged whole wheat breads are linked to lower risks of heart disease and diabetes, while some packaged yogurts are linked to lower levels of colorectal cancer. And food in other classification categories also carry risk levels that rival some UPF, like red meat. More specifically, while a cereal like Cheerios is ultra-processed, whole grain oats in the cereal make it more nutritious than other cereals, providing nutritional benefits to consumers. In general, research has shown that most forms of food processing are “necessary and harmless,” while noting that it’s possible that some processes can be unhealthy.
If the federal government did release a specific definition for UPF, it would likely lead to more complicated food labeling, creating confusion while increasing costs on consumers. Meanwhile, data from other countries show that there is no guarantee that the new definition would actually provide meaningful changes to American obesity or nutritional rates. In fact, too intense a focus on UPF could even create unhealthy eating disorders among some Americans.
Instead of focusing so directly on building definitions and regulations around UPF, experts recommend encouraging an increased mix of food in the American diet, with some acceptance that most Americans benefit from some processed foods—like pasta and bread—in their diet.
The government should hit the brakes on its current effort to define—and subsequently regulate—UPF. However, if it must proceed with some sort of food definition, it should prioritize consumer choice, clarity, and scientific accuracy. For example, some researchers suggest focusing on specific nutrients of concern rather than specifically on processing level, or building a definition that targets nutritional quality.