/>iEarlier this year, President Trump formed the Make America Healthy Again Commission. The Commission included representatives from more than a dozen government agencies. The Commission was tasked with studying chronic childhood diseases and their causes, advising the President on how best to educate the American people about chronic childhood diseases, and providing strategies to correct and prevent chronic childhood diseases. The MAHA Commission released the Make Our Children Healthy Again (MAHA) Report in May of this year. A second Strategy Report was set to be released on August 12, 2025 but has been delayed.
Ultra-processed foods were one of the “drivers” recognized in the MAHA Report related to rising rates of chronic childhood illnesses. However, the federal government has no specific definition of “ultra-processed foods.” Recently, agencies involved in the MAHA Report issued a joint Request for Information to assist them in creating a definition of “ultra-processed foods.”
So – how can the MAHA Report claim that ultra-processed foods cause chronic childhood diseases when there is not a federal definition for these types of foods? There have been efforts to define ultra-processed foods. The classification system recognized in the MAHA Report, and perhaps the most widely accepted one, is the NOVA classification system developed by Brazilian researchers, who divided foods into four groups:
- Group 1. Unprocessed or minimally processed foods
- Group 2. Processed culinary ingredients
- Group 3. Processed foods
- Group 4. Ultra-processed foods
Group 1 foods are self-explanatory – whole fruits, vegetables, herbs, meats, milk – eaten raw or cooked, dried, roasted, boiled, or non-alcohol fermented. Group 2 foods are “[p]rocessed culinary ingredients, such as oils, butter, sugar and salt, are substances derived from Group 1 foods or from nature by processes that include pressing, refining, grinding, milling and drying.” Group 2 foods are usually added to Group 1 foods to make more complex dishes. Group 3 dishes are represented by combinations of Group 1 and Group 2 foods that have been cooked or preserved, such as canned fruits and vegetables, cheese and bread. Group 4 foods are described as:
Ultra-processed foods, such as soft drinks, sweet or savoury packaged snacks, reconstituted meat products and pre-prepared frozen dishes, are not modified
foods but formulations made mostly or entirely from substances derived from foods and additives, with little if any intact Group 1 food.
Group 4 foods may contain ingredients such as preservatives, stabilizers, coloring agents, flavoring agents, sweeteners other than natural sugar, and processing agents to improve appearance and/or enhance shelf life. Many commonly used food items fall within the NOVA Group 4 classification of ultra-processed foods:
carbonated drinks; sweet or savoury packaged snacks; ice cream, chocolate, candies (confectionery); mass-produced packaged breads, buns, cookies
(biscuits), pastries, cakes and cake mixes; breakfast “cereals”, “cereal” and “energy” bars; margarines and spreads; processed cheese; “energy” drinks;
sugared milk drinks, sugared “fruit” yoghurts and “fruit” drinks; sugared cocoa drinks; meat and chicken extracts and “instant” sauces; infant formulas, follow-
on milks and other baby products (which may include expensive ingredients); “health” and “slimming” products such as powdered or “fortified” meal and dish
substitutes; and many ready-to-heat products including pre-prepared pies and pasta and pizza dishes; poultry and fish “nuggets” and “sticks”; sausages, burgers,
hot dogs and other reconstituted meat products; and powdered and packaged “instant” soups, noodles and desserts.
NOVA, and other similar classification systems, have been criticized, noting, among other things, that there is no universally accepted definition of ultra-processed foods. More fundamentally, the criticism attacks the concept that the level of processing is a valid criterion by which to judge food. The criticism can be summed up as:
The level of processing our food and drink undergoes does not determine the nutritional content of the final product. Classifying and legislating food on the basis of the level of processing is not a scientifically-sound approach to food policy and would lead to negative outcomes for our food systems.
So – what sort of definition for ultra-processed foods is the federal government likely to adopt? While the MAHA Report referenced the NOVA classification system, the federal government, via the joint Request for Information, is clearly seeking broader input beyond the NOVA classification. As this blog has previously covered, the FDA recently promulgated a new definition of “healthy.” Some foods that could fit within the NOVA definition of ultra-processed foods could potentially qualify as “healthy” under current FDA regulations. For the FDA to maintain internal consistency, it would seem that the level of processing will not be the sole criterion in the classification of ultra-processed foods. However, ingredients, such as additives, preservatives, and colorings beyond recognizable whole food items, will likely be encompassed within any future federal definition of ultra-processed foods.
The definition of ultra-processed foods established by the federal government is expected to affect many widely consumed products. Once this definition is determined, subsequent considerations will focus on its applications. The potential applications remain to be seen. Will some ingredients, like artificial dyes or certain preservatives, be banned? Will there be warning labels? Will sales be restricted in some way, such as some states have banned the purchase of sugary foods and drinks with EBT cards? When released, the upcoming Strategy Report may give insight into the direction of future government actions.
