Beyond Fat, Salt, and Sugar: The FDA’s Blind Spot on UPFs

The United States food industry is dominated by ultra-processed foods. Broadly, ultra-processed foods are products that undergo extensive industrial modification, such as instant noodles, soft drinks, and potato chips. These modifications increase profits, extend shelf life, and can make the foods addictive, using additives like MSG or artificial flavors. Ultra-processed foods make up 73% of the U.S. food supply and 53-62% of the average American diet.

The U.S. Food and Drug Administration (FDA) doesn’t have a set of criteria for what qualifies as ultra-processed food. Consequently, current policies focus on foods high in saturated fat, salt, and sugar.

Some food classification systems, like the widely adopted NOVA classification system, group foods based on the level of processing. NOVA was used to guide dietary recommendations in several Latin American countries, and France has applied it in their effort to cut ultra-processed food consumption by 20%.

Despite NOVA’s popularity, public health experts have voiced concerns over the system potentially misclassifying foods due to its focus on the level of processing over nutritional value.

Not all ultra-processed foods are created equal, as some can be dense in beneficial nutrients like protein and fiber and/or low in fat, sugar, and salt, all while limiting the use of additives. Previous research has even shown certain groups of ultra-processed foods to have reduced associations with cardiovascular disease and type 2 diabetes. Protein bars, flavored yogurt, fortified cereal, and plant-based milks are all examples of ultra-processed foods that have nutritional benefits.

Overconsumption of ultra-processed foods is linked to health conditions, such as obesity, cardiovascular disease, certain cancers, and even mental illnesses. While several policies have aimed to reduce unhealthy food consumption, few specifically target ultra-processed foods. Policymakers struggle to design targeted interventions when “ultra-processed” remains so loosely defined.

Oversimplifying food as ‘good’ or ‘bad’ doesn’t leave room for the nuance needed for policy and opens the door for overregulation.

Barry M. Popkin and colleagues analyzed nutrition labels from U.S. food purchase data to identify which foods were highly processed or high in fat, sugar, or salt (HFSS). They then tested four different approaches to estimate how much of what U.S. households buy could be targeted under each criterion. The approaches compared classification using both HFSS foods and ultra-processed foods definitions (the presence of additives like artificial colors and flavors).

About half of the 33 million products purchased by U.S. households were classified as ultra-processed foods, while 43% were considered HFSS. Although results from using these two categories overlapped, they were not identical. Researchers created four approaches:

• Approach #1 targeted foods high in fat, sugar, or salt that also had artificial sweeteners.
• Approach #2 focused on those foods with added colors or flavors.
• Approach #3 combined sweeteners and colors/flavors.
• Approach #4 included all common food additives,

Approach #4 achieved full agreement between both categories, capturing 100% of ultra-processed foods and 73% of all targeted products.

This combined approach enables policymakers to identify unhealthy products with more precision, moving beyond binary systems, like NOVA. Oversimplifying food as “good” or “bad” doesn’t leave room for the nuance needed for policy and opens the door for overregulation. Establishing clear definitions is critical in creating effective regulations that mitigate diet-related risks without over-regulating.

Notably, ultra-processed foods make up such a large part of the American diet because of taste and affordability. Overly restrictive policies could unintentionally increase food insecurity and grocery bills for several households, possibly worsening existing economic and health inequities. A balanced policy approach can promote healthier diets while maintaining access and affordability.