What Actually Counts as an Ultra-Processed Food? The FDA Still Hasn't Decided

What Actually Counts as an Ultra-Processed Food? The FDA Still Hasn't Decided

"Ultra-processed" shows up in headlines, doctor's office pamphlets, and now some food packaging. There is no legal U.S. definition of the term yet. The FDA is still weighing which definition to adopt, so right now "ultra-processed" is a research classification, not a regulation.

Where the Term Actually Comes From

The concept did not start at the FDA. It comes from NOVA, a food classification system developed by researchers at the University of Sao Paulo and used widely in nutrition research since the early 2010s. NOVA sorts all food into four groups based on the amount and purpose of processing, not on calories, fat, or sugar content alone.

• Group 1: Unprocessed or minimally processed foods (fresh produce, plain meat, eggs, milk, oats).
• Group 2: Processed culinary ingredients (oils, butter, sugar, salt) used to prepare Group 1 foods.
• Group 3: Processed foods (canned vegetables, cheese, fresh bread) made by adding Group 2 ingredients to Group 1 foods.
• Group 4: Ultra-processed foods. Industrial formulations with ingredients rarely found in a home kitchen, plus additives whose job is cosmetic: colors, emulsifiers, flavor enhancers, and texturizers that make a product look, feel, or taste a certain way rather than nourish.

NOVA is a research tool, not a nutrition facts requirement. It says nothing about whether a specific product is good or bad for you. It only classifies how a food was made.

Why the FDA Hasn't Adopted a Definition

According to a July 2026 FoodNavigator report, public comments on a possible FDA definition split three ways: adopt the NOVA system as written, build a hybrid definition that weighs both processing method and nutritional content, or reject a processing-based definition entirely on the argument that processing alone does not determine whether a food is nutritious.

That last group has a fair point. A store-bought whole wheat bread with a dough conditioner is technically ultra-processed under NOVA. So is a protein bar built around whey isolate and a sugar alcohol. Neither is nutritionally identical to a bag of chips, but NOVA's four groups do not have room for that distinction on their own. No FDA-adopted definition exists as of this writing, and until one does, "ultra-processed" on a label or in a headline is descriptive shorthand, not a regulated claim.

What This Means at the Grocery Store

Since there is no legal standard, a package can call itself "not ultra-processed" or avoid the term entirely without any enforcement behind it either way. The label itself will not settle the question for you. The ingredient list will get you closer.

A few things worth checking on any packaged food:

• Ingredient count. Long lists are not automatically bad, but a food with 20+ ingredients is more likely to include additives added for shelf life, texture, or appearance rather than nutrition.
• The recognize test. Could you buy each ingredient on its own at a grocery store and use it in a home kitchen? Maltodextrin, soy protein isolate, and mono- and diglycerides do not pass that test. Oats, almonds, and sea salt do.
• Additive category, not additive presence. Some additives are functional and mundane, like citric acid for acidity or lecithin as an emulsifier from sunflower or soy. Others exist mainly to mimic a food that was made with fewer shortcuts. The distinction is what the additive is doing, not whether one exists at all.
• Cosmetic colors and flavors. Artificial colors and artificial flavors are consistent markers of Group 4 processing under NOVA, and they are also on our own avoid list for the food category independent of this debate.

This is close to the same approach we already use to evaluate products for this site. We were applying an ingredient-level rubric before "ultra-processed" became a headline word. See How to Read Food Labels for the fuller version of this process.

The Bottom Line

The FDA's definition fight will settle a regulatory question, not a nutrition one. Whatever the agency eventually decides, the underlying signal does not change: shorter ingredient lists, ingredients you recognize, and an absence of cosmetic additives are worth seeking out regardless of what the final legal term ends up being. Products like Bob's Red Mill Organic Rolled Oats or Natural Delights Medjool Dates illustrate the low-processing end of the spectrum: short, recognizable ingredient lists with nothing added for appearance alone. Use that as the baseline, not a headline about a term regulators have not finished defining.