Navigating the UPF Definition Landscape: Are You Prepared?

Ultra-processed food (UPF) remains one of the food industry’s most pressing challenges—yet there’s still no standardized federal definition. This federal regulatory void, combined with 17 separate state definitions, has created significant confusion for manufacturers, retailers, and consumers alike. While FDA leadership promised a definition by late April, recent statements from FDA Deputy Commissioner Kyle Diamantas confirmed delays: “A definition for ultra-processed foods is really hard.”

Two Models, One Decision

The FDA is evaluating two competing approaches: the NOVA classification system (focused on processing level) and the IAFNS-led Guiding Principles model (balancing processing and formulation with nutritive value). There’s also speculation the FDA may define non-UPFs instead—a strategy mirroring the organic and GMO regulatory approaches of the past decade.

The Real Question for Your Business

Rather than debating which definition will prevail, forward-thinking food companies should ask: “Do we know how to win in each potential scenario?” Each definition carries distinct implications across the entire food ecosystem, affecting product formulation, marketing claims, regulatory compliance, and competitive positioning.

Policy Shifts Are Already Shaping the Market

The 2025 Dietary Guidelines for Americans prioritize “real food”—emphasizing protein, dairy, healthy fats, fruits, vegetables, and whole grains while rejecting processed foods. This guidance will directly influence federally funded programs including school lunch, WIC, SNAP, and military meals, as well as  changing shelf space requirements in retail.

However, mainstream consumer adoption remains uncertain. While the guidelines promote whole foods, convenience and processed products represent 43–70% of current American food purchases. Shifting eating patterns requires increased access, culinary education, and affordability—factors beyond regulatory control.

Preparation Is Competitive Advantage

Every potential scenario presents both opportunities and challenges. The policy discussion itself drives consumer awareness of product healthfulness, making strategic positioning critical.

To help food industry leaders prepare, we’ve developed the UPF Navigator, an AI-powered tool providing:

Regulatory Risk Mapping: How your products perform under NOVA vs. Guiding Principles models, including SNAP/WIC eligibility implications

Claim Vulnerability Assessment: Identifying marketing statements and ingredient choices that could face enforcement risk

Stakeholder Landscape Analysis: Your brand’s positioning relative to competitors, retailer expectations, and advocacy narratives

Monitoring Targets: Key developments to track before definition release

When policy and public opinion intersect with unprecedented polarization, mapping scenarios and developing action plans enables decisive brand strategy. This waiting period provides a critical opportunity for leaders to ready their responses.

One of the hottest topics in today’s food industry, ultra-processed food (UPF), still lacks a standardized federal definition and that lack of definition is causing a swirl of industry and consumer confusion. Health & Human Services Secretary Robert F. Kennedy, Jr. has stated that FDA will come forward with a definition, which will ideally qualm confused consumers and frustrated retailers and manufacturers trying to navigate the lack of a federal definition paired with the 17 separate state definitions currently on the books.  Originally promised by late April, the definition is likely delayed.  Just last week, FDA Deputy Commissioner for Food Kyle Diamantas shared, “A definition for ultra-processed foods is really hard.”

The hard part may be choosing which of the two competing models under consideration to choose. Both the NOVA classification (based on processing level) and the IAFNS-led Guiding Principles for Food Classification model (balancing processing and formulation with nutritive value) are being evaluated. It has also been suggested the definition may not define UPFs, but rather back into the definition by regulating the definition of non-UPFs instead, mirroring what happened last decade with organic and genetically-modified foods.

But the real question is not which definition will be chosen—because each has implications across the food ecosystem. The better question for the food industry is “do you know how to win?” in each of the possible scenarios.

The simplified version of the scenarios are the two likely potential definitions for UPF applied to the split “eating patterns” that exist today.

The 2025 Dietary Guidelines for Americans shifted the priority to “real food”—a diet grounded in protein, dairy & healthy fats, fruits & vegetables and whole grains –and with a strongly rejection of processed foods. These policies will shape funding of federally funded food programs such as school lunch, WIC and SNAP food assistance and military meals and will also require new shelving standards in grocery retail. 

What remains to be seen is how much of this guidance will be adopted by mainstream Americans, for whom convenience/processed foods are 43-70% of their food purchases and for whom “real food” may require more access, food preparation education and affordability.  

Each potential scenario has opportunities and challenges for brand and retailers as the discussion will drive consumer awareness of product healthfulness. To prepare for the upcoming definition, we’ve built the UPF Navigator, an AI-powered tool to help them see the full landscape of potential scenarios. Key outputs include:

Regulatory Risk Mapping: How your products fare under NOVA vs. Guiding Principles; exposure to SNAP/WIC eligibility changes

Claim Vulnerability Assessment: Which marketing statements, ingredient choices, or nutrient claims may be an enforcement risk under pending definitions

Stakeholder Landscape Analysis: Where your brand stands relative to competitor positioning, retailer expectations and advocacy narratives

Monitoring Targets: What to track between now and definition release to stay ahead

When policy and public opinion are both more polarized and intertwined than ever before, mapping options and potential action plans can help you turn a decision into a decisive move for your brand.

Need more information on the UPF Navigator? Reach out to the FleishmanHillard Food, Agribusiness and Beverage team.