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.

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