CFA Commends Step Towards Regulating Ultra-Processed Food, Urges Adoption of Prevailing “Nova” Definition

CFA submitted the following comments to the U.S. Food and Drug Administration in response to a request for information regarding how to adopt a uniform definition of ultra-processed foods (UPFs). The comments urge FDA to adopt a federal UPF definition grounded in the Nova classification system, which informs the research linking UPFs to diet-related disease. FDA should resist calls to conflate its UPF definition with other factors related to dietary quality, such as macronutrient content, or to circumscribe its definition to exclude foods that clearly meet the Nova definition. The comments acknowledge that some UPFs may fit into a healthy dietary pattern, while other, less processed, foods may be comparatively unhealthy, but they warn FDA that attempting to create a new UPF definition, different from Nova, would sow confusion among consumers and undermine the agency's credibility. The comments further urge FDA to clarify that use of certain "industrial processes," such as extrusion, that may not be reflected in the ingredients label on manufactured foods, will qualify those foods as UPFs.