On July 23, 2025, the U.S. Food and Drug Administration (FDA) and U.S. Department of Agriculture (USDA) announced a joint Request for Information (RFI) requesting data and comments to help develop a uniform definition of ultra-processed foods (UPFs). This RFI was issued as part of a series of efforts by the Administration to address concerns around UPFs and diet-related chronic disease as identified in the Make Our Children Healthy Again Assessment. U.S. Department of Health and Human Services (HHS) Secretary Robert F. Kennedy, Jr. noted that “defining ultra-processed foods with a clear, uniform standard will empower us even more to Make America Healthy Again.”
Over 19,000 comments[1] had been submitted when the comment period closed on October 23, 2025. This level of engagement indicates broad interest in the development of a uniform definition of UPFs and the need for careful policy consideration. Citing the term’s ambiguity and connotations, some commenters suggested the agencies pursue an alternative to “UPF.” The American Society for Nutrition specifically noted that “there may be unintended consequences of labeling a food as ‘ultra-processed’ when it has nutrient-dense characteristics and adds nutritional adequacy to the diet.” Some commenters also argued that special consideration should be given to federal nutrition programs when it comes to attempting to label certain foods as ultra-processed. The Academy of Nutrition and Dietetics said that applying too simplistic a definition of UPFs presents the risk of restricting access to shelf-stable or fortified foods that are integral to individuals relying on government nutrition assistance programs or specialized diets.
Recognizing the Unique Circumstances of Specialized Nutrition
While the Administration has emphasized nutrition reform, its current discussions appear to overlook a key population—those who rely on medical foods.
The FDA defines medical foods as specially formulated products intended for the dietary management of diseases or conditions with medically recognized, distinctive nutritional requirements that cannot be met by modification of the normal diet alone. They must be consumed or administered enterally under physician supervision and are used in the clinical care of individuals with conditions such as phenylketonuria, urea cycle disorders, severe gastrointestinal diseases, and neurologic impairments requiring tube feeding. One 2017 study estimated that nearly 500,000 Americans, including children with rare metabolic disorders and adults reliant on long-term enteral nutrition, depended on medical foods as a component of their treatment. Enteral nutrition isn’t limited to long-term care or home health settings; as noted in a recent New England Journal of Medicine article, it is “used frequently in the ICU and can also be an important aspect of treatment in non–critically ill medical and surgical patients.”
Considering medical foods and their unique role in patient care could help ensure that future policies on UPFs are comprehensive and responsive to the needs of this vulnerable population.
The Healthcare Nutrition Council (HNC) and Infant Nutrition Council of America (INCA) addressed the implications of the apparent oversight of medical food in the comments they submitted in response to this RFI. HNC represents manufacturers of enteral nutrition formulas and oral nutrition supplements, including those categorized as medical foods, and parenteral nutrition, while INCA represents domestic manufacturers of infant formula. These organizations emphasized their recommendation that specialized nutrition products shouldn’t be categorized in the same way as non-nutrient-dense, conventional foods when defining UPFs as they are intentionally formulated and processed to provide nutrition for various medical needs. HNC and INCA also noted that AB 1264, which recently passed with bipartisan support in California to “define ‘ultraprocessed food’ for certain school-related purposes,” excludes infant formula and medical foods from that definition. The American Society for Parenteral and Enteral Nutrition (ASPEN) and the National Home Infusion Association (NHIA) are among those that signed on to this comment letter.
Looking Forward
As noted in the RFI, FDA and USDA aim to develop a uniform definition of ultra-processed to allow for consistency in both policy and research to “pave the way for addressing health concerns associated with the consumption of UPFs.” However, there is little clarity about what policy efforts may result from the comments and data collected through this RFI or what restrictions or labeling requirements, if any, may be applied to certain types of foods.
Looking ahead, the Administration is preparing to release the updated Dietary Guidelines for Americans (DGAs). While it was previously reported that the new DGAs would be finalized by the end of October, the White House and HHS have confirmed their release has been delayed, citing the ongoing government shutdown as the reason. Statutorily, the DGAs must be finalized by December 31, 2025. Secretary Kennedy recently indicated that these recommendations may include increasing consumption of saturated fats and other foods not previously recommended, highlighting some of the new messaging by the federal government being observed in the nutrition space. Applied Policy will be watching closely to see what recommendations are incorporated and how they impacts broader policy discussions on nutrition.
[1] As of November 6, 2025, 3.57K comments had been released.