UPFs and the Future of Food Regulation: Why This Conversation Is Different

Ultra-processed foods are not a new concept—but the way they are being incorporated into U.S. policy is new.

Historically, food regulation has focused on nutrients, safety, and labeling accuracy. Today, regulators are beginning to ask a different question: not just what is in a product, but how it was made.

That shift matters.

It introduces a level of subjectivity that the industry has not had to navigate at scale. Terms like “ultra-processed” are not yet formally defined in U.S. regulation, but they are already influencing dietary guidance, school food discussions, and global labeling systems.

This creates a unique challenge for brands and co-packers.

Unlike traditional compliance issues—where rules are clearly written—UPFs represent a moving framework. Definitions are still forming. Policy is still taking shape. But expectations are already changing.

School meal programs are a clear example. Public feeding systems are being positioned as early adopters of nutrition policy, with increasing emphasis on whole foods and reduced reliance on highly engineered formulations. What happens there often expands into broader procurement standards.

At the same time, front-of-package labeling discussions are gaining traction. Globally, simplified labeling systems have already demonstrated the ability to shift consumer behavior and drive reformulation.

Taken together, these signals point to a likely outcome: UPFs will not be regulated through a single rule. They will be addressed through a combination of definitions, labeling, procurement standards, and market pressure.

For our industry, this is not a moment to wait for certainty — it is a moment to build flexibility. 

That means understanding where your products may be exposed, identifying opportunities for simplification, and preparing for a future where processing becomes part of the regulatory conversation.