Political and regulatory efforts to define ultra-processed foods and discourage their consumption could have unintended consequences when paired with funding cuts for public health programs, which also threaten to undo a dip in obesity rates for the first time in 20 years as measured by a nonpartisan public health nonprofit.
Data released this month by the Trust for America’s Health (TFAH) found 19 states had adult obesity rates at or above 35% in 2024 – that is down from 23 states the prior year.
While it is too soon to call this “positive step” a trend, the reversal is notable because it is the first time it has happened since TFAH began collecting the data in 2011 and releasing the results in its annual State of Obesity report, said Nadine Gracia, president and CEO of TFAH.
“This potential progress is also at risk due in part to recent and proposed federal actions to claw back and reduce funding for pubic health programs, eliminate programs and lay off experts that work on chronic disease prevention and limit access to nutrition support programs,” including SNAP and WIC, she said.
“For example,” she noted, “the President’s fiscal year 2026 budget request proposes the near total elimination of the National Center for Chronic Disease Prevention and Health Promotion at CDC, including the elimination of the Division of Nutrition, Physical Activity and Obesity.”
UPF regulation is warranted, but complicated to execute
Another threat to these gains could be unintended consequences related to defining ultra-processed foods, such as by the FDA and states, if it limits access to healthy, convenient, affordable foods with no clear harms to health, cautioned, Megan Lott, deputy director of Healthy Eating Research at Duke Global Health Institute.
“While the evidence base is more than sufficient to warrant regulation of ultra-processed foods, the lingering question is, how do we do this in the best way? We want to identify the set of processed foods that scientific evidence shows are clearly linked to health concerns so that government policies can assist people in limiting those foods in their diets without having the unintended consequence of limiting access to healthy, convenient, affordable foods with no clear harms to health,” she said.
FDA is considering a national UPF definition that will fill in nutrition gaps that NOVA misses.
Lott explained that the NOVA classification system, which groups foods into four categories based on their level of processing, was developed for research studies – not as the basis for determining healthy foods from a policy perspective.
“NOVA does not take a product’s nutrient health profile into consideration. Thus, it wasn’t designed to really distinguish those healthier category 4 products, like whole wheat bread, yogurt and tofu, from less healthy items like sugar-sweetened beverages, candy and processed meats. Under NOVA, those are all considered ultra-processed foods,” she said.
Because processing is not disclosed on food labels, some states use certain ingredients as markers for UPFs, Lott noted. But, she added: “Evidence on whether this is a good approach is currently lacking.”
To address this shortcoming, Healthy Eating Research convened a national expert panel to develop an evidence-based definition of UPF that builds on NOVA and could help policymakers. The panel also is evaluating implementation across settings, including retailers and schools, which are very different from each other, Lott said.
The panel’s recommendations will be published in early 2026.
What other strategies could offset consumption of unhealthy food?
Improving access and affordability of healthier foods, such as produce, is another way to decrease consumption of ultra-processed foods, said Lott.
But, federal efforts to do this are under threat, Lott said, echoing Gracia.
“Programs like WIC, school meals and SNAP are designed to support a family’s health and financial security, enhancing their ability to purchase healthy foods,” she said.
“The recent cuts to SNAP put the health and wellbeing of children, families and communities at risk,” she added, explaining: “Changes to program eligibility will have downstream impacts on school meals and WIC as well as an already strained charitable food system across the country. We are all bracing to see food insecurity rates rise as a result of decreased investment and access to these programs.”
