NACS sent a letter this week to the U.S. Department of Agriculture (USDA) and Food and Drug Administration’s (FDA) Secretary Brooke Rollins and Commissioner Martin Makary in response to the Agencies’ Request for Information on “Ultra-Processed Foods” (UPFs), published July 25, 2025.

“NACS has several concerns about efforts to tie federal nutrition policy to the concept of UPFs. UPFs simply are not a consistent or reliable proxy for the impact of different foods on human health. The term remains vague and contested and using it as the basis for regulation would not strengthen nutrition programs and ‘[address] health concerns,’ as noted in the RFI, but instead undermine food access and impose significant, complex compliance burdens on food retailers,” the letter states.

The UPF category is large and wide-ranging, making up an estimated 73% of the U.S. food supply. Consumption is highest among lower-income populations, where these foods are often essential because of their affordability, shelf stability and accessibility. In the convenience channel, which primarily serves these communities, retailers rely on shelf-stable and affordable items to meet customer needs. Yet many of these foods, such as whole-grain breads, Greek yogurt, fortified cereals and canned fruits and vegetables, are labeled as “ultra-processed” even though they provide important nutritional value.

NACS cautioned USDA and FDA to avoid building federal nutrition policy around vague, contested concepts like “ultra-processed foods.” The concept remains vulnerable to politicization and offers no value in setting effective standards. Tying nutrition policy to a UPF definition would restrict consumer choice, limit food access in vulnerable communities and saddle retailers with costly compliance burdens.

NACS members are committed to providing affordable and accessible food to the communities they serve, and NACS stands ready to continue working with USDA, FDA and other stakeholders to ensure that any future policies support that mission.