Competere has joined the Taxpayers Protection Alliance (TPA) and 15 other taxpayer, consumer and free-enterprise organisations in calling on the U.S. administration to reject a proposed federal definition of “ultra-processed food” (UPF). The message is simple: if the goal is better health, defining an overly broad category of foods is not the same as improving people’s diets.
On 26 October, we sent a letter to Office of Management and Budget (OMB) Director Russell Vought, raising concerns over the proposed White Paper developed by the Department of Health and Human Services (HHS) and the Food and Drug Administration (FDA), which is currently under OMB review.
Read the letter. Meet the signatories.
The initiative reinforces the message of our recent policy paper, Ultra-Processed Foods: Beyond Oversimplification – From Classification to Smarter Prevention: a definition can classify foods, but it cannot replace a prevention strategy.
In a nutshell:
- There is no scientific consensus on a single definition of ultra-processed foods (UPFs). Different foods with very different nutritional characteristics can fall within the same category simply because of the ingredients or processing techniques they use.
- A broad definition risks confusing processing with nutritional quality. Everyday products such as whole-grain bread, yogurt, fortified cereals and frozen chicken could be classified alongside foods with very different nutritional profiles.
- A federal definition could quickly become a regulatory and legal trigger, influencing lawsuits, labelling requirements, reformulation, marketing restrictions and state-level policies, with additional costs ultimately reaching consumers.
Processing Is Not a Proxy for Nutrition
The debate around UPFs increasingly risks turning the degree of processing into a shortcut for judging the nutritional value of food.
But food is more complex than a category.
The Food and Drug Administration (FDA) estimates that around 70% of the U.S. food supply consists of products commonly considered ultra-processed. When a definition potentially covers such a large share of what people eat, precision becomes essential.
A system that places whole-grain bread, yogurt or fortified cereals in the same broad category as products with completely different nutritional profiles may offer policymakers a simple classification – but not necessarily consumers a better understanding of their diet.
A broad label can classify food. It cannot explain how that food fits into a person’s overall diet and lifestyle.
From Definition to Regulation: Why It Matters
A federal UPF definition would not remain just a definition.
Once endorsed by the U.S. government, it could become a reference point for lawsuits, labelling rules, taxes, marketing restrictions and other regulation.
Currently, more than ten UPF-related cases are already being pursued against food companies in U.S. federal and state courts. San Francisco also filed its own lawsuit in December 2025.
That means a federal definition could quickly become a regulatory trigger.
For companies, the consequences could include product reformulation, new packaging requirements and a growing patchwork of state-level rules.
For consumers, the risk is equally concrete: more complexity, more compliance costs and, ultimately, higher prices at the checkout.
A definition may look technical. Its consequences would be anything but.
Beyond Classification: Better Questions for Better Prevention
The real challenge is not simply to decide which foods belong in the UPF category. It is to understand what actually drives poor health.
Prevention should look at nutritional quality, portion size, frequency of consumption, dietary patterns, individual needs and lifestyle.
A food category alone cannot tell us whether a product makes sense for a specific person, in a specific quantity, at a specific moment.
This is why policymakers should move beyond one-size-fits-all classifications and ask better questions:
- What does the food actually provide?
- How much and how often is it consumed?
- What does it replace in the diet?
- What are the realistic alternatives?
- How does it fit into the person’s broader lifestyle?
Better prevention starts with understanding context, not simply assigning categories.
From Static Labels to Smarter Prevention
Public health now has tools that can do much more than place foods into fixed boxes.
AI, wearable devices, digital food information and personalized nutrition can help people understand food in relation to their own needs, habits and goals.
Instead of simply telling consumers what to avoid, these tools can support more informed decisions around portions, frequency, balance, movement and lifestyle.
This is the direction we believe prevention should take: from static classifications to dynamic guidance, and from passive consumers to informed citizens.