On Sept. 9, 2025, the Make America Healthy Again (MAHA) Commission issued a report that aims to reform dietary guidelines, encourage states to make voluntary commitments to limit access to foods the commission deems unhealthy and to provide technical assistance to states willing to do so.

The report identifies ultra-processed foods (UPF) – foods that are typically high in added sugars, sodium and fats while lacking essential nutrients and fiber – as a key driver of childhood chronic diseases and calls for them to be defined and labeled, as well as for efforts to reduce their consumption, including restrictions on their being purchased with Supplemental Nutrition Assistance Program (SNAP) benefits.

What is the issue? The AFBF Policy Book does not reference “ultra-processed foods.” The MAHA strategy calls for the federal government to develop a standard definition of UPFs, which is a crucial step for implementing further regulations, including those for labels.

Background

Under the Policy Reforms section of the report, the recommendation stated:

Ultra-Processed Foods: USDA, HHS, and FDA will continue efforts to develop a U.S. government-wide definition for “Ultra-processed Food” to support potential future research and policy activity.

An ultra-processed food is loosely identified as a food product made mostly or entirely from substances derived from foods, with the addition of flavorings, colorings, emulsifiers, sweeteners and other cosmetic additives.

Unlike minimally processed foods, which may be cut or frozen, UPFs often have a long ingredient list.

The most widely used classification system for ultra-processed foods is the NOVA system, developed by Brazilian researchers. This system is widely used and has significantly influenced global nutrition policies and guidelines. The NOVA system categorizes foods into four groups based on the extent and purpose of their processing: 

1. Group 1: unprocessed or minimally processed foods
2. Group 2: processed culinary ingredients
3. Group 3: processed foods
4. Group 4: ultra-processed foods

Impact and Significance:

• A shift in government focus: The report indicates a significant focus on governmental efforts/action addressing UPFs.
• Proposal to label UPFs: The report suggests introducing front-of-package labeling for ultra-processed foods and exploring industry guidelines to limit the marketing of unhealthy foods to children.
• In early October, California Gov. Newsom signed a bill that will phase out ultra-processed foods out of school lunches by 2032 drawing comparisons to the MAHA movement.

What are the applications of UPFs?

UPFs and farming are deeply interconnected, with agriculture providing the commodity crops that are often primary ingredients for UPFs. This relationship has significant consequences for agricultural production and diet diversity.

The report cites evidence linking ultra-processed foods to negative health outcomes such as obesity, type 2 diabetes, cardiovascular disease and cognitive decline in children. It characterizes nutritional deficiencies as being high in added sugar, sodium and saturated fats, and low in fiber, vitamins and other beneficial micronutrients.

RESOURCES:

• MAHA Report Recognizes Solutions Within Agriculture
• FB.org Healthier America 
• Feed Post: Talking Points: Healthy & Sustainable Farming (MAHA)(subscription required)

Questions for Policy Development:

The 2025 AFBF Policy Book does not mention “ultra-processed foods.”

1) Since AFBF does not have specific policy defining “ultra-processed foods,” should our policy address this issue and define “ultra-processed foods”?

Action for State Farm Bureaus:

During your Policy Development process, we recommend that policy recommendations be submitted through the regular process for review during the Resolutions Meeting in December 2025. This policy issue may be addressed under Policy 345 / Labeling. If approved by the Delegates, staff recommend a new policy sub section 19.