September 8, 2025

The Vegetarian Resource Group (VRG) welcomes the opportunity to comment on the USDA’s and FDA’s Request for Information to help develop a uniform definition of ultra-processed foods for human food products in the U.S. food supply.

Nutritionally deficient ultra-processed foods including soft drinks, candies, salty snacks, processed meats, and baked desserts are an excessive part of the diet of many American children and adults. The negative health effects of diets high in these types of foods has long been recognized. There are, however, foods that could be categorized as “ultra-processed” that do have the same negative health effects as other food categorized as “ultra-processed.”

Although there have been a variety of attempts to define “ultra-processed” food including those by various U.S. states, the definitions generally suffer from an inability to differentiate between foods which can have negative health effects and those where processing can be beneficial or have a neutral effect. An example of negative health effects would be processes by which sugars, salt, saturated fats, and other substances associated with negative health are added to foods. Positive health effects could include food fortification, or processing to improve bioavailability of vitamins and minerals.

The Nova system identifies ultra-processed foods as foods that are ready to heat or to eat with little or no preparation (1,2). Foods in this category have undergone processes such as salting, baking, frying, pickling, and canning. They are typically high calorie, high sodium, low fiber foods that contain little protein, and few vitamins or minerals. Regrettably, many foods, such as plant milks and commercial veggie burgers, that may be eaten by vegetarians, vegans, and others seeking to reduce consumption of animal products are categorized as ultra-processed foods (3-5). It is impossible to equate a fortified soy milk and a soft drink in terms of nutritional quality or potential health effects.

Cow’s milk is considered a minimally processed food; in contrast, fortified soymilk has been classified as an ultra-processed food. A recent study examined the effect of substituting soymilk for cow’s milk (6). Substituting soymilk for cow’s milk resulted in a reduction in blood pressure, LDL cholesterol, and C-reactive protein. Substituting soymilk for cow’s milk did not affect blood glucose, diabetes control, or insulin levels and had no effect on body weight or BMI (6). These results raise questions about the categorization of fortified soymilk as an ultra-processed food.

A variety of research studies have found all foods categorized as ultra-processed do not have identical effects on the risk of heart disease and stroke (7,8), cancer (8), diabetes (8, 9), cognitive impairment (10), body weight (11), and frailty (12).

For example, a study of more than 200,000 U.S. adults found that only processed meats and sugar-sweetened beverages were associated with an increased risk of heart disease and stroke while ultra-processed savory snacks and cold cereals were associated with a lower risk of heart disease (7). Additionally, a higher intake of ultra-processed breads and cereals was associated with a lower risk of stroke (7). This study suggests that different types of ultra-processed foods have different effects on the risk of heart disease and stroke.

Similarly, a study of more than 260,000 adults found that higher consumption of ultra-processed animal-based products and artificial and sugar-sweetened beverages was associated with a higher risk of multimorbidity (developing at least two chronic diseases, namely cancer, heart disease, and/or type 2 diabetes) (8). Higher consumption of ultra-processed plant-based alternatives or ultra-processed breads and cereals was not associated with an increased risk of multimorbidity (8). Clearly, a more nuanced analysis of ultra-processed foods is warranted prior to developing labeling recommendations.

A study of more than 110,000 U.S. adults found an increased risk of type 2 diabetes in those with the highest consumption of ultra-processed foods (9). Subgroup analysis found higher consumption of certain food groups including breads made with refined flour, artificially and sugar-sweetened beverages, and animal-based products was associated with higher risk of type 2 diabetes. In contrast, higher consumption of foods that were classified as ultra-processed including cereals, whole-grain breads, and packaged sweet and savory snacks was associated with lower risk of type 2 diabetes (9).

A study of 4,750 middle-aged and older U.S. adults found that consuming an additional serving a day of ultra-processed animal products was associated with a 17% higher risk of developing cognitive impairment (10). An additional serving a day of ultra-processed beverages (like sugar-sweetened soft drinks) was associated with a 6.3% higher risk of developing cognitive impairment (10). Higher ultra-processed food consumption overall was not associated with a higher risk of developing cognitive impairment nor was higher consumption of ultra-processed snacks, grains, or sweets (10).

These studies and other similar studies that look at sub-categories of ultra-processed foods strongly support the idea that a blanket categorization of foods as ultra-processed will be confusing and is unlikely to provide health benefits. It may result in the avoidance of foods with health benefits.

Data indicate that the health effects of ultra-processed foods are highly dependent on their nutritional quality (13). We support the evaluation of foods based on their nutritional and health effects, rather than solely focusing on the degree of processing. At this time, it is premature to unequivocally call for avoiding all ultra-processed foods. Additional careful study is needed before characterizing certain foods as “ultra-processed.” Ultimately, a subset of what are now classified as ultra-processed foods would be developed and would encompass those ultra-processed foods or categories of foods that are associated with clear public health risks. Other foods that are currently classified as “ultra-processed” would be placed in a different category, such as the one proposed by the American Society for Preventive Cardiology (14). The American Society for Preventive Cardiology has proposed a new category of “smartly processed” foods which includes fortified plant milks and plant protein-based meat and egg substitutes (14). Whole-grain breads and commercial bean spreads could also be in this category. The American Society for Preventive Cardiology describes “smartly processed foods” as low in saturated fat, refined carbohydrates, and cholesterol and states that these foods can add nutrition value (14). This sort of categorization system that takes into consideration the nutritional quality of the food is more helpful than simply categorizing foods as “ultra-processed.”

Until additional research is completed, documents such as Dietary Guidelines for Americans provide useful guidance and were developed to provide current information and to utilize evidence-based research and a stringent process to develop recommendations for foods to eat and foods to limit. These documents provide support for a marked reduction in consumption of those ultra-processed foods that are high in saturated fat, added sugars, and salt. Clearly identifying these foods on food labels and working with food companies to improve the composition of these foods should be a priority. Consumption of other foods currently categorized as “ultra-processed” that are of better quality, such as fortified plant milks, some plant-based meat alternatives, bean spreads, and whole grain breads should not be discouraged, and these foods should be included as part of a healthy dietary pattern (15).

VRG is an independent non-profit organization dedicated to educating the public on vegetarianism and the interrelated issues of health, nutrition, environment, ethics, and world hunger. Our health professionals, activists, and educators work with businesses and individuals to bring about healthy changes in schools, workplaces, and the community. Registered dietitians and physicians aid in the development of nutrition-related publications and answer questions about the vegetarian and vegan diet. For the past 31 years, we have commissioned polls exploring vegetarian-related issues, results of which are often used by researchers, the food industry, and the media. Financial support comes primarily from memberships, contributions, and book sales.

Thank you for the opportunity to comment on this issue.

Sincerely,

Reed Mangels, PhD, RD

Nutrition Advisor, The Vegetarian Resource Group

Charles Stahler

Co-Director, The Vegetarian Resource Group

Debra Wasserman

Co-Director, The Vegetarian Resource Group

References

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