istockphoto

by Alexandra Holzinger, VRG intern

In recent years, the concept of an “ultra-processed food” (UPF) has become a growing focus of public health policy across the U.S. It stems from concerns about the relationship between highly processed foods, and increased risk of heart disease, high cholesterol, obesity, and other chronic diseases. As policymakers respond to these health concerns, they must first establish formal definitions and classification systems to determine which foods should be subject to regulation. So far, a system developed by researchers in Brazil, called the NOVA food classification system, has been the blueprint. NOVA groups foods into unprocessed or minimally processed foods, processed foods, and ultra-processed foods based upon the processing methods, extent of processing, and additives required to produce each food.¹ State legislatures have developed definitions for UPFs, similar to those of the NOVA system, to use in policies designed to improve the nutritional value of school meals and support children’s health.

As states consider restricting ultra-processed foods in school meals, common criteria involve the presence of certain additives, or by broader characteristics such as high levels of sugar, sodium, saturated fat, or processing aids.^2-15 Although these policies are intended to improve children’s diets, the definitions may also capture some nutritious plant-based foods. Many plant-based products rely on stabilizers, emulsifiers, or fortifiers to maintain texture, functionality, and nutritional value; yet they still fall into some states’ definition of a UPF. Plant milks are especially at risk, since almost every plant milk currently available in schools contains at least one emulsifier or stabilizer.^16-20 For students, fortified plant milks and plant-based protein products can be important sources of calcium, protein, vitamins A and D, riboflavin, vitamin B12, magnesium, phosphorus, and potassium.²¹ Regulations that rely primarily on the presence of specific additives, rather than evaluating a food’s overall nutritional value, may unintentionally limit access to these foods in school meal programs.

Several approaches could help schools balance the need to restrict foods linked to illness and disease while maintaining accessibility for vegan and vegetarian students. Moving forward, policymakers may wish to consider exemptions or alternative criteria for healthy fortified foods that provide key nutrients. As schools continue to improve the nutritional quality of their meals, considering the overall dietary implications of certain foods in addition to the degree of processing may help ensure that all students have access to healthy, balanced meals.

For more information about school meal regulations, visit:

vrg.org/blog/2026/08/31/state-legislation-regarding-ultra-processed-foods-possible-effects-on-vegan-diets

.vrg.org/blog/2026/09/24/ultra-processed-foods-in-the-senate-whats-going-on

References

¹ Food classification Nova | nupens. (2023). In Nupens | Center for Epidemiological Research in Nutrition and Health. nupens.fsp.usp.br/en/food-classification-nova

² Ultra-Processed Food, no. SB 1826, The Florida Senate (2025). flsenate.gov/Session/Bill/2025/1826

³ Relating to prohibiting ultraprocessed food from being served or sold to students in public schools., (2025) (testimony of Partisan Bill), 89(R) HB 3292, Texas Legislature (2025). capitol.texas.gov/Search/DocViewer.aspx?DocId=89RHB032921B&AllWords=&AnyWords=ultraprocessed&ExactWords=&CustomWords=&DocType=B

⁴ SNAP Lunches no. S. 589, South Carolina General Assembly (2025). scstatehouse.gov/sess126_2025-2026/bills/589.htm

⁵ SNAP Lunches no. H. 4339, South Carolina General Assembly (2025), scstatehouse.gov/sess126_2025-2026/bills/4339.htm

⁶ AL HB580. Alison Legislature State Alabama (2026). alison.legislature.state.al.us/files/pdf/SearchableInstruments/2025RS/HB580-int.pdf

⁷ AN ACT Relating to School Nutrition 25Rs HB 439. Kentucky General Assembly (2025). apps.legislature.ky.gov/record/25rs/hb439.html

⁸ Ultra Processed Foods in Schools, MHB2887, Missouri House of Representatives. (2026). house.mo.gov/billdocumentmobile.aspx?year=2026&code=r%20&bill=hb2887

⁹ An Act Concerning Ultraprocessed Food, S946, New Jersey Legislature. (2026) njleg.state.nj.us/bill-search/2026/S946/bill-text?f=S1000&n=946_I1

¹⁰ House Bill 874, North Carolina General Assembly. (2025). ncleg.gov/billlookup/2025/h874

¹¹ Arizona Healthy Schools Act, no. 2164, Arizona House of Representatives (2025). azleg.gov/legtext/57leg/1R/laws/0052.pdf

¹² Foods Additives in Schools, no. HB0402, Utah House of Representatives (2025). le.utah.gov/~2025/bills/static/HB0402.html

¹³ Pupil nutrition: restricted school foods and ultraprocessed foods of concern: prohibition, no. AB-1264, California Legislative Information (2025). leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260AB1264

¹⁴ House Bill 5507, Illinois General Assembly (2026). ilga.gov/Legislation/BillStatus/FullText?GAID=18&DocNum=5507&DocTypeID=HB&LegId=167481&SessionID=114

¹⁵ An act Amending the act of March 10, 1949 (P.L.30, No.14), entitled “An act relating to the public school system, including certain provisions applicable as well to private and parochial schools; amending, revising, consolidating and changing the laws relating thereto,” in school health services, providing for unhealthy ultra-processed food prohibited in competitive Foods.”, no. HB1132, The General Assembly of Pennsylvania (2025). palegis.us/legislation/bills/text/PDF/2025/0/HB1132/PN1417

¹⁶ 8th Continent Original Soymilk, half gallon, Price Rite. (2026). priceritemarketplace.com/sm/planning/rsid/127/product/8th-continent-original-soymilk-half-gallon-00053859070663 (accessed July 26th, 2026)

¹⁷ Original Dairy-Free Plant-Based Milk, Ripple Foods (2026). dev.ripplefoods.com/original-plant-milk (accessed July 26th, 2026)

¹⁸ PEARL® Organic Soymilk Smart Original, Kikkoman USA (2026). kikkomanusa.com/products/pearl-organic-soymilk-smart-original (accessed July 26th, 2026)

¹⁹ Pacific Foods® Original Ultra Soy Milk, Plant Based Milk, Campbells Food Service (2026). campbellsfoodservice.com/product/ultra-soy-original-beverage (accessed July 26th, 2026)

²⁰ Original Soymilk | Silk®, Silk (2026). silk.com/plant-based-products/soymilk/original-soymilk (accessed July 26th, 2026)

²¹ The Vegetarian Resource Group Blog. Vrg.org2026. Accessed July 29, 2026. vrg.org/blog/2026/02/24/what-are-some-of-the-brands-of-plant-milks-that-can-be-used-in-the-national-school-lunch-program