October 23, 2025
The Honorable Martin A. Makary, MD, MPH
Commissioner
Food and Drug Administration
10903 New Hampshire Ave.
Silver Spring, MD 20993
Re: Docket No. FDA-2025-N-1793
Dear Dr. Makary:
The National Council of Farmer Cooperatives (NCFC) appreciates the opportunity to submit comments in response to the Food and Drug Administration’s (FDA) request for information on developing a uniform definition of “ultra-processed foods” (UPFs) for human food products in the U.S. food supply.
Introduction
Since 1929, NCFC has been the voice of America’s farmer cooperatives. Our members are regional and national farmer cooperatives, which are in turn comprised of nearly 3,000 local farmer cooperatives across the country. NCFC members also include twenty-six state and regional councils of cooperatives.
Farmer-owned cooperatives handle, process, and market almost every type of agricultural commodity and provide consumers with nutritious, affordable, and shelf-stable food throughout the year. They also furnish farm supplies and provide credit and related financial services, including export financing. Nationwide, farmer cooperatives provide over 250,000 jobs, with a total payroll of more than $8 billion, and contribute significantly to the economic well-being of rural America.
NCFC strongly supports the federal government’s goal of promoting public health and transparency. As the FDA considers establishing a formal definition of “ultra-processed foods,” we urge the agency to adopt a science-based, practical, and nutrition-focused approach that aligns with the USDA’s Dietary Guidelines for Americans (DGA). The DGA provides a well-established, evidence-based foundation for evaluating food choices within the broader context of dietary patterns and nutrient adequacy.
Guiding Principles
1. Distinguish between processing and ultra-processing
Processing is an essential part of ensuring food safety, quality, and accessibility — goals that the Dietary Guidelines for Americans, 2020–2025, explicitly recognize as important for supporting healthy eating patterns across all populations. Activities such as washing, drying, pasteurizing, canning, and juicing are vital to prevent foodborne illness, reduce waste, and extend the shelf life of nutrient dense foods while maintaining nutrient integrity.
A uniform definition should therefore clearly differentiate between beneficial processing and ultra-processing that fundamentally alters the composition or purpose of a food. Traditional preservation methods that maintain or enhance nutritional quality should not be classified as “ultra-processed.”
2. Focus on overall dietary patterns, not isolated ingredients
The DGA emphasizes that “nutritional needs should be met primarily through nutrient-dense foods and beverages” and that “the combination of foods and beverages that people consume over time matters more than individual foods or nutrients.” Consistent with this evidence-based approach, the FDA’s definition of ultra-processed foods should evaluate foods within the context of overall diet quality, not penalize products for containing a specific ingredient that serves a functional or safety purpose.
For example, the use of ascorbic acid (vitamin C) as an antioxidant or pectin as a natural stabilizer in fruit products should not render these foods “ultra-processed,” since they remain nutrient-dense and aligned with DGA recommendations to consume fruits in varied forms.
3. Avoid overbroad or ingredient-count–based definitions
Rigid definitions based solely on the number of ingredients or the presence of a disfavored additive list could inadvertently capture nutritious foods encouraged by the Dietary Guidelines, such as canned or dried fruits, fruit juices, or whole-grain products. The DGA explicitly recognizes that canned, frozen, and dried forms of fruits and vegetables contribute to fruit and vegetable intake and help Americans meet dietary recommendations.
Therefore, the FDA should ensure that any definition of “ultra-processed” does not conflict with the DGA’s message that these processed products can be part of a healthy dietary pattern.
4. Align with established regulatory frameworks
To ensure clarity for consumers and consistency across nutrition policy, the definition of UPFs should align with established regulatory frameworks, such as the FDA’s “healthy” definition and qualified health claims process, which reflect current dietary science.
Furthermore, foods encouraged by federal dietary guidance or recognized as “healthy” under the FDA’s nutrient content claim definition should not be categorized as ultra-processed. Such conflicting characterizations would be misleading and confusing to consumers. Similarly, the agencies must also consider the role of qualified health claims, which reflect credible scientific evidence linking certain nutrients or food products to reduced risk of certain acute and chronic diseases. Categorizing a food as ultra-processed when it is eligible for a qualified health claim would also be contradictory and confusing. While the definition offers a useful framework, it should not be the sole determinant in evaluating the nutritional value of foods, particularly those that contribute to shortfall nutrients or serve important roles in public health.
5. Use a science-based, multidimensional definition
The Dietary Guidelines rely on a total diet approach, integrating nutrient profiles, food groups, and overall energy balance. Similarly, a definition of ultra-processed foods should consider three intersecting factors:
-
-
- Degree and purpose of processing – whether the process preserves, stabilizes, or fundamentally reconstitutes food components;
- Nature of ingredients used – distinguishing traditional food ingredients from novel or synthetic substances; and
- Nutritional and dietary contribution – evaluating nutrient density, added sugar, sodium, and saturated fat in context.
This approach mirrors the DGA’s focus on food quality rather than rigid exclusion based on production or processing steps.
6. Recognize potential unintended consequences
If defined too broadly, “ultra-processed food” could stigmatize safe, wholesome products and discourage fruit and vegetable consumption, contrary to DGA recommendations. The DGA notes that “most Americans do not consume enough fruits, vegetables, and whole grains”, and that strategies to improve diet quality should focus on increasing access to all forms of these foods, including fresh, frozen, canned, dried, and 100% juice.
A definition that classifies these foods as “ultra-processed” could create confusion and undermine federal nutrition policy coherence between FDA, USDA, and HHS.
Conclusion
NCFC supports evidence-based nutrition policy and consumer transparency. We urge the agency to consider the following:
-
-
- Align any UPF definition with existing regulatory frameworks, including the USDA Dietary Guidelines for Americans and FDA “healthy” definition and qualified health claims process, emphasizing nutrient density and overall dietary patterns;
- Distinguish between beneficial food processing and ultra-processing that alters a product’s fundamental character or nutritional quality;
- Avoid definitions that could discourage consumption of safe, nutrient-rich processed foods such as dried fruits, fruit juice, and canned fruits; and
- Conduct impact assessments on how a UPF definition could affect supply chains for nutritious processed foods and consumer access to affordable foods.
Our nation’s farmer-owned cooperatives are committed to producing and processing foods that nourish Americans and reduce food waste, in full alignment with the Dietary Guidelines’ call to “make every bite count.”
Sincerely,
Duane Simpson
President & CEO
NCFC Submits Comments to the Food and Drug Administration RFI on Developing Definition for “Ultra-Processed Foods”
October 23, 2025
The Honorable Martin A. Makary, MD, MPH
Commissioner
Food and Drug Administration
10903 New Hampshire Ave.
Silver Spring, MD 20993
Re: Docket No. FDA-2025-N-1793
Dear Dr. Makary:
The National Council of Farmer Cooperatives (NCFC) appreciates the opportunity to submit comments in response to the Food and Drug Administration’s (FDA) request for information on developing a uniform definition of “ultra-processed foods” (UPFs) for human food products in the U.S. food supply.
Introduction
Since 1929, NCFC has been the voice of America’s farmer cooperatives. Our members are regional and national farmer cooperatives, which are in turn comprised of nearly 3,000 local farmer cooperatives across the country. NCFC members also include twenty-six state and regional councils of cooperatives.
Farmer-owned cooperatives handle, process, and market almost every type of agricultural commodity and provide consumers with nutritious, affordable, and shelf-stable food throughout the year. They also furnish farm supplies and provide credit and related financial services, including export financing. Nationwide, farmer cooperatives provide over 250,000 jobs, with a total payroll of more than $8 billion, and contribute significantly to the economic well-being of rural America.
NCFC strongly supports the federal government’s goal of promoting public health and transparency. As the FDA considers establishing a formal definition of “ultra-processed foods,” we urge the agency to adopt a science-based, practical, and nutrition-focused approach that aligns with the USDA’s Dietary Guidelines for Americans (DGA). The DGA provides a well-established, evidence-based foundation for evaluating food choices within the broader context of dietary patterns and nutrient adequacy.
Guiding Principles
1. Distinguish between processing and ultra-processing
Processing is an essential part of ensuring food safety, quality, and accessibility — goals that the Dietary Guidelines for Americans, 2020–2025, explicitly recognize as important for supporting healthy eating patterns across all populations. Activities such as washing, drying, pasteurizing, canning, and juicing are vital to prevent foodborne illness, reduce waste, and extend the shelf life of nutrient dense foods while maintaining nutrient integrity.
A uniform definition should therefore clearly differentiate between beneficial processing and ultra-processing that fundamentally alters the composition or purpose of a food. Traditional preservation methods that maintain or enhance nutritional quality should not be classified as “ultra-processed.”
2. Focus on overall dietary patterns, not isolated ingredients
The DGA emphasizes that “nutritional needs should be met primarily through nutrient-dense foods and beverages” and that “the combination of foods and beverages that people consume over time matters more than individual foods or nutrients.” Consistent with this evidence-based approach, the FDA’s definition of ultra-processed foods should evaluate foods within the context of overall diet quality, not penalize products for containing a specific ingredient that serves a functional or safety purpose.
For example, the use of ascorbic acid (vitamin C) as an antioxidant or pectin as a natural stabilizer in fruit products should not render these foods “ultra-processed,” since they remain nutrient-dense and aligned with DGA recommendations to consume fruits in varied forms.
3. Avoid overbroad or ingredient-count–based definitions
Rigid definitions based solely on the number of ingredients or the presence of a disfavored additive list could inadvertently capture nutritious foods encouraged by the Dietary Guidelines, such as canned or dried fruits, fruit juices, or whole-grain products. The DGA explicitly recognizes that canned, frozen, and dried forms of fruits and vegetables contribute to fruit and vegetable intake and help Americans meet dietary recommendations.
Therefore, the FDA should ensure that any definition of “ultra-processed” does not conflict with the DGA’s message that these processed products can be part of a healthy dietary pattern.
4. Align with established regulatory frameworks
To ensure clarity for consumers and consistency across nutrition policy, the definition of UPFs should align with established regulatory frameworks, such as the FDA’s “healthy” definition and qualified health claims process, which reflect current dietary science.
Furthermore, foods encouraged by federal dietary guidance or recognized as “healthy” under the FDA’s nutrient content claim definition should not be categorized as ultra-processed. Such conflicting characterizations would be misleading and confusing to consumers. Similarly, the agencies must also consider the role of qualified health claims, which reflect credible scientific evidence linking certain nutrients or food products to reduced risk of certain acute and chronic diseases. Categorizing a food as ultra-processed when it is eligible for a qualified health claim would also be contradictory and confusing. While the definition offers a useful framework, it should not be the sole determinant in evaluating the nutritional value of foods, particularly those that contribute to shortfall nutrients or serve important roles in public health.
5. Use a science-based, multidimensional definition
The Dietary Guidelines rely on a total diet approach, integrating nutrient profiles, food groups, and overall energy balance. Similarly, a definition of ultra-processed foods should consider three intersecting factors:
This approach mirrors the DGA’s focus on food quality rather than rigid exclusion based on production or processing steps.
6. Recognize potential unintended consequences
If defined too broadly, “ultra-processed food” could stigmatize safe, wholesome products and discourage fruit and vegetable consumption, contrary to DGA recommendations. The DGA notes that “most Americans do not consume enough fruits, vegetables, and whole grains”, and that strategies to improve diet quality should focus on increasing access to all forms of these foods, including fresh, frozen, canned, dried, and 100% juice.
A definition that classifies these foods as “ultra-processed” could create confusion and undermine federal nutrition policy coherence between FDA, USDA, and HHS.
Conclusion
NCFC supports evidence-based nutrition policy and consumer transparency. We urge the agency to consider the following:
Our nation’s farmer-owned cooperatives are committed to producing and processing foods that nourish Americans and reduce food waste, in full alignment with the Dietary Guidelines’ call to “make every bite count.”
Sincerely,
Duane Simpson
President & CEO
Related Resources
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NCFC Comments to FDA on Proposed Definition of Healthy Rule
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