Defining and Delineating Ultra-Processed Foods  These comments are submitted on behalf of the Heartland Health Research Alliance (HHRA), a non-profit organization conducting research on the impacts of farming systems on the environment and public health (hh-ra.org), and the Swette Center for Sustainable Food Systems at Arizona State University. HHRA and the Swette Center submitted comments dated July 15, 2025 to the FDA on its proposed front-of-package nutrition labeling system. In February, 2023, HHRA and the Swette Center submitted comments to the FDA on the definition of “healthy” food and related measurement challenges. In our 2023 comments, we recommended adoption of novel metrics to quantify food nutritional quality as part of an analytical system called NuCal; two co-authors of these comments (Benbrook, Mesnage) published a paper describing NuCal in 2024. The co-authors of these comments on ultra-processed foods are (alpha): Mr. Dan Barber, Chef and Co-Owner, Blue Hill Restaurant at Stone Barns. Dr. Charles Benbrook, former Executive Director of HHRA. Anne Biklé, science writer who, with David Montgomery, authored What Your Food Ate: How to Heal Our Land and Reclaim Our Health (2022). Dr. Asa Bradman, University of California, Merced and member of the HHRA Board of Directors. Dr. Steven Chen, Chief Medical Officer of the Recipe4Health, a food-as-medicine program in Alameda County, California. Dr. Donald R. Davis, retired nutrition scientist who has conducted extensive research on historical changes in food nutrient content. Mr. Alan Lewis, Vice President for Government Affairs, Stakeholder Relations, and Organic Compliance at Natural Grocers. Dr. Kathleen Merrigan, Executive Director of the Swette Center, Chair of HHRA’s Public Policy Advisory Committee, and former USDA Deputy Secretary. Dr. Robin Mesnage, scientist conducting genomics and metabolic research on food safety and nutritional quality at the Buchinger Wilhelmi Clinic in Uberlinger, Germany. Mesnage and HHRA science advisor. Dr. David Montgomery, professor of geomorphology at the University of Washington in Seattle, and expert on how soil health impacts food nutritional quality and human health. Ms. Mary Purdy, MS, RDN, Managing Director of the Nutrient Density Alliance and Adjunct Faculty at the Culinary Institute of America. Mr. Bob Quinn, PhD, founder of Kamut International, and an organic farmer in Montana who has recently founded a regenerative organic research institute on a portion of his farm. Dr. Adam Shriver, Director of Wellness and Nutrition at the Harkin Institute at Drake University in Des Moines, Iowa. Dr. Andrew Smith, Chief Scientific Officer of the Rodale Institute. Mr. Tom Willey, retired California organic farmer and host of the “Down on the Farm” podcast. Access to multiple documents drawn upon in the preparation of these comments is provided via hyperlinks in the text. Citations to published papers appear in “References”.   Table of Contents I. Summary and Key Recommendations. II. Why Define, Measure, and Label Food by Degree of Processing? A. Evidence Linking Processed Foods to Adverse Public Health Outcomes Has Not Been Matched by Efforts to Reverse the Decline in Food Quality and Safety. B. Classifying Foods by Degree of Processing. 1. Food-as-medicine Programs Bring New Focus on Food Nutritional Quality. 2. A Key Challenge Confronting the FDA and USDA. C. Terminology and Focus. III. Taking Account of Food Manufacturing in Delineating the Degree of Processing A. Key Concerns and Metrics Needed to Identify UPF. 1. What’s Lost? 2. Nutritional Quality Should be the Bedrock Metric. 3. What’s Added? 4. New Risks? B. Classifying the Degree of Processing in Food Products. 1. Generic Food Processing Classification Criteria Applicable to All Products. 2. Food Group Specific Criteria Needed in Classifying the Impacts of Processing. C. Vetting the System to Achieve Continuous Improvement. IV. Questions Posed by the FDA-USDA. A. Supporting Cohesive Research, Continuous Improvement, and Consistent Guidance to Consumers B. Responses to Questions 1-5 Posed by the FDA-USDA. V. Conclusions and Recommendations. References.   I.             Summary and Key Recommendations Improving the safety and nutritional quality of ultra-processed foods (UPF) is among the most promising — and attainable — options to enhance the health of the American public. Doing so will require major changes in policy, technology, consumer awareness, and market dynamics. Manufacturing and selling unhealthy UPFs is profitable and accepted in the US. For this reason, chronic diseases rooted in unhealthy food and dietary patterns, including metabolic syndrome, Type 2 diabetes, and cardiovascular disease, are undermining well-being. Health costs will also continue rising. We commend the FDA and USDA for seeking guidance on how to define and classify foods based on the impacts of processing. Government action will be essential to achieve meaningful improvements in public health. Left unchecked, current trends will exacerbate already serious health, policy, and fiscal crises. To turn the tide, manufacturing safe and nutritious UPF must become the most profitable option for the food industry. Forging consensus on how to define and measure the degree of processing is an essential first step. We argue this must be done through the lens of public health. Metrics used to measure the degree of processing in a finished food product must be grounded in changes in the nutritional quality and safety of food products, and ultimately, impacts on public health outcomes. Defining and classifying mostly whole and fresh foods is straightforward. The degree of processing in a finished processed food product, and its impacts on public health, should be determined as a function of: Nutrients and health-promoting phytochemicals that are lost or altered as a result of processing, What is added in recipes, or via processing technologies, and Whether, and to what extent, milling, oil extraction, other processing methods, and cooking creates new, or exacerbates existing, food safety hazards. The foundational metric should be the percentage loss of nutritional quality as a result of processing. Such a calculation should be made across all individual nutrients with a Recommended Dietary Allowance, or an equivalent daily intake benchmark required to sustain good health. The total amount of each essential nutrient in the raw ingredients required to manufacture a serving of processed food should be measured, just as the food industry now does for nutrients featured in […]

Multiple lines of evidence point to consumer food choices as major contributors to diet-related disease, and poor health and fitness. In a peer-reviewed journal article published today, authors Chuck Benbrook and Robin Mesnage cite studies indicating that “Some 90% of the estimated USD 4.3 trillion in annual health care costs in the US is triggered or made worse by poor food quality and diet-related disease.” Benbrook is the founder and former executive director of the Heartland Health Research Alliance (HHRA). The authors recommend novel metrics on both the nutrient density of food, and how to more accurately and usefully characterize the degree of food processing and its impacts on public health. The article is open access in the journal Foods and entitled “Enhanced Labeling to Promote Consumption of Nutrient Dense Foods and Healthier Diets.” The core nutrient density metric is a ratio: the percent of daily nutrient needs satisfied by a serving of food relative to the percent of a 2000 calorie daily diet taken up by the serving of food. This single metric is unmatched in comprehensively reflecting the nutritional quality of food. A graphic option to convey the metric on packaging is presented in Figure 3 in the new paper: A novel graphic is presented in Figure 5 to which integrates both the nutrient density and food processing metrics and graphics in a single graphic, shown below. The impacts of ultra-processed food (UPF) on public health outcomes is among the hottest topics in nutrition, medical, and public health journals, and media coverage on food quality and health outcomes. At the request of the journal, the authors developed a video abstract that explains the paper’s goals, methods, and key findings and recommendations. The authors conclude their paper with these observations: Transparent and accurate food product-specific ingredient and nutrient composition data should determine the content of nutrition health labeling. Efforts to soften the message should be resisted in light of the overwhelming need for new food labels that help bring about substantial improvements in food nutritional quality and dietary choices. Benbrook and Mesnage’s paper builds on public comments HHRA submitted in response to the US Food and Drug Administration (FDA) proposed rule in 2023 to update the definition of the term “healthy” on food labels. The proposed role would require foods labeled “healthy” to contain minimum amounts of foods recommended by USDA’s Dietary Guidelines, and to limit saturated fat, sodium, added sugar and other less healthy nutrients. Entitled “Food Labeling: Nutrient Content Claims; Definition of Term `Healthy’”, the comments recommended new  nutrition/health messaging on the front of food packaging. Co-authors of comments included the chair of HHRA’s Policy Advisory committee Dr. Kathleen Merrigan, HHRA science advisors, and other experts working on how changes in farming systems and technology can increase the nutritional quality of food: Dr. Hannah Flower, Dr. Donald R. Davis, Dr. David Montgomery and Anne Biklé. In the comments, the authors introduced “NuCal” as a name for their new system. Resources HHRA February 2023 comments to the FDA. Benbrook and Mesnage (2024). Enhanced Labeling to Promote Consumption of Nutrient Dense Foods and Healthier Diets, Foods. https://doi.org/10.3390/foods13213377 Video Abstract: “Enhanced Labeling to Promote Consumption of Nutrient Dense Foods and Healthier Diets”

HHRA and ORG-Tracker, represented by Dr. Chuck Benbrook and Dr. Brian Baker, submitted comments to the Agricultural Marketing Service at the USDA in advance of the National Organic Standards Board (NOSB) meeting in Portland, Oregon, from October 22nd to 24th, 2024. Drs. Benbrook and Baker will both attend the conference and deliver public comments. ORG-Tracker is a project carried out by HHRA. It aggregates pesticide residue data from inspections of organic farms carried out by certifiers. The tables generated by ORG-Tracker utilize the results of certifier testing to compare residue frequency and risk levels to food produced on conventional farms. The team is working to more effectively highlight gaps and challenges faced by certification agencies to answer questions like What crops should we be testing, and where? Is a pesticide residue found in an organic sample likely caused by accident, pesticide drift, or an intentional and illegal application? How can we modify organic programs to better mitigate risk? The comments delivered to the USDA discuss risk-based certification, pesticide residue testing, and policies impacting the incorporation of so-called inert ingredients in the biopesticides approved for use on organic farms. They argue for a more rigorous, comprehensive, and health-focused approach to risk oversight. Regarding residue testing, they advocate for more expansive and effective data aggregation to inform consumers and the organics community. Finally, for inert ingredients, they recommend further review of current policy, including increased transparency of ingredients in pesticide products. Thank you to Drs. Benbrook and Baker for your advocacy and hard work!   The three sets of comments are posted on HHRA’s website as part of our policy program: Comments to the NOSB on the Risk-Based Certification Discussion Document Under Consideration During the October 2024 Meeting in Portland, Oregon Written Comments on the NOSB Discussion Document “Residue Testing for the Global Supply Chain” Comments on the Inert Ingredients in Organic Pesticide Products Proposal dated August 13, 2024   Drs. Benbrook and Baker also submitted and presented comments at the Spring 2024 meeting of the NOSB, which are available on HHRA’s Policy and Regulatory Reform page.

Dr. Yolton is a developmental psychologist and epidemiologist serving as Professor of Pediatrics at Cincinnati Children’s Hospital Medical Center. Her interests include exposures and experiences that may alter a child’s developmental trajectory from infancy through adolescence. She collaborates on research projects on typical child development as well as those focused on the impact of exposures to environmental toxicants, opiates and stress during early development.

  Paul Hartnett has served as HHRA’s CFO since our founding . With the departure of Russell King, Paul has now joined the board and Executive Director. We thank Russell for his service and wish him the best in his future endeavors.