By: Tom Green, HHRA Board Chair and Kathleen Merrigan, Chair, Policy Advisory Committee
Excessive intakes of unhealthy processed foods are driving deeply worrisome trends in public health that every American family is aware of, and likely impacted by. Problems arising in the wake of industrial-scale, processed food manufacturing have grown steadily more severe over the last half century.
On October 16th, the New York Times published “How America Got Hooked on Ultraprocessed Food”. It catalogues how processed foods have come to dominate caloric intake in 2025. Coca-cola was first marketed in 1886. Remember Tang, and the 8 ways Wonder Bread builds strong bodies?
The public is now painfully aware that their food choices matter. But to drive change, eaters need credible, consistent, and actionable information on which foods are healthy, and not so healthy, and just plan unhealthy.
If this is done without sugar-coating and soft-peddling, the stage will be set for rapid progress. But providing consumers such information will be vigorously contested by those currently profiting from nationwide sales of many UPF brands.
An Evolving MAHA Priority
The FDA and USDA published a request for public guidance on how to identify UPFs in July. HHRA and the Swette Center convened a diverse team to write the UPF comments that have just been submitted to the FDA-USDA.
Our comments urge the government to define and quantify the impacts of food processing through the lens of public health. Doing so will require three metrics. A first to quantify the nutrients lost as raw ingredients are converted into finished processed foods.
A second “What’s Added?” metric to reflect the quantity of supplemental nutrients added into a finished food product, typically to replace nutrients lost in milling and processing. And a third “New Risks?” metric to capture, to the extent possible, the degree to which processing creates new, or increases existing, food safety risks, or adversely alters nutrient bioavailability.
Our food processing comments explain how the above metrics can be calculated, and then drawn upon in classifying processed foods in terms of healthfulness. Table 1 below summarizes a way such metrics could be used in delineating zones along a continuum of food processing impacts.
Our food processing comments build on earlier comments to the FDA.
February, 2023 comments by HHRA and the Swette Center responded to a FDA proposed rule on how to define and quantify food nutritional quality.
We recommended that nutritional quality be quantified using a metric that takes into account the number and concentrations of health-promoting nutrients in a serving of food, coupled with caloric content.
A second set of HHRA-Swette Center comments was submitted to the FDA in July, 2025. These comments responded to another proposed rule focused on how to optimally communicate nutritional quality information via front-of-package (FOP) labeling. We recommended the FDA require FOP labeling based on the nutritional quality and processing metrics in what we call the “NuCal” system.
Optimal Delivery of Nutritional Quality and Processing Information
A study published just this month in JAMA Network Open compared six options for delivering nutritional quality information. These included the FDA’s 2025 proposal, combinations of “High In” and other positive messages, and what is called a “spectrum” label.
The spectrum option utilizes a single, integrated measure of nutritional quality that takes account of both positive attributes (e.g., “high in calcium” or “promotes heart health”), as well as negative factors (e.g., excessive added salt, sugar, or fat). .
The recent study concludes that spectrum labels were the most effective, and that none of the other five options led to healthier food choices.
In our just-submitted comments, we recommend just such a “spectrum” metric and graphic display to convey both nutritional quality and food processing information, as shown below.
The government is likely to issue another proposed rule by mid-2026 on FOP labelling and classifying foods by degree of processing.
HHRA and the Swette Center look forward to the next proposal advanced by the FDA-USDA.
We will again share our thoughts and recommendations on how the government can put in place new systems and labelling that will enhance the nutritional quality and safety of the U.S. food supply, and hopefully, the sooner the better.
Sources and Further Information
“Defining and Delineating Ultra-Processed Foods,” HHRA and Swette Center comments to the FDA-USDA submitted October 21,2025.
“Nutrition Info and Other Front-of-Package Labels and Simulated Food and Beverage Purchases: A Randomized Clinical Trial”, Grummon et al., JAMA Network Open. 2025 Oct. doi: 10.1001/jamanetworkopen.2025.37389.
“Enhanced Labeling to Promote Consumption of Nutrient Dense Foods and Healthier Diets”, Benbrook and Mesnage, Foods, 2024. doi.org/10.3390/foods13213377.
“GRAS NOTIFICATION FOR SOY LEGHEMOGLOBIN PROTEIN PREPARATION DERIVED FROM PICH/A PASTORIS”, Submitted by Impossible Foods to the FDA.