The term “ultra-processed food” is a catch-all term that could unintentionally misclassify nutrient-dense foods simply because they are processed, the National Pork Producers Council (NPPC) wrote in comments submitted to the U.S. Food and Drug Administration ahead of the Dietary Guidelines for Americans release.
“If the Trump administration’s aim is to positively impact health, nutrition should be the focus – not processing,” NPPC said.
NPPC formally expressed its concerns regarding the FDA’s forthcoming definition of “ultra-processed foods,” which could be damaging for consumers of pork products.
“Pork products offer incredible nutritional value, yet they are at risk of being labeled as an “ultra-processed food,” while other foods that contain very little ingredients but lack nutritional value, may evade the classification,” NPPC wrote.
NPPC encouraged FDA to do the following:
- Not classify food as ultra-processed simply because it does not fit into one of three categories (out of four) of the problematic NOVA classification system. Such a sorting focuses on the processing of foods rather than the nutritional benefits.
- Not categorize food as ultra-processed that contains ingredients that enhance food safety, shelf stability, and nutrient availability. Such ingredients protect public health and allow nutrient dense foods to reach consumers.
- Ensure an ultra-processed foods definition does not conflict with FDA’s Standards of Identity regulations, which detail what specific foods must contain, the amount or proportion of ingredients or components, and, sometimes, the method of production or formulation.
Because there is no consensus on what constitutes an “ultra-processed food,” NPPC said FDA should elevate the importance of nutritional composition while also protecting processing and ingredients that promote nutrient bioavailability, food safety and shelf stability.
Rather than “ultra-processed foods,” NPPC recommends the FDA use a term such as “discretionary foods” for food products characterized by lower nutritional quality, the release said.
“This would put the conversation back on nutrition as the basis for addressing diet-related chronic disease in America,” NPPC wrote.


