The Vegetarian Useful resource Group Weblog

September 8, 2025

The Vegetarian Useful resource Group (VRG) welcomes the chance to touch upon the USDA’s and FDA’s Request for Data to assist develop a uniform definition of ultra-processed meals for human meals merchandise within the U.S. meals provide.

Nutritionally poor ultra-processed meals together with smooth drinks, candies, salty snacks, processed meats, and baked desserts are an extreme a part of the weight loss plan of many American kids and adults. The unfavourable well being results of diets excessive in most of these meals has lengthy been acknowledged. There are, nevertheless, meals that could possibly be categorized as “ultra-processed” that do have the identical unfavourable well being results as different meals categorized as “ultra-processed.”

Though there have been a wide range of makes an attempt to outline “ultra-processed” meals together with these by varied U.S. states, the definitions usually endure from an lack of ability to distinguish between meals which may have unfavourable well being results and people the place processing could be helpful or have a impartial impact. An instance of unfavourable well being results could be processes by which sugars, salt, saturated fat, and different substances related to unfavourable well being are added to meals. Optimistic well being results may embody meals fortification, or processing to enhance bioavailability of nutritional vitamins and minerals.

The Nova system identifies ultra-processed meals as meals which can be able to warmth or to eat with little or no preparation (1,2). Meals on this class have undergone processes similar to salting, baking, frying, pickling, and canning. They’re sometimes excessive calorie, excessive sodium, low fiber meals that comprise little protein, and few nutritional vitamins or minerals. Regrettably, many meals, similar to plant milks and business veggie burgers, that could be eaten by vegetarians, vegans, and others searching for to scale back consumption of animal merchandise are categorized as ultra-processed meals (3-5). It’s unimaginable to equate a fortified soy milk and a smooth drink by way of dietary high quality or potential well being results.

Cow’s milk is taken into account a minimally processed meals; in distinction, fortified soymilk has been categorised as an ultra-processed meals. A latest examine examined the impact of substituting soymilk for cow’s milk (6). Substituting soymilk for cow’s milk resulted in a discount in blood stress, LDL ldl cholesterol, and C-reactive protein. Substituting soymilk for cow’s milk didn’t have an effect on blood glucose, diabetes management, or insulin ranges and had no impact on physique weight or BMI (6). These outcomes increase questions in regards to the categorization of fortified soymilk as an ultra-processed meals.

Quite a lot of analysis research have discovered all meals categorized as ultra-processed should not have an identical results on the danger of coronary heart illness and stroke (7,8), most cancers (8), diabetes (8, 9), cognitive impairment (10), physique weight (11), and frailty (12).

For instance, a examine of greater than 200,000 U.S. adults discovered that solely processed meats and sugar-sweetened drinks had been related to an elevated danger of coronary heart illness and stroke whereas ultra-processed savory snacks and chilly cereals had been related to a decrease danger of coronary heart illness (7). Moreover, the next consumption of ultra-processed breads and cereals was related to a decrease danger of stroke (7). This examine means that various kinds of ultra-processed meals have completely different results on the danger of coronary heart illness and stroke.

Equally, a examine of greater than 260,000 adults discovered that larger consumption of ultra-processed animal-based merchandise and synthetic and sugar-sweetened drinks was related to the next danger of multimorbidity (creating at the very least two persistent ailments, specifically most cancers, coronary heart illness, and/or sort 2 diabetes) (8). Larger consumption of ultra-processed plant-based options or ultra-processed breads and cereals was not related to an elevated danger of multimorbidity (8). Clearly, a extra nuanced evaluation of ultra-processed meals is warranted previous to creating labeling suggestions.

A examine of greater than 110,000 U.S. adults discovered an elevated danger of sort 2 diabetes in these with the best consumption of ultra-processed meals (9). Subgroup evaluation discovered larger consumption of sure meals teams together with breads made with refined flour, artificially and sugar-sweetened drinks, and animal-based merchandise was related to larger danger of sort 2 diabetes. In distinction, larger consumption of meals that had been categorised as ultra-processed together with cereals, whole-grain breads, and packaged candy and savory snacks was related to decrease danger of sort 2 diabetes (9).

A examine of 4,750 middle-aged and older U.S. adults discovered that consuming an extra serving a day of ultra-processed animal merchandise was related to a 17% larger danger of creating cognitive impairment (10). A further serving a day of ultra-processed drinks (like sugar-sweetened smooth drinks) was related to a 6.3% larger danger of creating cognitive impairment (10). Larger ultra-processed meals consumption total was not related to the next danger of creating cognitive impairment nor was larger consumption of ultra-processed snacks, grains, or sweets (10).

These research and different comparable research that take a look at sub-categories of ultra-processed meals strongly help the concept that a blanket categorization of meals as ultra-processed can be complicated and is unlikely to offer well being advantages. It might consequence within the avoidance of meals with well being advantages.

Information point out that the well being results of ultra-processed meals are extremely depending on their dietary high quality (13). We help the analysis of meals primarily based on their dietary and well being results, fairly than solely specializing in the diploma of processing. Right now, it’s untimely to unequivocally name for avoiding all ultra-processed meals. Extra cautious examine is required earlier than characterizing sure meals as “ultra-processed.” Finally, a subset of what are actually categorised as ultra-processed meals could be developed and would embody these ultra-processed meals or classes of meals which can be related to clear public well being dangers. Different meals which can be presently categorised as “ultra-processed” could be positioned in a distinct class, such because the one proposed by the American Society for Preventive Cardiology (14). The American Society for Preventive Cardiology has proposed a brand new class of “well processed” meals which incorporates fortified plant milks and plant protein-based meat and egg substitutes (14). Complete-grain breads and business bean spreads may be on this class. The American Society for Preventive Cardiology describes “well processed meals” as low in saturated fats, refined carbohydrates, and ldl cholesterol and states that these meals can add vitamin worth (14). This type of categorization system that takes into consideration the dietary high quality of the meals is extra useful than merely categorizing meals as “ultra-processed.”

Till extra analysis is accomplished, paperwork similar to Dietary Pointers for People present helpful steering and had been developed to offer present data and to make the most of evidence-based analysis and a stringent course of to develop suggestions for meals to eat and meals to restrict. These paperwork present help for a marked discount in consumption of these ultra-processed meals which can be excessive in saturated fats, added sugars, and salt. Clearly figuring out these meals on meals labels and dealing with meals firms to enhance the composition of those meals must be a precedence. Consumption of different meals presently categorized as “ultra-processed” which can be of higher high quality, similar to fortified plant milks, some plant-based meat options, bean spreads, and entire grain breads shouldn’t be discouraged, and these meals must be included as a part of a wholesome dietary sample (15).

VRG is an unbiased non-profit group devoted to educating the general public on vegetarianism and the interrelated problems with well being, vitamin, surroundings, ethics, and world starvation. Our well being professionals, activists, and educators work with companies and people to result in wholesome adjustments in faculties, workplaces, and the neighborhood. Registered dietitians and physicians assist within the growth of nutrition-related publications and reply questions in regards to the vegetarian and vegan weight loss plan. For the previous 31 years, we’ve commissioned polls exploring vegetarian-related points, outcomes of which are sometimes utilized by researchers, the meals trade, and the media. Monetary help comes primarily from memberships, contributions, and guide gross sales.

Thanks for the chance to touch upon this concern.

Sincerely,

Reed Mangels, PhD, RD

Diet Advisor, The Vegetarian Useful resource Group

Charles Stahler

Co-Director, The Vegetarian Useful resource Group

Debra Wasserman

Co-Director, The Vegetarian Useful resource Group

References

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14. Belardo D, Michos ED, Blankstein R, et al. Sensible, evidence-based approaches to dietary modifications to scale back atherosclerotic heart problems: an American Society For Preventive Cardiology Scientific Follow Assertion. Am J Prev Cardiol. 2022;10:100323.
15. Vadiveloo MK, Gardner CD, Bleich SN, et al. Ultraprocessed Meals and Their Affiliation With Cardiometabolic Well being: Proof, Gaps, and Alternatives: A Science Advisory From the American Coronary heart Affiliation. Circulation. Printed on-line August 8, 2025.