Before “ultra-processed foods” can be limited or eliminated, “ultra-processed foods” will need to be defined.
Sounds simple enough. California and one or two other states have already imposed restrictions on “ultra-processed foods” (UPF). But the situation is so complex that in July the federal government began asking for help in crafting a definition.
In response, the National Chicken Council (NCC) took 14 pages of single-spaced comments to inform the FDA and USDA of Docket No. FDA–2025–N–1793: Request for Information: Ultra-Processed Foods. The NCC represents chicken producers in the United States.
The NCC's extensive comments begin with “general concerns about the classification system and argue that the FDA and USDA should maintain existing structures and consumer education as the science evolves, rather than develop a classification system at all.”
“However, if agencies decide to move forward with the classification system, NCC encourages the use of a uniform, science-based approach to food characterization that prioritizes the nutritional composition and function of ingredients over the number of processing steps or ingredients.
“We call on the FDA and USDA to adopt a nutrition-based framework that promotes the consumption of safe, accessible and culturally relevant proteins, like chicken, that millions of families, schools and food assistance programs rely on for essential nutrition,” NCC Senior Vice President for Scientific Affairs Ashley Peterson said in comments.
“If agencies decide to use a classification system, NCC is committed to working with the FDA, USDA and other stakeholders to create a clear, science-based system that protects public health without discouraging the unintentional consumption of nutrient-dense foods. As discussed, the so-called 'ultra-processed food' term is too broad and may mislead consumers into suggesting that a food is unhealthy solely based on how it is made rather than what it contains.” “without nutrients.”
NCC highlights include:
1. Use peer-reviewed research and government data, including comparisons of the nutrient profiles (protein, vitamins, minerals) of chicken products with other commonly consumed “UPFs” to highlight the vital nutritional role that processed chicken products (e.g., frozen chicken cutlets or nuggets) play in the diet of all Americans by providing high-quality protein and micronutrients in an accessible and affordable manner.
2. Highlight the problems associated with overprocessing-oriented classification systems (particularly the NOVA system), including the failure to consider nutrient density, protein quality, and processing intent, and the resulting inconsistent, often misleading classification.
3. Caution against overly broad policy use of a term commonly referred to as “ultra-processed,” given that it groups foods with different nutritional values (e.g., breaded chicken nuggets and candy are labeled as “ultra-processed” despite having very different nutritional characteristics).
4. Offer considerations that highlight what is in the food, including nutrient density, protein quality and ingredients, rather than how it was produced.
“We stand ready to provide additional data, expertise and collaboration as the FDA and USDA address this definitional challenge and we share the goal of improving Americans' diets and health outcomes, especially for children,” Peterson said. “Importantly, a nutrient-sensitive definition can better help consumers and policymakers understand the differences between foods that may be processed but still provide nutritional value and those that provide little health benefit.
The NCC's comments can be read in full. by clicking here.
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