NutriLab | Still Waiting for a UPF Definition: What It Could Mean for Your Labels

In August, it looked like the U.S. was finally getting its first federal definition of ultra-processed foods (UPFs). On August 10, 2026, HHS announced that FDA and USDA had submitted a proposed definition for final review. At the time, the key word was 'proposed.' Three months later, that's still the case. The definition is under White House review, and its text hasn't been published. It's been a long road: FDA and USDA first asked the public for input in July 2025, and HHS Secretary Robert F. Kennedy Jr. said earlier this year that a definition would be ready by April. That date came and went. While we wait, a new study from the University of Chicago tries to answer the question many food businesses are asking: if a UPF definition turned into a mandatory label, what would it mean for real products? Their answer starts with a big number: at least $14.2 billion a year.

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What Did the Study Find?

The researchers, from the University of Chicago's Initiative on Enabling Choice and Competition in Health Care, checked the ingredient statements of products in USDA's branded food database. Under the definition they used, 72% of packaged foods would qualify as ultra-processed, covering about half of what U.S. households spend on groceries. The $14.2 billion breaks down into three parts:

$9.5 billion for reformulation. Changing recipes so products no longer trigger the label. This is about two-thirds of the total. -** $4.5 billion for substitute ingredients**. Replacement ingredients cost more, every year the reformulated product is on the shelf. -** $0.2 billion for classification and relabeling.** Reviewing products and changing packages.

One important point: the federal definition hasn't been published, so the researchers used one released by Healthy Eating Research in May 2026. The official definition could look different.

One Ingredient Is Enough

Under the definition in the study, a product is flagged if it contains even one "marker" ingredient, such as certain flavors, thickeners, emulsifiers, or sweeteners. That reaches further than most people expect. The screen flagged flavored milks, some plain yogurts thickened with pectin or gelatin, and sparkling water with natural flavor. At the other end, only 7% of rice and 11% of frozen vegetables were flagged.

What one ingredient can do. We know of a small, much-loved donut shop where almost every donut was vegan. This summer, its flour changed overnight. After California banned a common flour additive, flour mills began removing it from their flour nationwide, even for bakers nowhere near California. The shop got no notice. To keep its donuts tasting the same as always, it had to add a small amount of milk and eggs, and it lost its vegan customers, along with people with egg and milk allergies. That's one additive, one recipe, one small business. A UPF label could put dozens of additives in play at once, across thousands of products, and the changes would ripple through suppliers just like this one did. That's the kind of change the $9.5 billion reformulation estimate is trying to measure, and it doesn't count the customers a new recipe can lose.

Why it matters:

The products most at risk may not be the ones you'd guess. The model predicts the biggest sales losses for categories shoppers see as healthy, like bread, cereal, yogurt, and bars, and almost none for candy, soda, and snacks.

How Do Other Labels Work? Nutrients, Not Ingredients

A mandatory front-of-pack label wouldn't be new. Several countries, mostly in Latin America, already require one, and FDA has its own proposal. Almost all of them are based on nutrients, not ingredients.

Chile was the first, in 2016. Packaged foods that go over set limits for sugars, sodium, saturated fat, or calories must carry a black octagon that says "HIGH IN" ("ALTO EN"). Peru, Uruguay, Mexico, and Argentina followed with similar black octagons, and Brazil, Colombia, and Canada have since adopted their own warning systems. The University of Chicago researchers used Chile's experience as a reference for how shoppers and companies react to a mandatory label.

The U.S. has a nutrient-based proposal too. In January 2025, FDA proposed a front-of-package "Nutrition Info box" that would rate saturated fat, sodium, and added sugars as "high," "medium," or "low." Unlike Chile's octagons, it would appear on every product, not only on those over a limit. FDA estimated it would cost about $333 million a year, a small fraction of the UPF estimate, because it doesn't require anyone to change a recipe.

Brazil is an interesting case. The term "ultra-processed" was born there, at the University of São Paulo, where researchers created the NOVA classification. Yet Brazil's front-of-pack label is nutrient-based too. Where Brazil does use the UPF category is in policy: its national school meal program, which serves about 40 million students, limits spending on processed and ultra-processed foods to 10% of its food budget in 2026. It's a reminder that a UPF definition can matter even without a label, through school meals, public purchasing, or benefit programs.

Why it matters:

With a nutrient-based label, the label follows the nutrition numbers. Cut the sugar, and the octagon disappears or the rating improves. That's why many companies in Chile reformulated.
A UPF label, as modeled in the study, works differently. If a marker ingredient stays in the recipe, the label stays, no matter how good the nutrition numbers are.
The two U.S. tracks could merge. Kennedy has said he wants to rework front-of-pack labeling once the UPF definition is out, possibly with a traffic-light system, which could mean replacing FDA's 2025 proposal with a new one.
Ingredient-based warnings aren't entirely new. Mexico and Argentina also require warnings for non-caloric sweeteners and caffeine.

Is It a Regulation Yet?

Not yet. Today there is no federal definition of ultra-processed food, and nothing requires a UPF label on your package.

The proposed definition reached the White House on August 3, 2026. It was filed as a white paper, not as a proposed rule, and as of November 4 it was still under review, with no deadline. Secretary Kennedy has said he wants to move to front-of-pack labeling once the definition is out.

For a UPF label to become mandatory, the definition would need to be published, FDA would need to propose a labeling rule and take public comments, and then finalize it with a compliance date. For reference, FDA's front-of-package "Nutrition Info box" proposal from January 2025, which is still pending, would give companies with $10 million or more in annual food sales three years after the final rule takes effect.

In short: a UPF label is years away, not months. But three years is a short time to reformulate a product line.

What Can You Do Now?

You don't need to change any labels today. But you can start preparing with the data you already have:

Screen your ingredient statements. Look for marker ingredients like flavors, thickeners, emulsifiers, and sweeteners, and make a list of products that would likely be flagged. Have someone review unclear ingredient names.
Sort the flagged products. Reformulate your best sellers and anything sold on a health promise. Relabel products where shoppers already know what they're buying. Consider retiring low-volume products that wouldn't earn back a reformulation.
Time any relabel with your next packaging redesign. The study estimates a coordinated relabel costs a small fraction of a change made off your design calendar.
Look for shared bases. Reformulating one base, sauce, or seasoning used across a product family costs less per product than reworking each recipe.

How NutriLab Can Help

At NutriLab, we help food businesses get ready for changes like this one. Your ingredients, sub-ingredients, and ingredient statements live in one place, so finding which products contain a given ingredient is a search, not a spreadsheet project. You can turn shared bases and sauces into products, reuse them across recipes, and keep a full history of every reformulation. And with our expertise in FDA and LATAM regulations, we can help you understand how nutrient-based and ingredient-based labels could affect your products.

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References

Still Waiting for a UPF Definition: What It Could Mean for Your Labels