For consumers, the idea may sound straightforward: a label designed to identify foods that meet California’s criteria for being non-ultraprocessed. But for food scientists, regulators, manufacturers and others across the food system, the new law raises a more complicated question: What are the implications of individual states creating certification programs around UPFs while the federal government is still working to define the term?

That question matters because California is not working in a vacuum. The state already established statutory criteria related to ultraprocessed foods through legislation enacted in 2025, and AB 2244 builds a consumer-facing certification program on that framework. Meanwhile, the FDA and USDA are working to develop a uniform federal definition of UPFs — an effort the FDA has identified as a priority for 2026.

The timing highlights the importance of establishing a consistent, science-based framework as UPF policy continues to evolve.

IFT has consistently advocated for a science-based approach to UPF policy. In comments submitted in response to the federal Request for Information on ultraprocessed foods, IFT urged policymakers to focus on the nutritional quality of foods rather than processing level alone and cautioned against relying on existing UPF classification systems as the basis for public policy (view IFT comments).

There is a good reason for that caution.

Many commonly used UPF classification systems focus primarily on processing intensity rather than nutritional value. As a result, foods such as whole-grain bread, yogurt, fortified cereals, infant formula, allergy-friendly foods and medical nutrition products can be categorized as ultraprocessed despite providing important nutritional benefits.

That distinction matters. Policies based largely on processing criteria could unintentionally penalize foods that help consumers meet nutrient needs and support broader public health objectives.

Food processing itself is not inherently negative, either.

Processing technologies play critical roles in food safety, preservation, nutrient delivery, affordability, accessibility and food security. Fermentation, pasteurization, drying, fortification and other processing and preservation techniques have helped improve the safety and nutritional quality of the food supply for decades.

A regulatory framework that treats processing as a primary indicator of healthfulness risks oversimplifying the complex relationship between food production and nutrition.

The stakes also reach well beyond voluntary labeling.

A state-by-state patchwork

Perhaps the biggest concern, however, is what happens next.

If other states adopt similar certification programs or develop their own definitions of ultraprocessed foods while a uniform federal definition is still taking shape, manufacturers, retailers, schools and consumers could eventually face different interpretations of what qualifies as an ultraprocessed food.

We do not yet know whether that will happen. But the possibility of multiple state-level approaches highlights the importance of developing a consistent, science-based framework as UPF policies become more widespread.

The stakes also reach well beyond voluntary labeling. How ultraprocessed foods are defined could ultimately influence school meals, nutrition assistance programs, product reformulation efforts, front-of-pack labeling initiatives and future dietary guidance.

Given those potential implications for the food system, definitions should be rooted in sound science, aligned with broader nutrition policy objectives and flexible enough to evolve as evidence emerges.

As UPF policy moves from academic discussion into regulatory and legislative action, the debate is becoming about more than how foods are classified. It is also about who defines those classifications, what scientific criteria support them, how they are communicated to consumers and whether processing level alone tells us enough about the nutritional quality of a food.

Anna Rosales, RD, is vice president of science and policy at the Institute of Food Technologists ([email protected]).