The Heartland Health Research Alliance (HHRA) and the Swette Center for Sustainable Food Systems at Arizona State University recently released comments recommending guidance on identifying ultra-processed foods (UPFs). They urge the government to more clearly define the impact these foods have on public health to help eaters make more informed choices.
The comments come in response to the request for public guidance from the U.S. Food and Drug Administration (FDA) and U.S. Department of Agriculture (USDA) as the Trump-Vance Administration seeks to develop a uniform definition of UPFs.
At the heart of HHRA’s and Swette Center’s comments is a front-of-packaging labeling system called NuCal. The organizations argue that the NuCal system will better group foods in categories to determine if they are very healthy, moderately healthy, or not so healthy.
The NuCal system displays scores based on processing level and health impact. The goal is to help eaters understand that whole and lightly processed foods are generally healthier compared to ultra-processed options or products that deliver nutrients through fortification or supplements. A cup of raw spinach, for example, has a NuCal Value of 17.05, while a Big Mac with cheese has a NuCal Value of just 0.46.
Early reactions to the UPF comments and the NuCal rating system have been encouraging, Benbrook shares. “It avoids the problems associated with the NOVA system,” he explains, referring to criticism that the NOVA food classification leads consumers to believe that all UPFs are uniformly harmful. “But most importantly, it will accurately differentiate between healthy UPFs and less healthy, and flat-out unhealthy processed foods.”
The authors believe this rating system can be helpful as the Food as Medicine movement gains popularity nationwide. It’s particularly important, they argue, when considering that diets must be personalized according to medical needs, patients’ cultures, tastes, and preferences.
“Just as one shoe does not fit all feet, one mix of contents in a box is never going to optimally promote improved health outcomes across the diversity of medical conditions, life stages, and needs and desires of individual patients,” Charles Benbrook, the lead author of the HHRA-Swette Center comments tells Food Tank. “This realization then leads to an obvious question that Food as Medicine teams are now confronting—how to customize the contents in boxes and prescriptions to maximize the bang for the buck.”
HHRA and the Swette Center believe that changes in the labeling system are inevitable, but Benbrook is mindful that these changes can only go so far. “Both the government and food industry will shy away from a hard-edged system that accurately characterizes just how bad junk food is for the American public,” he states. “But what they will almost certainly do is put in place a system that accurately distinguishes between unhealthy UPFs and healthy ones.”
Benbrook also notes that the transition won’t come without pushback from the private sector. “The food industry will fight until hell freezes over to avoid putting an honest label on the worst of UPFs,” Benbrook tells Food Tank. But, if the NuCal system is introduced, it “will not be able to stop other food companies from labeling their UPF as ‘healthy’ when it meets a meaningful set of data-driven criteria.”
Articles like the one you just read are made possible through the generosity of Food Tank members. Can we please count on you to be part of our growing movement? Become a member today by clicking here.
Photo courtesy of Tiia Monto, Wikimedia Commons







