A Federal Ultra-Processed Food Label Could Cost $14.2 Billion a Year, University of Chicago Researchers Estimate

A University of Chicago analysis found 72% of 450,000 products would meet a broad ultra-processed food definition, and that labeling could add about $60 a year per household.

What would it cost to put an ultra-processed food label on America’s groceries? Researchers at the University of Chicago have put a number on it: at least $14.2 billion a year. Most of that is the price of reformulating food to avoid the label, and about $60 a year per household would land on shoppers.

TLDR

  • The study modeled a hypothetical mandatory federal label for ultra-processed food.
  • Under the broad definition it used, 72.3% of about 450,000 grocery products would qualify.
  • The researchers estimate costs of at least $14.2 billion a year, about $8.1 billion of it passed to consumers.
  • FDA’s own definition has been under White House review since August and has not been released.

What the Study Measured

The analysis, published October 17 by researchers working with the University of Chicago’s Initiative on Enabling Choice and Competition in Health Care Markets, asked a practical question: what happens if the federal government requires ultra-processed foods to carry a label? FoodNavigator reported on the findings.

FDA’s proposed definition is not public, so the researchers used the definition recommended in May 2026 by an expert panel convened by Healthy Eating Research, a national program of the Robert Wood Johnson Foundation. That 14-member panel, chaired by Jim Krieger and Lindsey Smith Taillie, built its definition on the NOVA classification system, which describes ultra-processed foods as industrial formulations with few or no whole-food ingredients, and proposed an ingredient-based approach that regulators could apply product by product.

The researchers applied that definition to about 450,000 products in USDA’s Global Branded Food Products Database.

Which Foods Would Carry the Label

72.3% of the products assessed met the definition. Nearly all confectionery, baked sweets, soda, pasta dinners and frozen appetizers qualified. Rice and frozen or canned vegetables were the least likely to.

The reach is wide because ultra-processed food is most of what Americans buy. The study found ultra-processed foods account for 51% of the money spent on food eaten at home.

Breaking Down the $14.2 Billion

  • Reformulation: $9.5 billion a year for manufacturers to change products so they no longer trigger the label.
  • Substitute ingredients: $4.5 billion a year for the replacement ingredients those new formulas require.
  • Administration: $200 million a year in federal administration, relabeling and classification costs.

Of the total, $8.1 billion would reach consumers through higher prices, or about $60 per household. If companies cut product quality instead of paying for substitute ingredients, consumer losses would rise to $9.8 billion.

The researchers call their figure a “lower bounds” estimate. It leaves out several costs: about $1 billion a year in lost revenue for domestic agriculture, $7.7 billion to $8.7 billion a year in higher food import costs, and any litigation. The $14.2 billion is also 142 times the $100 million threshold the White House budget office uses to label a regulation “economically significant,” though the study and FDA’s white paper are measuring different things.

Where the Federal Definition Stands

FDA and USDA asked the public for input on a federal definition of ultra-processed food in July 2025, with comments closing that October. On August 10, 2026, Health Secretary Robert F. Kennedy Jr. said the agencies had sent their proposed definition to the Office of Management and Budget for final review. No details were released.

The proposal went to the budget office as a white paper, not a formal rule. On its own it would not require any label. It could still shape federal nutrition programs, voluntary reformulation, future labeling rules and litigation. Kennedy has indicated interest in a label claim, symbol or “stoplight” model for ultra-processed foods, FoodNavigator reported, but no labeling proposal has been issued.

California Is Not Waiting

California has already written its own definition into law. The Real Food, Healthy Kids Act, Assembly Bill 1264, signed by Governor Gavin Newsom on October 8, 2025, created the first legal definition of ultra-processed food in the country. The California Department of Public Health, working with University of California experts, is to identify the most harmful ultra-processed foods so they can be phased out of school meals by 2035. State scientists will weigh whether a product contains additives banned or restricted elsewhere, is linked to health harms such as cancer, cardiovascular disease or obesity, or contributes to food addiction.

“California has never waited for Washington or anyone else to lead on kids’ health,” Newsom said at the signing.

The Industry Response

The food industry has pushed back on a broad definition. In an August statement, Rhonda Bentz, executive vice president of public affairs at the Consumer Brands Association, objected to “any so-called definition that captures 80 percent of the nation’s food supply while picking winners and losers,” and warned of “disastrous consequences” for grocery prices.

A CBA spokeswoman said regulators “should focus on providing consumers with clear, science-based nutrition facts.” The group has also raised the possibility that a federal label could invite false advertising, public nuisance and failure-to-warn lawsuits, while acknowledging those claims are hypothetical.

The Health Backdrop

The push for a definition comes as the research linking ultra-processed food to poor health keeps growing. A 2024 umbrella review in The BMJ, which pooled 45 meta-analyses covering about 9.9 million people, linked higher consumption of ultra-processed food to 32 health outcomes, including cardiovascular disease, type 2 diabetes and mental health disorders.

Why It Matters

Whether ultra-processed food gets a federal definition is no longer the question. The question is how broad it will be, and what it will be used for. A definition that captures nearly three-quarters of the grocery store would push reformulation across the industry and raise prices along the way. A narrower one would be cheaper but leave more foods unlabeled. Studies like this one will shape where the line is drawn, and whether a label ever reaches the front of the package.


Sources: FoodNavigator; Healthy Eating Research; Food Safety Magazine; Office of Assemblymember Jesse Gabriel; The BMJ.

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