The American Frozen Food Institute (AFFI) submitted comments to the U.S. Food and Drug Administration (FDA) and U.S. Department of Agriculture (USDA) in response to a Request for Information to help define “ultra-processed foods.”
AFFI urged the agencies to not issue a proposed definition for UPFs at this moment and added that classifying foods based on processing or ingredients alone ignores that processing can deliver safe and accessible foods for Americans.
“Frozen foods play a vital role in meeting the public health objectives of the Trump Administration, thanks to using freezing as nature’s pause button,” said Alison Bodor, president and CEO of AFFI.
“Freezing locks in the nutrients of farm-fresh produce, helps consumers enjoy pre-portioned meals and control caloric intake and increases access to quality food options. We urge the administration to consider these factors when determining any potential definition for ultra-processed foods and recognize that freezing delivers public health benefits.”
In August, AFFI released 10 policy recommendations for the Make America Healthy Again (MAHA) Commission that leveraged frozen foods to advance the MAHA agenda. These recommendations highlighted how frozen foods offer a MAHA solution that works with real life and provides variety, ease-of-preparation, cost effectiveness and nutritional comparability to fresh and homemade counterparts.
AFFI’s comments emphasize that the lack of scientific agreement around the level of processing required to be considered a UPF, as well as the lack of causal evidence linking processing to health-related outcomes and notes that any regulatory definition to inform policy is premature at this time. The association also cautioned against regulatory approaches that could mischaracterize frozen foods and recommended that FDA and USDA prioritize evidence-based frameworks centered on nutrition and food safety, rather than ingredient lists or processing methods alone.
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