Putting Tribal Sovereignty in Food Sovereignty
The U.S. Food and Drug Administration (FDA) and the U.S. Department of Agriculture are currently considering whether to define “ultra processed foods” (UPFs) and how that definition could be used in food labeling, nutrition programs, and dietary guidelines. The outcome may directly impact food access in Tribal communities.
A federal definition of UPFs could shape what foods are allowed in programs like the Food Distribution Program on Indian Reservations (FDPIR), school meals, and other nutrition assistance programs. If the definition is too broad or based on incomplete criteria, like the presence of certain additives or the use of shelf-stable processing methods, it could unintentionally exclude affordable, nutrient-rich foods that are essential for food security in remote and rural areas.
Some proposed definitions of UPFs focus heavily on how a food is made rather than its nutritional value. These definitions often flag the presence of additives (like stabilizers and preservatives), industrial processing methods (like canning or hydrogenation), or the creation of foods that are “ready-to-eat” as markers of ultra-processing. But these characteristics do not necessarily make a food unhealthy. Foods that are generally considered healthy and nutrient-dense, like sliced deli meat, whole grain bread, and American cheese, would likely meet the technical definitions of being “ultra-processed.”
Additionally, a poorly designed definition could also lead to the exclusion of culturally appropriate foods that many Tribal communities rely on. For instance, canned or pouched salmon might be classified as “ultra-processed” simply because of its preservation methods, despite its nutritional benefits and cultural relevance for some Tribal communities.
Processing alone does not determine whether a food is healthy or appropriate. The food’s overall nutritional value must be considered. That means looking at the nutrient profile of the food to determine how much beneficial nutrition it provides (e.g., protein, fiber, vitamins, and minerals) compared to things such as added sugars, sodium, or unhealthy fats. Nutritional value, cultural relevance, and accessibility are the key factors that guide how foods are classified and included in programs that support Tribal communities.
IFAI has drafted a comment template letter to incorporate some of these concerns relevant to Tribal communities.
Comments are due October 23, 2025, and may be submitted through the Federal eRulemaking Portal. Go to https://www.regulations.gov and enter Docket Number FDA-2025-N-1793 into the search bar to submit your comment electronically.
Physically written comments may be sent to Dockets Management Staff (HFA-305), Food and Drug Administration, 5630 Fishers Lane, Rm. 1061, Rockville, MD 20852.
All responses to this notice will be summarized and included in the request for Office of Management and Budget approval. All comments will be a matter of public record.
Download the comment template below.