California wants to be the first state in the nation to ban ultra-processed foods in public school lunches. If – and it's a big if – its Office of Environmental Health Hazard Assessment (OEHHA) can come up with a definition and identify “particularly harmful” ultra-processed foods. 

Research has linked diets that include a lot of ultra-processed foods, primarily soft drinks and packaged snacks, to health risks including cancer, cardiovascular disease, and Type 2 diabetes. According to a study published in JAMA in 2021, 67 percent of the calories in food eaten by some children comes from ultra-processed food. The California bill would essentially phase out ultra-processed foods from school lunches by 2032 and outright ban them by 2035.

Sounds great, right? But the devil in the details here is the definition of what is considered to be an ultra-processed food and which of these foods are “particularly harmful.” The bill attempts to define ultra-processed foods as those that contain one or more certain functional ingredients, including colors, flavors, sweeteners, emulsifiers, and thickening agents. It also directs OEHHA to determine whether a food is "particularly harmful" based upon: (i) peer-reviewed evidence linking the ingredient to cancer, cardiovascular disease, metabolic disease, developmental harms, reproductive harms, obesity, Type 2 diabetes; (ii) whether the substance is hyper-palatable or may contribute to food addiction; and (iii) whether the food has been modified to be high in fat, sugar and salt. 

If OEHHA is able to do what the food and beverage community has not been able to do to date – i.e., come up with an accepted definition of ultra-processed food and an agreed-upon risk assessment of those that are “particularly harmful” – then I suspect more states will follow California's lead and ban ultra-processed foods in certain contexts.