← Back to Articles Metabolic Health

Ultra-Processed Food and the GRAS Loophole Explained

By Dr. Robert Rakowski · August 26, 2026

The short answer: Ultra-processed foods now make up 55% of the calories Americans consume, and they have been linked to 32 adverse health outcomes including cardiovascular disease, diabetes, obesity, depression, and early death. On August 10, 2026, the U.S. government proposed its first-ever federal definition of ultra-processed food and moved to close a regulatory loophole that has allowed food companies to add thousands of chemical additives without FDA review since 1958.

I have been teaching patients about the dangers of processed food for over 34 years. In my book Magnificent by Design, the very first of The Magnificent Seven principles is Eat Right, because what goes into your body determines its structure, energy, and ability to function. For decades, I watched patients come through my clinic at the Natural Medicine Center carrying the metabolic burden of a food supply they assumed was safe. They were told the ingredients were “generally recognized as safe.” They trusted the label. Their bodies told a different story.

Now the federal government is catching up to what functional medicine practitioners have known all along: the American food supply has a safety problem, and the regulatory system designed to protect consumers has been broken for decades.

What Just Happened With the GRAS Loophole?

On August 10, 2026, the U.S. Department of Health and Human Services announced two historic actions. The FDA proposed a rule making GRAS (Generally Recognized As Safe) notifications mandatory, and HHS submitted the federal government’s first proposed definition of ultra-processed food for final review.

The GRAS system was created in 1958 for ingredients that were already so widely used that formal safety review seemed unnecessary. Think vinegar, baking soda, and salt. Nobody needed a clinical trial to prove table salt was safe for human consumption. But in 1997, the FDA opened the door for food companies to self-certify their own ingredients as safe without notifying the agency. No filing requirement. No public disclosure. No independent review.

The result? According to an analysis by the Environmental Working Group, 99% of new food chemicals introduced since 2000 entered the market through the GRAS pathway rather than through FDA safety review. Between 2000 and 2024, companies sent the FDA 863 voluntary notifications for new substances. In the same period, the FDA reviewed just 10 new food additives and approved only seven. An unknown number of additional substances entered the food supply through “self-affirmed GRAS,” a process where a company assembles its own evidence, convenes its own panel of experts (often paid by the company), and declares its own ingredient safe. Nobody knows exactly how many self-affirmed ingredients are in the food supply. Not even the FDA.

The proposed rule would change that by requiring companies to notify the FDA every time they conclude a substance is GRAS. It does not create premarket approval. Companies will still reach their own safety conclusions. But the FDA will at least know what is being added to the food supply, which is a fundamental shift from the current system where regulators are, by design, kept in the dark.

How Much Ultra-Processed Food Are Americans Actually Eating?

Americans get more than half of their daily calories from ultra-processed foods. A CDC report using NHANES data from 2021 to 2023 found that the overall average was 55% of total calories. For children 18 and under, that number climbed to nearly 62%.

Ultra-processed foods are industrial formulations made mostly or entirely from substances extracted from foods, derived from food constituents, or synthesized in laboratories. They contain ingredients you would never find in a home kitchen: protein isolates, hydrogenated oils, modified starches, emulsifiers, artificial colors, synthetic flavor enhancers. Common examples include most packaged snacks, sweetened beverages, frozen meals, breakfast cereals, and processed meats.

These are not foods your great-grandmother would recognize. As I write in Magnificent by Design, the “what” of eating right is straightforward: choose real, whole foods that nature provides. Foods that grew in soil or walked on earth. Foods with minimal processing and maximum nutrient density. The further a food gets from its natural form, the more your body has to work to process it and the less nutrition it actually delivers.

Why Ultra-Processed Food Is Harmful Beyond Just Bad Ingredients

A landmark 2026 study from Tufts University, published in the American Journal of Public Health, revealed something critical: it is not just what is in ultra-processed food that causes harm. The industrial processing itself appears to play an independent role.

The researchers analyzed data from nearly 50,000 American adults across 20 years of NHANES surveys. They found that people who ate more ultra-processed food had higher body weight, worse blood sugar control, higher blood pressure, and less favorable cholesterol levels. They were more likely to have diabetes, metabolic syndrome, and cancer, and they had a higher risk of dying during the study period. These associations held even after the researchers accounted for the nutritional quality of the foods and the amounts of saturated fat, added sugar, and sodium they contained.

In other words, adjusting for the “bad stuff” everyone already knows about did not explain the harm. Something about the processing itself, the changes to the food’s cellular structure, the loss of beneficial compounds, the chemical additives, the substances migrating from packaging, creates health risks that traditional nutrition metrics do not capture.

This confirms what I have been teaching patients for decades. In Magnificent by Design, I describe how food processing strips away fiber, vitamins, and minerals, leaving behind essentially empty calories. These foods fill your stomach but leave your cells starving. The Tufts study puts clinical data behind that principle.

The Full Scale of the Health Damage

A 2024 umbrella review published in the BMJ synthesized 45 meta-analyses covering nearly 10 million participants. The results were stark. Higher ultra-processed food intake was associated with 32 different adverse health outcomes spanning mortality, cardiovascular disease, cancer, metabolic conditions, mental health disorders, respiratory illness, and gastrointestinal problems.

The strongest findings: a roughly 50% increased risk of cardiovascular disease-related death. A 48% to 53% higher risk of anxiety and common mental disorders. A 12% greater risk of type 2 diabetes. Additional evidence pointed to a 21% greater risk of death from any cause, a 40% to 66% increased risk of heart disease death, obesity, and sleep problems, and a 22% increased risk of depression.

These are not marginal numbers. These are population-level shifts in disease risk driven by what people eat every day, three times a day, for decades.

What Happens Inside Your Body When You Eat Processed Food

The damage from ultra-processed food operates through multiple pathways that compound over time.

First, chronic inflammation. As I explain in Magnificent by Design, foods that promote inflammation, including processed sugar, refined oils, and chemical additives, directly fuel a fire inside your body. When this inflammation persists, your body diverts resources away from essential maintenance and repair. Under continuous low-grade inflammation, cells become less responsive to insulin. You develop metabolic fragility. Your body stays in a perpetual defensive state instead of doing the deep repair work it needs.

Second, nutrient displacement. When 55% of your calories come from foods that are low in fiber, vitamins, and minerals, you are displacing the whole foods your cells actually need to function. You can eat enough to feel full and still be profoundly undernourished at the cellular level. Over-consumption of macronutrients with profound under-nutrition of micronutrients is the metabolic trap most Americans are living in without knowing it.

Third, gut disruption. Ultra-processed foods lack the dietary fiber that feeds beneficial gut bacteria and promotes healthy elimination. They are quickly digested and absorbed, bypassing the slower processes that support microbiome diversity. Over time, this degrades the gut lining and shifts the microbial balance toward organisms associated with inflammation and metabolic dysfunction. If you want to understand what healthy gut function actually looks like, read my guide on what your stool is telling you about your health.

What Functional Medicine Sees That Conventional Medicine Misses

Most conventional doctors do not ask patients what they eat in any meaningful detail. When they do, they are looking at calories, macronutrients, maybe cholesterol. They are not looking at the cumulative toxic burden from decades of chemical additives the FDA never reviewed. They are not testing for the inflammatory markers that spike when someone’s diet is 60% industrial food products. They are not connecting the fatigue, the brain fog, the joint pain, and the stubborn weight gain to a food supply that has been quietly degrading for decades.

In my practice, the conversation starts with the Magnificent Seven. When a patient tells me they are tired, gaining weight, and dealing with brain fog, the first question is not “what medication are you on?” It is “what are you eating, how often, and how much of it came from a package?” That question, asked carefully and answered honestly, reveals more about the root cause of chronic disease than most lab panels.

The food is the foundation. When the foundation is made of industrial chemicals, modified starches, and synthetic additives, everything built on top of it is unstable.

When to Talk to a Practitioner

If you are dealing with persistent fatigue, unexplained weight gain, digestive issues, brain fog, or chronic inflammation that has not responded to conventional treatment, the food supply may be a bigger factor than anyone has told you. These symptoms do not appear overnight. They accumulate over years and decades of eating foods your body was never designed to process.

This is especially important if you have been told your lab work is “normal” but you still feel off. Standard lab panels do not measure the inflammatory and metabolic markers that reveal the damage from ultra-processed food exposure. A practitioner trained in functional medicine can look at the full picture, not just the standard ranges.

Five Steps You Can Start Today

  1. Audit your kitchen. Pick up every packaged food and read the ingredient list. If it contains substances you would not find in a home kitchen, including emulsifiers, modified starches, artificial colors, or hydrogenated oils, replace it with a whole food alternative.

  2. Follow the 80/20 principle. Aim for at least 80% of your calories from real, whole foods: vegetables and fruits in every color, pasture-raised meats and eggs, wild-caught fish, nuts, seeds, and healthy fats. The remaining 20% gives you flexibility without metabolic compromise.

  3. Eat fewer times per day. Time-restricted eating, consuming your meals within an 8 to 12 hour window, gives your digestive system breaks for cellular cleanup and metabolic rest. When you stop grazing constantly, insulin levels stabilize and your body can shift from defense to repair.

  4. Choose organic when possible. Organic produce, grass-fed meat, and wild-caught fish reduce your exposure to pesticides, herbicides, and growth hormones. Eating clean stops the incoming damage, even though it takes strategic supplementation to repair what has already accumulated.

  5. Read beyond the nutrition label. The new GRAS rule, if finalized, will give the FDA more visibility into what is being added to your food. But it will not solve the problem overnight. Your best defense is knowing what you are eating and making choices that align with how your body was designed to function.

If you have been dealing with symptoms that no one can explain and you are ready to look at the full picture, book a consultation and let us find out what is actually going on.

To your magnificent health,

Dr. Bob Rakowski, DC, CCN, DACBN, DIBAK 🌿


This article is for educational purposes only and is not a substitute for professional medical advice, diagnosis, or treatment. Always consult with a qualified healthcare provider before making changes to your diet or health regimen.


References

  1. U.S. Department of Health and Human Services. “HHS Announces Proposed GRAS Rule.” Press release, August 10, 2026.
  2. Hatta-Langedyk, J., et al. “Ultra-Processed Foods and Health Outcomes: Beyond Nutrients.” American Journal of Public Health, 2026. DOI: 10.2105/AJPH.2026.308499
  3. Lane, M.M., et al. “Ultra-processed food exposure and adverse health outcomes: umbrella review of epidemiological meta-analyses.” BMJ, 2024;384:e077310.
  4. Centers for Disease Control and Prevention. “Ultra-Processed Foods Among Americans.” NCHS Data Brief No. 536, August 2025.
  5. Environmental Working Group. “Secret GRAS: How 100+ Food Chemicals Bypassed Government Safety Review.” March 2026.
  6. Rakowski, R. Magnificent by Design: The Seven Laws That Govern Biological Health, Happiness and Longevity. 2026.

Ready to take the next step?

Book a consultation at the Natural Medicine Center and find out what's actually driving your symptoms.

Book a Consultation →