Experts propose a tobacco playbook for food policy

Diet‑related diseases such as type 2 diabetes, obesity and hypertension, particularly those affecting children, remain stubbornly high. Can public policies like those that have been successful with tobacco control help shape a more effective public health impact on these diseases?

A group of food policy researchers with decades of experience believes so. Experts from the new Center for Food and Nutrition Policy at Penn Medicine are bringing their knowledge to bear on key food- and health-related regulatory issues.

“It’s an approach we call ‘strategic science’ because we’re creating research questions around important topics that policy change agents—regulators, legislators, advocates—have told us they need answers to,” said Christina Roberto, Ph.D., the Mitchell J. Blutt and Margo Krody Blutt Presidential Professor of Health Policy and director of the center.

The center was established in 2025 as an evolution of the former Psychology of Eating and Consumer Health (PEACH) Lab. “At the PEACH lab, we were always committed to using research to inform policy, but the center has given us a stronger platform and the resources we need to build relationships with people impacting food policy and communicate the science in more effective ways,” Roberto said.

Food policy using the tobacco playbook

For instance, in September of 2025, the U.S. Department of Health and Human Services (HHS) released its “Make Our Children Healthy Again” report, which argued that food companies have fueled a national crisis by producing ultra-processed junk foods, aggressively marketing them to children, and influencing nutrition research and policy.

In a viewpoint, published today in JAMA Health Forum, Roberto and Alyssa J. Moran, ScD, MPH, deputy director at the center, point to a proven framework—modeled on tobacco control—that can be adapted to food policy on the heels of the HHS report.

“For years, tobacco companies owned major food manufacturers and used similar tactics to resist regulation, from voluntary industry rule programs to deceptive media campaigns,” Roberto said. “Effective tobacco policies like taxes, warning labels, and marketing bans dramatically reduced smoking rates. Many of these same strategies can be applied to rein in the food industry and protect children from diet-related disease.”

Key recommendations include:

• Funding government regulators through fees paid by the food industry to monitor the safety of ingredients added to the food supply
• Requiring warning labels on unhealthy foods
• Restricting ultra-processed products in schools and public institutions
• Taxing sugary drinks and junk foods to support initiatives like subsidies for healthier foods

Roberto and Moran also call for reducing industry influence in nutrition research, ensuring that policy decisions are guided by independent science.

“We’ve seen some of these measures working already, such as the sweetened beverage tax here in Philadelphia,” Roberto said. Her team studied the early impacts of the levy, and found that the tax dramatically reduced both sweetened beverage purchases, and adolescents’ soda intake, as well as improved Medicaid recipients’ dental health.

Defining ‘ultra-processed’ and what’s next for the center

A related area where the center is hoping to impact policy is the debate around how the U.S. Food and Drug Administration (FDA) should define highly processed foods, particularly those marketed to children.

A recent Nature Medicine commentary by Moran and Roberto called for the FDA to define “real food” and categorize everything else as ultra-processed. Think: scrambled eggs versus sugary breakfast cereals. Some scientists are advocating for the FDA to define ultra-processed foods based on the presence of certain additives and ingredients, but this approach, according to Roberto and Moran, is incomplete and inefficient.

“The global food supply contains thousands of evolving additives and ingredients, and no regulatory body maintains a comprehensive list,” Moran said. “As a result, many unhealthy products would slip through the cracks, and regulators would be left playing catch-up.”

This strategy, which aligns with the Nova classification system, allows regulators to identify healthy foods by their limited, well-understood ingredients and production methods. It would prevent what Moran called a “whack-a-mole approach” to nutrition policy, whereby the food industry would simply reformulate their foods to include additives and ingredients that are not yet on the FDA’s list.

“All other products would be considered ultra-processed by default, closing loopholes and making it harder for manufacturers to game the system,” Moran said.

This approach also shifts the burden of proof from public health agencies to food manufacturers, who would need to demonstrate that any new additives are necessary for safety, and not just for appearance or taste.

“By defining what makes a food ‘real,” we can create a more robust and efficient regulatory system that truly protects public health,” Roberto added.

Ultimately, they argue, defining ultra-processed foods by what they are not empowers policymakers to act more decisively and encourages the food industry to innovate healthier options. This shift could help reverse the tide of diet-related diseases, especially among children, and create a stronger foundation for future nutrition policy.