Will a UPF definition flag your sauce thickener? 69 texturants checked

Against the HER expert panel's ultra-processed marker lists, 39 of 69 texturants in the SKS library carry a named marker, mostly modified food starch. Clean-label starches are not named, but their status is unsettled.

The short answer

If your sauce uses modified food starch, probably yes, under the most detailed published proposal. SKS compared 69 texturant entries in its reference library, compiled from Tate & Lyle, Ingredion and Cargill literature, with the ultra-processed food (UPF) marker lists in the May 2026 Healthy Eating Research (HER) expert panel report. 39 of them (57%) would carry a label name the report lists, mostly "modified food starch". The 20 clean-label starches that label by base name, such as "corn starch", are not named, but no source settles how a federal definition would treat them.

Where the federal UPF definition stands, as of November 2026

Submitted, not published. On August 10, 2026, HHS announced that HHS and USDA had submitted the federal government's first proposed definition of ultra-processed foods for final review. Food Engineering reported that it went to the Office of Information and Regulatory Affairs as a white paper and that no legal deadline had been set. The text has not been released.
Pressure to release it. PBS NewsHour reported on October 23, 2026 that more than 100 experts had sent an open letter to the Office of Management and Budget urging release of the definition, and that the effort had stalled.
Background. FDA and USDA opened a request for information on a UPF definition in July 2025. It closed for comment on October 23, 2025.

Until the federal text is out, the most detailed public model to test against is the HER panel's, an independent recommendation, not a federal rule.

What the HER panel would count as a UPF marker

The 14-member panel recommends Nova Category 4 as the scientific basis and an ingredient-based rule: a product is a UPF if it contains at least one marker ingredient, meaning a cosmetic additive and/or an ingredient of non-culinary use. The report says markers are chosen as reliable indicators of Nova 4, not because of inherent health risks of the individual ingredients.

Cosmetic additives are any additive in these functional classes: flavors and flavor enhancers, colors, sweeteners, emulsifiers and emulsifying salts, thickeners and bulking agents, anti-foaming and carbonating agents, and gelling and glazing agents. The appendix tables name examples that matter for sauces and dressings:

Listed against FDA's "stabilizers and thickeners" technical effect: carboxymethyl cellulose, carrageenan, guar gum, modified food starch, pectin, polydextrose.
Emulsifier examples: carob bean gum, gum arabic, hydroxypropyl methylcellulose, lecithin.
Also named among the cosmetic additive examples: mono- and diglycerides of fatty acids, agar.
Non-culinary ingredients: modified starch, maltodextrin, soluble and insoluble fiber, whey protein and whey isolate, protein isolates, lecithin.

Plain starch is not on these lists, and neither are xanthan gum or gellan gum by name, although both are used as thickening and gelling agents. Vitamins and minerals, herbs and spices, and yeast are excluded from the marker list.

The panel also proposes that a UPF meeting FDA's "healthy" criteria and containing no non-sugar sweetener be exempt from policy action. That exemption does not change its classification as a UPF.

What SKS found in 69 texturant entries

The SKS texturant reference library holds 69 entries (products or product ranges): 37 from Tate & Lyle, 18 from Ingredion and 14 from Cargill. It records type, chemistry and process tolerance as the suppliers describe them; it is not lab data, and it reflects these three portfolios, not the whole US market. SKS grouped each entry by the label name its recorded chemistry implies and compared those names with the HER tables:

Modified starches: 35 (51%). Cook-up, instant, emulsifying and highly modified grades. These label as modified food starch, which appears in the cosmetic additive table, and "modified starch" appears on the non-culinary list.
Clean-label starches: 20 (29%). 11 are recorded as "clean label modified starch", the rest as clean-label native, organic or instant starches; 16 come from Ingredion's NOVATION range. Ingredion states that its functional native starches label by base descriptions such as "corn starch" or "tapioca starch". For the Tate & Lyle and Cargill grades, confirm the label declaration on the specification. Not named in the HER tables.
Pregelatinized and dry-mix starches: 6 (9%). The label name depends on whether the grade is chemically modified, so check the specification.
Pectins: 2. Named in the stabilizers and thickeners examples, including one sugar beet pectin marketed as clean label.
Xanthan gum blend: 1. Its notes list guar, locust bean gum and carrageenan, which the tables name.
Xanthan and gellan gums: 2. Thickening and gelling functions, but not named as examples.
Microparticulated whey protein: 1. Whey protein is on the non-culinary list.
Citrus fiber: 1. Marketed as clean label, but could fall under "soluble fiber" or "insoluble fiber". Unclear.
Gluten-free flour blend: 1. Likely culinary; check the blend's components.

Put together, 39 of 69 (57%) carry a name the HER tables list, 41 (59%) are named or used for a listed function, and 27 (39%) have an unclear status: the 20 clean-label starches, the 6 pregelatinized and dry-mix grades and the citrus fiber. These shares describe the library's mix of entries, not market share or usage.

Two details stand out. "Clean label" marketing does not mean "not a marker": the clean-label pectin is named outright. And harsh-process entries are mostly modified starches: of the 6 entries whose process-tolerance or notes field mentions retort, aseptic or UHT, 5 are modified starches and 1 is a clean-label instant starch tagged for UHT.

Can clean-label starch replace modified starch in a sauce?

Sometimes. Of the 20 clean-label starches, according to the supplier descriptions captured in the library:

12 are tagged for heat, acid and shear tolerance.
4 of those carry qualifiers such as "moderate" or "low-moderate" for at least one stress.
2 instant grades are tagged for heat and shear but not acid.
1 is tagged for UHT only.
5 have no process tolerance listed.

Nutritional Outlook reported in 2018 that retort, high shear, low pH and freezing are the conditions that challenge clean-label starches, and that starches have historically been chemically modified to tolerate them. Treat the library's tags as supplier claims and verify them:

Sort your line by process first. Hot-fill, acidified dressings and retorted soups are different problems.
Test the exact stress, not the brochure. Measure viscosity before and after your real process and after a shelf-life temperature cycle, including freeze-thaw if the product is ever frozen.
Look at the whole label, not only the thickener. Under the HER rule one marker is enough. If the formula keeps a natural flavor, a color or an emulsifier, swapping the starch does not change the classification. Panel co-chair Jim Krieger said in a June 2026 interview that of the products they examined, "Most had three, four, five or more" markers.
Use the food matrix where it fits. Tomato solids, fruit pulp, vegetable purees and egg yolk build body without an added thickener.
Do not reformulate to a draft. The federal text is unpublished and could differ from the HER model. Plan options now and decide when the criteria are public. Consult a regulatory expert on labeling.

To benchmark texture, the SKS Category Atlases include SKS reference texture scores for 100 US sauces, and AI Formula Ideation can draft a starting formula with an alternative texturant system that you then put through those process tests.

What we do not know yet

Whether the federal definition will use ingredient markers at all, nutrient thresholds, or both.
How a marker list would treat starches that are physically modified but label as "corn starch". The HER report does not name plain starch, and no source SKS read addresses this case.
Whether isolated fibers such as citrus fiber would count as non-culinary.

How SKS analyzed this

SKS used its texturant reference library (69 entries compiled from Tate & Lyle, Ingredion and Cargill literature), which records each entry's type, chemistry, positioning and process tolerance as the suppliers describe them. With a Python script, SKS assigned each entry to a label group from its recorded chemistry and notes (modified, clean-label, pregelatinized or dry-mix starch, pectin, gum or gum blend, protein, fiber or flour) and compared the groups with the cosmetic-additive and non-culinary tables in the May 2026 HER report. Process tolerance counts come from keyword matches on "heat", "acid", "shear", "retort", "aseptic" and "UHT" in the library's tolerance and notes fields. The mapping is SKS's reading of a non-binding proposal, not confirmed by any agency.

Frequently asked questions

Is modified food starch an ultra-processed marker?

In the HER expert panel's proposal, yes. Modified food starch is a named example in the cosmetic additive table, and modified starch is on the non-culinary list. The federal definition has not been published, so whether it uses the same lists is unknown as of November 2026.

Would xanthan gum make a sauce ultra-processed?

The HER tables SKS read do not name xanthan gum, but the rule covers any additive in the thickener and gelling functional classes, which describes how xanthan is used in sauces. Treat it as a likely marker under that model.

Does a clean-label starch avoid the UPF label?

Not on its own. A starch that labels as "corn starch" is not named in the HER tables, but how a thickening starch would be treated is unsettled, and any other marker in the formula, such as a flavor, color or emulsifier, would still classify the product.

Should I reformulate now?

Not to a draft. Map which products depend on modified starch and gums, and run process tests on alternatives so you have options. Commit once the federal criteria are published, and check labeling with a regulatory expert.

Sources

Secretary Kennedy Announces Landmark Food Policy Reforms to Advance President Trump's MAHA Agenda, U.S. Department of Health and Human Services, August 10, 2026. https://www.hhs.gov/press-room/hhs-announces-ultra-processed-foods-gras-reforms.html
FDA, USDA Submit 'Ultra-Processed Foods' Definition for Final Review, Food Safety Magazine, August 10, 2026. https://www.food-safety.com/articles/11714-fda-usda-submit-ultra-processed-foods-definition-for-final-review
HHS, FDA Submit Proposed Definition of 'Ultra-Processed Foods' for Final Review, Food Engineering, October 8, 2026. https://www.foodengineeringmag.com/articles/103964-hhs-fda-submit-proposed-definition-of-ultra-processed-foods-for-final-review
What exactly are ultraprocessed foods? Experts weigh in as RFK Jr.'s effort to define them stalls, PBS NewsHour, October 23, 2026. https://www.pbs.org/newshour/health/why-experts-are-pushing-rfk-jr-to-release-a-federal-definition-of-ultraprocessed-foods
Ultraprocessed Foods in the U.S.: Recommended Definitions and Policies, Healthy Eating Research technical report, May 2026. https://healthyeatingresearch.org/wp-content/uploads/2026/05/HER-UPF-Expert-Panel-Technical-Report-04-1.pdf
Q&A: A better definition of ultra-processed foods, UW News, University of Washington, June 23, 2026. https://www.washington.edu/news/2026/06/23/qa-a-better-definition-of-ultra-processed-foods/
Functional native starches, Ingredion. https://www.ingredion.com/na/en-us/ingredients/ingredient-types/starches/functional-native-starches
Clean-Label Starch Innovations Are Quickly Expanding Applications for Food, Beverage Formulators, Nutritional Outlook, May 2, 2018. https://www.nutritionaloutlook.com/clean-label-starch-innovations-are-quickly-expanding-applications-food-beverage-formulators

Published by SKS Nutrition. Explore the tools behind this research on SKS Nutrition AI.