As the Administration’s new dietary guidelines urge us to “eat real food,” actually avoiding sketchy additives in everything from tortillas to coconut milk is not getting easier. This is true even for customers at Whole Foods, one of the nation’s largest chains committed to “sell[ing] the highest quality natural and organic foods.”
Our investigation started after noticing a change in the ingredient list on a longtime favorite: the retailer’s private label “365 brand” corn tortillas. Whereas before the tortillas contained only stone-ground corn flour, water, and lime, they now contain an additional ingredient: guar gum. Guar gum is an emulsifier and characteristic ultra-processed food ingredient. To see whether this new additive represents an isolated change or part of a larger trend, we analyzed other 365 product ingredient lists over time. It turns out that several have added gums in just the past few years alone. Call it ultra-processed food creep.
When did they make these changes? The exact date is unclear. Unsurprisingly, Whole Foods does not publicize the addition of unfamiliar chemicals like guar gum to products that previously contained only “simple” ingredients. The USDA Branded Foods database, which contains information on formulation changes over time, would seem like the perfect tool to investigate, but updating entries to the database is voluntary for food manufacturers. We were only able to confirm that previous versions of the corn tortillas did not contain guar gum by finding an old YouTube video that showed the product label. With that suspicion confirmed, we set out to find other examples of ingredient proliferation.
Our analysis compared two separate “scrapes” (pulling data off a web page) of the Whole Foods website. These scrapes contained data on each product sold, as well as each product’s ingredients. The first scrape was conducted by Harvard researchers in 2021 and is publicly available here. The second scrape was done by the popular health app GoCoCo in 2023 and shared with us by GoCoCo’s research team.[1] We filtered both datasets for Whole Foods’ private label products (365 brand) as Whole Foods controls these products’ ingredient formulations. Then, we compared the ingredient lists of the 256 products that contained “gums” (e.g. guar gum, xanthan gum, gellan gum) in the more recent dataset to the older dataset to determine changes over time.[2]
We discovered that Whole Foods added guar gum to the following three products:
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Organic Unsweetened Coconut Milk
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Frozen Four Cheese Rising Crust Pizza
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Citrus, Lemon, Orange, Strawberry Lemonade Pop-Ups
And added gums (other than guar gum) to three products that did not contain any in 2021:
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Chocolate Sandwich Cremes (Xanthan Gum)
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Organic Heavy Cream (Gellan Gum)
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Vanilla Sandwich Cremes (Xanthan Gum)
In other words, sometime between 2021 and 2023, these foods became ultra-processed, or in some cases, more ultra-processed.
Why does this matter? Ingredients like guar gum, which comes from the endosperm of the guar plant (Cyamopsis tetragonoloba), a legume native to Asia, may cause little harm or even benefit health when consumed in small quantities. But as toxicologists are fond of saying, it’s the dose that makes the poison. Research suggests that emulsifiers like guar gum may injure the gut at higher levels. One recent animal study, for example, concluded that “guar gum increased susceptibility to colitis.” When added to a diet already featuring high levels of other chemical emulsifiers commonly added to processed foods—e.g. lecithins, mono- and diglycerides, polysorbates, carrageenans, carboxymethylcellulose—the gums may have a cumulative impact that researchers suggest “could contribute to developing metabolic and inflammatory diseases through the modulation of the gut microbiota.”
So, there’s reason to want to avoid these ingredients, albeit subject to some uncertainty. Whole Foods has nevertheless calculated that the money it saves from adding these ingredients to products like “organic heavy cream” will outweigh any lost sales that result from alienating customers. That bet may pay off because many consumers will not notice if their cream suddenly contains gellan gum. But even if they do, most Whole Foods customers have few good retail alternatives for buying “health foods” like tortillas with a shelf-life of less than three years or organic heavy cream.
Indeed, those in search of culprits behind ultra-processed food’s rising prominence in the American diet may need look no further than the collapse of competition in food retail. Economic theory holds that firms with monopoly power undersupply goods to the market to maximize profits, leaving consumers to overpay for inferior products. In the food sector, this dynamic suggests that monopolies will use their market power to undersupply “real food” and steer consumers toward cheaper, more profitable ultra-processed alternatives.
With this theory in mind, the new gums in Whole Foods’ products are unsurprising. They are simply what happens when a dominant retailer, insulated from meaningful competition, has every financial incentive to quietly degrade its products — and no particular reason to fear the consequences.
Unfortunately, the problem extends far beyond just Whole Foods. According to USDA, the top four grocery retailer’s share of sales increased from just 13% in 1990, to 34% in 2019. Simultaneously, between 2001 and 2019, the proportion of food products purchased by U.S. households that contained additives (i.e. were UPFs) rose from 49.6% to 59.5%. Correlation does not always signify causation, but the factors contributing to consolidation in the food retail space suggest the trends are related. If a retailer whose brand identity touts a commitment to natural, organic, and healthy products cannot resist the lure of cheap food additives, why would we expect its competitors with a less health-conscious customer base to act differently?
Findings like ours underscore the need to rein in corporate excess to improve American diets, and why ad campaigns alone will do little to reduce obesity and other diet-related disease. Consumers would like to “eat real food.” But corporate capture of the food system has created an obesogenic environment that makes healthy eating hard: harder than exercising regularly, getting eight hours of sleep a night, preparing taxes, or even finding the “perfect gift” for a family member, according to one recent survey. Indeed, the only thing Americans perceive as more difficult than eating well is learning a foreign language. And no wonder! U.S. consumers must struggle against a lack of choice and a sophisticated food marketing apparatus designed to drive profits ever higher through the sale of cheap, unhealthy food-like products, even if that means periodically tricking us into buying something we do not want.
Have you noticed ultra-processed food creep in any of the foods you buy? If so, please reach out to us at eweiland@consumerfed.org. And if you are interested in learning more about the ways public policy can help consumers “eat real food,” check out our report “Ultra-processed Foods: Why They Matter and What to Do About It.”
[1] Ideally, we’d have more recent data but both research teams explained to us the difficulty of scraping Whole Foods’ website today due to measures now in place to prevent scraping by bots seeking training data for AI.
[2] Unfortunately, corn tortillas were not captured in the scrapes.

