Does FDA consider conventional foods that, in their natural state, do not contain protein or are low in protein to meet the definition of a medical food?

No. Conventional foods such as fruits, certain vegetables, fats, and sugars generally are not specially formulated to be significantly low in protein or to contain no protein—instead, they are low in protein in their natural state. Under 21 CFR 101.9(j)(8)(i), a medical food must be a specially formulated and processed product (as opposed to a naturally occurring foodstuff used in its natural state) for the partial or exclusive feeding of a patient by means of oral intake or enteral feeding by tube. Therefore, conventional foods that do not ordinarily contain protein or are ordinarily low in protein would not meet the statutory and regulatory criteria for medical foods.