Non-ultra-processed foods summary
- Current UPF definitions rely on Nova classification grouping foods by processing
- Regulating additives directly is costly and easy for manufacturers to bypass
- New proposal suggests defining UPFs by absence of non-UPF characteristics
- Burden would shift to manufacturers to prove additives are essential for safety
- Category-based approach allows exceptions for foods with nutritional or sustainability benefits
So far, the conversation around ultra-processed foods (UPFs) has focused on what these foods are, and how they can be identified. Much of the coverage around the health risks of UPFs have been linked to food additives.
Policy suggestions on tackling UPFs are often focused on regulating additives themselves, many of which have been linked to mortality.
But what if, suggests a comment published in Nature Medicine, we were instead to build a definition of ultra-processed foods based on what they’re not?
Benefits of defining non-ultra-processed foods
The most common way of defining ultra-processed foods is through the Nova classification. This groups foods into four processing levels, the highest of which, ultra-processed foods, are those made from ingredients extracted from whole foods combined with additives, and often contain little to no whole foods.
One of the ways that future food regulation around UPFs may use to identify additives is to single out commonly used ones found in the foods. Considering the sheer number of such additives, this process would likely be costly and burdensome for regulators, let alone manufacturers.
And such an approach, according to researchers, could be circumvented by suppliers finding or developing new ultra-processed ingredients not already covered by the legislation.
“It is potentially quite easy for companies to develop new ingredients, with very similar chemical structures and functions, that don’t currently exist, and therefore are not included in the ultra-processed food definition,” says Alyssa J Moran, one of the comment’s authors.
This has already been seen, for example in the US when companies began to rely on Red Dye 3 after Red Dye 2 was banned (although Red Dye 3 was also recently banned).
No regulatory body in the world has a complete list of all cosmetic additives, meaning that there would always be additives left off any ‘banned’ list.
Proving additives have benefits
If regulators were to, instead, place the burden on manufacturers to prove that additives are necessary for food safety, suggests Moran, the process would be less complex and time-consuming.
Before manufacturers have proved this, a product containing additives would be considered ultra-processed by default, thus removing the incentive for a manufacturer to find a new additive to replace a regulated one.
This is important, because the role of an additive in a product can make the difference between it being either UPF or not UPF.
As additives are often multi-purpose, placing the burden on manufacturers to prove that an additive has a necessary function would help regulators make sense of why a food has a certain composition.
Identifying which products are not ultra-processed means that, by default, all products that do not fit this definition are ultra-processed.
How would non-ultra-processed foods be defined?
First, foods could be grouped into categories, depending on how they’re produced and consumed. The starting point would be how foods are commonly consumed in a typical diet, and this would be refined after that. Yoghurt, for example, could be a category.
For each category, a definition of ‘non-ultra-processed’ could be created, using Nova’s UPF classification in combination with expert knowledge of the technology necessary to produce the product to meet minimal safety standards.
Other definitions of non-UPF
Before the current proposal, other definitions of non-ultra-processed foods have been developed.
Last year, the Non-UPF Verified certification was rolled out. This definition is based on two main criteria: processing limits and ingredient integrity.
- Under the standard, products must be at least 70% minimally or moderately processed, and methods such as synthetic biology and 3D printing are prohibited.
- There are restrictions on levels of added sugars, which vary by product category. Non-nutritive sweeteners and bio-enhanced sweeteners are prohibited, and minimally processed ingredients like stevia are acceptable so long as they’re not used as a sugar replacement.
- Some other additives are allowed, but only if the company making the product can demonstrate that no less processed alternatives exist.
Another set of criteria, from the Non-UPF Program, simply allows products that are classified between 1 and 3 by Nova, although it is also monitoring new preservatives. Each product is put under review.
Therefore, regulators would know which additives are necessary in certain contexts, for factors such as food safety. Necessary additives would not condemn a food to be considered UPF – only unnecessary additives would.
It is far easier for regulators to identify the additives necessary for food safety than attempt to keep a complete list of existing additives, which are used for purposes such as shelf-life extension and cosmetic appeal.
Exceptions to the regulation
This contextual approach would mean that certain foods could be free from regulation if they had other benefits – for example, plant-based meat has sustainability credentials. Other foods, such as bread or yoghurt, may not be prohibited from schools because of the important nutrients they contain.
Using a category-based approach “makes it easier for policymakers to determine which categories of ultra-processed foods will be regulated, based on their goals, their context, the kind of benefit to risk ratio that the product has,” says Moran.
The method above simply defines the foods in scope for a UPF regulation, rather than those that will definitely be regulated. Therefore, there is always room for exceptions.
