Conflicting snack ratings explained
- Nutritional quality and ultra-processed classifications measure different characteristics, so a product can meet one standard while failing another
- Removing an additive may improve certification eligibility or an app score without changing sugar, salt or fibre
- Yuka’s user survey suggests ratings influence purchasing, although it doesn’t measure sales gains following reformulation
- Manufacturers should weigh certification requirements against nutritional benefits, production performance, shelf life and commercial returns
Food producers can spend months cutting sugar, increasing wholegrain and reducing salt, only to find that an emulsifier still prevents a product from qualifying for a non-UPF label. Removing it might improve eligibility without changing those nutritional achievements, leaving the business to explain why a recipe considered acceptable under one assessment falls short under another.
Brand owners face this problem because nutrition rules, processing classifications and food-scanning apps don’t measure healthfulness in the same way. Some require particular amounts of recommended food groups and limit certain nutrients; others scrutinise ingredient categories, manufacturing methods or individual additives. A product can satisfy one set of requirements without meeting the others, even when every assessment is being applied correctly.
California’s decision to introduce a voluntary state-backed non-ultraprocessed certification programme gives manufacturers another reason to examine those differences before committing to recipe changes. Governor Gavin Newsom signed AB 2244 on 28 September, with the California Department of Public Health required to accredit certification agents by 1 June 2029.
Increasing wholegrain content, lowering sodium and removing an emulsifier could consequently compete for the same R&D budget while offering different nutritional and commercial returns. Producers need to establish which changes improve the food, which secure a claim or retail opportunity, and whether pursuing one objective makes another harder to achieve.
Why nutrition scores and non-UPF standards disagree
The US Food and Drug Administration’s (FDA) updated voluntary ‘healthy’ claim requires qualifying amounts of recommended food groups alongside limits on added sugars, saturated fat and sodium. Grain products generally need at least 12g (¾ oz) of whole grains per reference amount customarily consumed, with maximums of 5g added sugar, 230mg sodium and 1g saturated fat.
The FDA identifies fortified white bread and highly sweetened cereals among products that qualified under the previous criteria but wouldn’t under the updated definition. Their previous eligibility doesn’t protect them when the nutritional requirements change.
Under California’s programme, certification agents must exclude products meeting specified additive criteria, as well as those classified as UPFs of concern or restricted school foods. The referenced categories include emulsifiers, stabilisers and thickeners, and certain flavouring agents, subject to specified exceptions.
A hypothetical wholegrain cracker illustrates the practical consequences. Increasing its wholegrain content and lowering sodium could help it satisfy the FDA’s nutritional requirements while leaving a disqualifying emulsifier in the recipe. Taking out that emulsifier would address the certification obstacle but wouldn’t itself deliver another gram of wholegrain or a further reduction in sodium.
The food-scanning app Yuka combines nutritional and ingredient assessments within a single score, although its approach differs from California’s eligibility rules. Gabriella Sebag-Weingrad, Yuka’s US country manager, says nutritional quality accounts for 60% of its food score, additive assessments for 30% and organic certification for 10%. Its nutritional component is based on Nutri-Score, while additives are assessed individually.
“The seal and Yuka answer different questions, though, so on some products they will disagree,” she says.
Research using UK consumption data shows how substantially nutritional and processing classifications can diverge. A 2025 study in BMJ Nutrition, Prevention & Health examined food and drink items consumed across 11 annual waves of the National Diet and Nutrition Survey. It classified 36.2% as ultra-processed, 33.4% as high in fat, salt or sugar (HFSS), and 20.1% as both.
Calculated from those proportions, around 44% of items classified as UPF weren’t HFSS under the nutrient profiling model used. White, brown, granary and wholemeal breads were among the common contributors to that group.
The researchers used Nova and the UK nutrient profiling model, rather than California’s criteria, so the findings don’t predict eligibility for the new seal. They do show why a producer can improve nutritional composition without necessarily escaping an ultra-processed classification.
A better score needs a better explanation
Yuka argues that its combined approach prevents manufacturers from securing a favourable rating by removing an additive while leaving a poor nutritional profile untouched.
“A snack with a poor nutritional profile cannot reach a ‘good’ rating just by removing an additive,” says Sebag-Weingrad. She adds that a product with a Nutri-Score of D or E cannot exceed 49 out of 100 on Yuka, regardless of its organic status or additives. A single additive that Yuka classifies as high risk also caps the overall score at 49.
Brand owners examining a score improvement need to establish what changed in the recipe. Removing an additive may lift the rating without changing sugar, salt or fibre, while improving nutritional composition could leave an additive-related ceiling in place. Communicating the specific improvement would give shoppers more useful information than announcing a higher number alone.
The commercial incentive to improve those ratings is evident in Yuka’s 2024 US impact survey of more than 20,000 users. “Ninety-four percent of users said they put a product back on the shelf when it is rated red, and 56% said they always do,” says Sebag-Weingrad. “Eighty-nine percent look for another product on the shelf, and 66% often or always choose an alternative the app recommends.”
These are self-reported purchasing habits, rather than measured sales changes following reformulation, but they give producers a reason to investigate how ratings influence their customers before dismissing them or investing heavily in improving them.
Choosing a certification programme requires similar scrutiny. In an August article published on its website, the US consumer advocacy organisation Center for Science in the Public Interest compared three private non-UPF programmes: the Non-UPF Program, the Non-GMO Project’s scheme and WISEcode’s offering.
Its authors highlighted differences in the ingredients, processing methods and nutrients considered by each programme. They also raised concerns that certification could imply more about overall healthfulness than the criteria establish, making the choice of scheme consequential for both formulation and packaging claims.
Sebag-Weingrad points to a further problem with voluntary certification, since shoppers won’t necessarily know why one product carries a seal and another doesn’t. “The seal is voluntary: it will appear on products that qualify but say nothing about those that don’t,” she says.
A product without a seal may never have been submitted for assessment, yet its producer could still face questions from retailers or shoppers who assume it failed to qualify.
Meeting nutritional guidelines also doesn’t settle every concern about processing. A 2025 randomised crossover trial recruited 55 adults with overweight or obesity and provided two eight-week diets, both following the UK Eatwell Guide. Average weight loss was 2.06% on the minimally processed diet and 1.05% on the ultra-processed diet, although the study didn’t isolate which ingredients or food characteristics accounted for the difference.
Assessing individual additives requires evidence on exposure and potential health effects. Sebag-Weingrad says Yuka considers consumption across the diet, including exposure among vulnerable groups, when evaluating them.
“Low levels in one product therefore do not settle the question on their own because exposure builds up across a whole diet,” she says.
Producers defending an ingredient need to address that wider exposure evidence alongside its technological function. Assessors, in turn, need to explain how their conclusions relate to the quantities people consume, rather than treating an ingredient’s presence as sufficient evidence of harm.
Which change deserves the reformulation budget?
Before authorising a reformulation, producers should be able to describe the intended improvement without relying on the name of a certification or app. A target such as increasing wholegrain content or reducing sodium can be measured directly; securing a seal requires a separate explanation of the commercial opportunity and the changes needed to qualify.
Retailer requests need the same precision, particularly when ‘non-UPF’ could refer to different standards. R&D teams need the named programme, its current criteria and the documentation required to demonstrate compliance, rather than a broad instruction that leaves developers guessing which ingredients and processes are acceptable.
That assessment should include supplier specifications, especially where eligibility depends on technical categories or ingredient functions. A more familiar name on the pack doesn’t establish compliance, and replacing one ingredient with another is a poor use of development time if the substitute encounters the same restriction.
Developers also need to measure the consequences of removal across production and shelf life. An emulsifier-free prototype may perform well in an initial tasting, but the investment decision needs evidence on texture, consistency, manufacturing performance and cost over the period in which the product will actually be sold.
Certification itself introduces continuing responsibilities. California’s law requires products to be recertified at least every three years, while reformulated products must receive recertification before continuing to use the seal. Future recipe changes will therefore need to account for certification requirements as well as procurement, production and labelling.
A convincing business case should show what the reformulation delivers beyond eligibility: a nutritional improvement, access to a valuable listing, stronger repeat purchase or another outcome that can be evaluated. Where the return depends on shoppers valuing a seal or score, that assumption deserves testing before the full development budget is committed.
Manufacturers will struggle to satisfy every assessment, but they can demand a defensible reason for each recipe change. Chasing approval becomes expensive when an ingredient disappears, costs rise and nobody can demonstrate what improved. A seal may help sell the product; it cannot justify the reformulation on its own.
Three assessments, three different questions
FDA ‘healthy’ claim
Does the product contain qualifying amounts of recommended food groups while meeting limits on added sugars, saturated fat and sodium? It assesses nutritional composition; qualifying doesn’t automatically establish non-UPF status.
California’s forthcoming non-UPF certification
Does the product meet the state’s eligibility requirements, including its additive restrictions and exclusions for designated foods? It determines eligibility for a seal, rather than awarding a nutritional score.
Yuka rating
How does the product score when nutritional quality, individual additive assessments and organic certification are combined? These account for 60%, 30% and 10% respectively, with scoring ceilings for poor nutritional profiles and additives Yuka classifies as high risk.
What this means for formulation
Increasing wholegrain could help satisfy the FDA criteria, while removing a disqualifying emulsifier could address a California certification requirement. Either change might affect a Yuka score differently, so producers need to check each assessment separately.
Studies:
Kesaite V, Chavez-Ugalde Y, White M, Adams J. Overlap between ultra-processed food and food that is high in fat, salt or sugar: analysis of 11 annual waves of the UK National Diet and Nutrition Survey 2008/2009–2018/2019. BMJ Nutrition, Prevention & Health. 2025;8:. https://doi.org/10.1136/bmjnph-2024-001035
Dicken SJ, Jassil FC, Brown A, et al. Ultraprocessed or minimally processed diets following healthy dietary guidelines on weight and cardiometabolic health: a randomized, crossover trial. Nat Med31, 3297–3308 (2025). https://doi.org/10.1038/s41591-025-03842-0
