Why Regulating Ultra-Processed Foods Is a Public Health Priority

Ultra-processed foods (UPFs) have become a dominant force in modern diets — and a major driver of chronic disease. A growing body of scientific evidence links their consumption to obesity, diabetes, cancer, and cardiovascular disease. Unlike natural or minimally processed foods, UPFs are industrial formulations designed to maximize profit and encourage overconsumption, exploiting the brain’s reward and appetite mechanisms. Addressing their impact is no longer a matter of personal choice, but a public health necessity.

The public health imperative to regulate Ultra-Processed Foods

Ultra-Processed Foods as a major cause of diet-related diseases

Ultra-processed foods (UPFs) are a leading cause of diet-related illness and premature death.1,2 In the United States, one person dies every four minutes from diet‑related causes linked to UPF consumption.3 UPF consumption is strongly linked to obesity, type 2 diabetes, hypertension, cancer, cardiovascular disease, depression, dementia, cognitive decline, liver fat accumulation, reproduction problems and other non-communicable diseases (NCD). The scale of harm makes UPFs a public health emergency.4-14

Strong and converging scientific evidence confirming UPF harm

The evidence linking UPFs to poor health outcomes is already overwhelming: since 2015, more than 80 prospective studies consistently showed associations between consumption of UPF and adverse health outcomes.15 Recent randomized controlled trials in humans, the gold standard for establishing causality, demonstrate that UPF diets influence cardiometabolic and reproductive health, overeating and weight gain compared to minimally processed diets with the same amount of calories.16 Large cohort studies and meta-analyses confirm these findings across populations and health outcomes.17-20

The negative effects of an ultra-processed diet can be seen rapidly. In a study of 2025, the degradation of various health markers was observed in young men in just three weeks when switching from a non-UPF diet to an UPF diet, despite consuming the same number of calories.16

While industry groups claim research is still “emerging,” the existing body of evidence is already strong; much stronger, in fact, than what we had when regulations were first put in place for tobacco or alcohol. Back then, policymakers didn’t wait for decades of randomized trials; they acted based on the precautionary principle.21,22 That same principle must apply here.

The prevalence of UPFs in the American diet

Unlike alcohol or tobacco, whose use is usually limited or age-restricted, UPFs are consumed daily— often beginning in early childhood and continuing throughout life. They now provide more than half of the calories in the U.S. diet and account for around 70% of the national food supply.23,24 UPFs consumption in the U.S. is among the highest in the world.25 Their ubiquity magnifies their impact, normalizing harmful consumption patterns across the entire population.

Source: Touvier et al, EMJ 202326

The structural limits of voluntary industry reform

The health crisis caused by UPFs cannot be solved through voluntary industry reform. These products generate too much profit to expect meaningful reform from within. Made with cheap ingredients, addictive formulations and aggressive marketing, UPFs form the backbone of a business model that prioritizes profit over health. Because the mechanisms that make UPFs harmful are the same ones that make them profitable, the industry has no incentive to change voluntarily.

UPFs were not designed to nourish, but to maximize profit by driving overconsumption. They exploit neurobiological mechanisms related to reward, pleasure and appetite. By combining sugar, salt, fat, and hyper-palatable sensory elements such as colors, aromas, and textures, they override natural satiety signals and encourage compulsive eating. This intentional and systemic design promotes pathological eating behaviors and makes public regulation the only viable mechanism to protect health.27-36

This is a structural market problem, not a series of isolated consumer choices. Over the past three decades, global food companies have systematically used neurobiological science to create products that are harder to resist and easier to overconsume. As The Lancet NCD Action Group has described, UPFs are the vectors of an “industrial epidemic” and like any epidemic, they require a coordinated, policy-driven response.37

Scientific and practical foundations to define Ultra-Processed Foods

The NOVA Classification

The internationally recognized NOVA classes food in 4 groups (NOVA 1, 2 ,3 and 4) based on the extent and purpose of industrial processing – not their nutrient composition.  Ultra-processed foods (UPFs) correspond to NOVA Group 4. These products bear little resemblance to real, whole foods — those found in nature and prepared by humans for centuries. Such products are industrial formulations made from ingredients extracted from foods or synthesized in laboratories, designed to be cheap, hyper‑palatable, long‑shelf‑life, and ready‑to‑consume. 

The NOVA system provides a strong conceptual framework for identifying ultra-processed foods (UPFs). The classification was created in 2009 and has been refined several times since its introduction to reflect advances in research and understanding. In 2019, NOVA researchers published a practical method for identifying UPFs without requiring detailed information about processing steps, relying instead on data available in the ingredient list. 

The NOVA system provides a strong conceptual framework for identifying ultra-processed foods (UPFs). The classification was created in 2009 and has been refined several times since its introduction to reflect advances in research and understanding. In 2019, NOVA researchers published a practical method for identifying UPFs without requiring detailed information about processing steps, relying instead on data available in the ingredient list. 

Based on the NOVA system and on our work at Yuka studying additive-related risks, we propose the following criteria for defining UPFs.

Practical Identification: label-based markers of Ultra-Processing

A product can be identified as an UPF when its ingredient list contains non-culinary substances or certain additives typically found in such products.

A. Presence of industrial ingredients/non‑culinary substances

These ingredients and substances are not found in normal culinary use. Although they may not always be classified as additives under food regulations, they are intentionally added to products. Common examples include:

  • Hydrogenated oils and shortenings
  • Hydrolyzed protein, soy protein isolate/concentrate, casein, whey protein, gluten
  • Mechanically separated meat and textured vegetable protein
  • High-fructose corn syrup, glucose corn syrup, invert sugar/invert syrup, maltodextrin, dextrose, fructose
  • Modified food starch (chemically altered)

B. Additives typically associated with UPFs

UPFs typically have many additives, some are used to enhance a product’s appeal from its appearance to its texture, or to intensify flavor. The NOVA classification refers to these as “cosmetic additives.” These substances can alter the way we consume food by stimulating the brain’s mechanisms related to appetite, reward, and satiety regulation.

We also included certain antioxidants and preservatives that are not classified as “cosmetic additives” by the NOVA system but that have well-documented health risks in the scientific literature. These concerns, along with their extensive use in UPFs, justify their inclusion in this selection.

Examples of widely used additives of concern (non-exhaustive list):

  • Artificial dyes: Yellow 5, Yellow 6, Red 40, Red 3, Blue 1, Blue 2, Green 3, Titanium dioxide, caramel colors
  • Artificial sweeteners: Acesulfame K, Sucralose, Aspartame, Saccharin, Neotame
  • Texture agents: Mono- and diglycerides of fatty acids and its esters, Polysorbates, Modified celluloses, Gums (xanthan, guar, carrageenan), Phosphate additives
  • Flavor enhancers: Monosodium glutamate (MSG), Disodium guanylate, Disodium inosinate, Disodium 5′-ribonucleotides
  • Flavorings : Artificial flavorings, Smoke flavourings
  • Anti-caking agents: Aluminum sulfates and silicates, Silicon dioxide
  • Antioxidants: BHA, BHT, TBHQ, gallates.
  • Preservatives: Nitrites and nitrates, Parabens, Benzoates

By examining the ingredient list, the presence of at least one industrial ingredient or one typical UPF additive from these lists (A and B) can be considered a signal that the product is an ultra-processed food (UPF). Importantly, these ingredients are not inherently harmful; they are useful indicators for identifying products belonging to the UPF category — a category consistently associated with poor health outcomes.

Understanding what qualifies as an ultra-processed food is the first step. However, defining them alone is not enough; it is equally important to understand the mechanisms of harm behind them. The next section explores these mechanisms — considering nutritional quality, additives, and processing level — and how combining these dimensions provides a more accurate picture of their health risks.

Understanding the mechanisms of harm associated with UPFs

The following diagram summarizes the complex mechanisms behind ultra-processed foods, as described by leading researchers in the field. Despite the complexity, these experts argue that an incomplete understanding of these mechanisms should not be used as an excuse for inaction.

Source: Touvier et al, EMJ 202326

A.  Nutritional issues

UPFs are the primary source of foods high in calories, sugars, unhealthy fats and sodium.
UPF contributes nearly 90% of all added sugars in US products. Numerous studies show a strong statistical link between UPF intake and total sugar intake: the more UPFs people eat, the more added sugar they consume.38 Data from the two most recent NHANES national surveys confirm that UPFs represent the largest source of dietary sugars in the American diet. On average, sugars account for 21% of total calories of UPFs compared to only 2.4% in processed foods. This is no coincidence: sugar is deliberately added —even in savory products— to achieve the so-called “bliss point” and stimulate brain reward circuits and reinforce cravings. The bliss point refers to the optimal combination of sugar, salt, and fat that makes food hyperpalatable and difficult to resist.39

Source: Steele et al, 201638

Beyond the amount of sugar and fat, the way these nutrients are combined in a product also matters. In particular, the ratio of calories from fat and carbohydrates is a major driver of overconsumption. A landmark 2018 study demonstrated that foods with an approximately 1:1 calorie ratio of fat to carbohydrates have addictive properties and alter how people perceive energy intake. Participants were able to accurately estimate calorie content when consuming fat alone, but lost this ability when fat was combined with carbohydrates—leading to underestimation and overeating.40 Foods high in both fat and carbohydrates were found to be more rewarding per calorie than foods rich in either nutrient alone, independent of portion size, liking, or total energy content. This 1:1 ratio is rare in nature but common in industrially formulated products, making it both a strong indicator of ultra-processing and a practical tool for identifying UPFs.

B. Impact of processing in the food matrix

Processing affects the caloric and metabolic impact of foods by altering the food matrix, changing how nutrients interact, and influencing both rate of consumption and absorption. UPFs typically have softer textures that require less chewing and promote faster eating rates (quantity and calories/min), leading to reduced satiety and higher overall energy intake compared to non-UPFs. Moreover, calories absorbed gradually through an intact food matrix produce different metabolic responses than those from disintegrated, rapidly absorbed UPFs.

Industrial processes such as extrusion and pre-frying profoundly modify the structure of foods. Extrusion increases the surface area, making nutrients more readily available for absorption. As a result, breakfast cereals made from extruded grains — even when enriched with fiber — do not elicit the same metabolic effects as minimally processed whole grains such as rice or wheat. Similarly, pre-frying modifies the food matrix and markedly increases fat content, while creating a porous structure that promotes rapid fat absorption during subsequent cooking or reheating. As a result, pre-fried instant noodles do not have the same physiological effects as homemade pasta.

Processing can also increase energy density and glycemic load by removing natural fiber, which normally slows digestion and moderates postprandial glucose responses. Because fiber is closely associated with phytochemicals in the food matrix, its disruption also exposes these bioactive compounds to degradative conditions such as heat, light, and oxygen, leading to significant losses of vitamins and phytochemicals. For example, fruit-flavored popsicles not only provoke very different glycemic and insulin responses compared with whole fruits, but also lack the vitamins and phytochemicals naturally present in fresh fruit.

C. Problematic industrial ingredients and food additives

  • Industrial ingredients

They were developed by the food industry to reduce production costs and increase yield. Most of these ingredients are derived from industrial commodities such as corn, soy, or rapeseed (canola), or from by-products of other industries (e.g., protein concentrates, mechanically separated meat etc), which makes them inexpensive and highly attractive for large-scale food production.

  • Food additives typically present in UPFs

Additives can have several functions and they are not all the same. They have different effects and risks for human health.  Here are some examples of additives and their main health harms.

Artificial food dyes: Humans are naturally attracted to colorful foods, and color can manipulate our perception of taste. Food dyes are widely used in products marketed to children, where bright colors increase attractiveness and can even foster brand loyalty from an early age. These dyes are petroleum-based, which makes them highly stable and inexpensive, yet they have no real technological necessity, their use is purely cosmetic. Beyond manipulating brain perception, they have several other biological effects, but what makes them particularly concerning is their potential contribution to hyperactivity and attention disorders in children.41-44

Flavor enhancers: These additives are commonly used in processed foods to intensify taste, stimulate appetite, and promote overconsumption. Monosodium glutamate (MSG) is a well-known example, responsible for the “umami” flavor, often referred to as the fifth basic taste. Some studies suggest that MSG may contribute to leptin resistance, thereby impairing satiety regulation and increasing the risk of being overweight, independently of physical activity or total calorie intake. More recent research also points to a potential association between high MSG consumption and cardiovascular disease, possibly mediated through alterations in glucose tolerance and gut microbiota, both of which play key roles in metabolic health.45-48

Artificial sweeteners: Many people end up eating more when consuming “zero-sugar” products, which are instead loaded with sweeteners. These additives disrupt the body’s mechanisms of sugar perception and blood-glucose control. Intense sweeteners such as aspartame, sucralose, and acesulfame-K emerged a few decades ago as a “miracle solution” providing sweetness without calories. However, an increasing number of studies now highlight their potential health risks. All these compounds share one key feature: they bind to the body’s sweet-taste receptors, which is what gives them their sweet flavor. The issue is that activating these receptors stimulates insulin release, triggering a cascade of physiological responses. Over time, this could promote cardiovascular complications and insulin resistance, a common precursor to type 2 diabetes. Several epidemiological studies have also found an elevated cancer risk associated with the consumption of as little as half a can of diet soda per day. Some researchers even suggest that some artificial sweeteners contribute to the global obesity epidemic.49-53

Preservatives: These additives are used to extend the shelf life of food products. Nitrates and nitrites, commonly added to processed meats, can lead to the formation of nitrosamines, some of which are classified as “probably carcinogenic to humans” and genotoxic. The consumption of processed meat itself is classified by the IARC (Group 1) as carcinogenic to humans. In 2023, the French government announced an “Action plan to reduce the use of Nitrite/Nitrate additives in food.” This plan sets out a three-step roadmap aimed at reducing or eliminating nitrate additives in food products. In addition to cancer risk, nitrate and nitrite exposure have also been linked to type 2 diabetes.54-58

Texturizing agents: These additives modify the texture of foods, usually to make them smoother and create a more pleasant mouthfeel. As a result, they reduce the amount of chewing required before swallowing, which may contribute to overeating.59 This is a key mechanism highlighted in recent research on ultra-processed foods (UPFs): their soft, uniform textures facilitate rapid consumption, preventing sufficient chewing to trigger satiety signals. This large family of additives includes thickeners, emulsifiers and emulsifier salts, bulking agents, foaming agents, gelling agents, and glazing agents. One of the major concerns with some of these compounds is their impact on the gut microbiota — a key pillar of human health that remains widely underestimated. Research shows that an imbalanced microbiota can impair insulin regulation, increase cravings for sugar and fat, and reduce energy levels. More importantly, a disrupted microbiota can trigger low-grade chronic inflammation — a silent inflammatory state with no visible symptoms, yet one that represents the starting point for numerous chronic diseases, including type 2 diabetes, cancer, obesity, and autoimmune disorders.60-62

Artificial flavorings : similar effect to color, flavorings can manipulate perception of taste but they are often hidden behind terms as “flavourings”. 

The need of having a combined approach

Nutrient profiling and ultra-processing capture different but complementary aspects of a food’s health impact. While the two dimensions partially overlap, they are not collinear. Ultra-processed foods (UPFs) tend, on average, to be of lower nutritional quality with higher levels of energy, salt, sugar or fats, yet not all UPFs are nutritionally poor and not all unhealthy products are ultra-processed.63

The scientists behind Nutri-Score (the European reference of nutritional Front of Packaging label) report that this overlap between nutritional quality and ultra-processing is only partial: 87.5% of ultraprocessed foods fall into the less favorable Nutri-Score grades (C–E).64 Meaning that relying on nutrient profiling alone would miss about 12.5% of UPFs. Similarly, a 2024 study found that 16% of UPFs were not identified when only nutritional criteria were used, but this gap closed completely when processing markers were added.65

Conversely, processing-based metrics alone are insufficient: associations between poorer Nutri-Score profiles and higher cancer risk persist even after adjusting for ultra-processed food intake, indicating that nutritional composition has effects beyond processing level.66 To exemplify, pure grape juice (classified as NOVA 1) has a bad nutritional grade by Nutri-Score due to its high sugar content.

Emerging evidence supports the integration of both dimensions. A 2024 study evaluating the updated Nutri-Score, which incorporates certain aspects of the NOVA classification, demonstrated a better alignment between the two systems, reinforcing their complementarity while maintaining their distinct purposes.67 A controlled trial study of 2025 also indicated that both caloric intake and the processed nature of the food are likely to contribute to the deleterious effect of UPF consumption.16

In Europe, regulators are also considering adding a black contour around the Nutri-Score label to indicate ultra-processed products, with promising initial results.

Source: Stour et al, 202368

Beyond accuracy, a combined approach helps prevent policy loopholes. Policies that focus solely on nutrient content have often been bypassed by industrials through reformulations that do not genuinely improve health outcomes. For instance, after Chile69 introduced front-of-pack warning labels for high-sugar products, many manufacturers reduced sugar content but replaced it with non-nutritive sweeteners. A similar trend was observed in Europe with Nutri-Score: some beverages appeared healthier simply because sugar had been replaced with artificial sweeteners, and many breakfast cereals improved their scores by adding fiber. As a result, highly processed extruded cereals and sodas could have good Nutri-Scores despite being clear examples of UPFs. Recognizing these limitations, the Nutri-Score system was updated in 2025 to penalize such reformulations and better reflect overall nutritional quality — strengthening the rationale for a dual system that integrates both nutrient composition and degree of processing.70 

Conclusion

An “ultra-processed food” is an industrial formulation in which the original food matrix is substantially or totally modified by industrial processes (e.g. extrusion, hydrogenation, pre-frying) and/or that contains at least one industrial ingredient, or one additive typically associated with UPFs (e.g., flavorings, flavor enhancers, colorings, sweeteners, texturizers, preservatives). UPFs are typically ready-to-eat/heat and are characterized by combinations of refined carbohydrates, added fats, and/or added sugars not commonly achieved in home cooking.

High UPF consumption is also consistently associated with increased risk of multiple non-communicable diseases (NCDs). Even when diets provide an equal number of calories and similar nutrient composition, UPF diets still lead to greater energy intake and weight gain compared with minimally processed diets. Neither nutrient-based profiling nor processing-based metrics alone are sufficient: nutrient-only labels miss part of UPFs and can be manipulated through reformulation (e.g., use of artificial sweeteners or fiber-fortified extruded cereals), while processing indicators do not capture the full nutritional dimension.

A clear regulatory definition of UPFs paired with promotion of minimally processed foods would allow industry to compete on producing convenient, affordable, accessible real foods, rather than racing to the bottom with addictive, nutrient-poor products. Smart regulation can empower industry to innovate for public good, rather than profit from consumer vulnerability.

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    The Nutri-Score nutrition label : justifications, scientific basis, user guide, benefits, limitations, deployment and update
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