What is the "ultra" in "ultra-processed food"?

Europe wants to tackle “ultra-processed foods”, but what exactly counts, and what evidence should policy rely on? As Brussels weighs new action, the challenge is separating a useful health tool from a catch-all category that drives blunt regulation

By Bill Wirtz

Bill Wirtz is Senior policy analyst at the Consumer Choice Center

07 Apr 2026


Consumer Choice Center (CCC)

One of the most notable political demarcations across the Atlantic has always been health policy, particularly as it relates to food. While the U.S taunts a model reliant on innovation and personal responsibility, Europe advocates a precautionary approach that is keen to regulate. And yet, EU health commissioner Olivér Várhelyi and U.S Secretary of Health Robert F. Kennedy Jr. seems to have found a point of convergence, which according to the Hungarian commissioner "matters deeply to citizens: food and nutrition". 

In line with the aims of the Safe Hearts Plan, the Commission recently announced it will study the effects of so-called "ultra-processed foods (UPF)" and incentivise producers to reformulate their products. That in itself is inherently contradictory if the Commission wishes to act in an evidence-based fashion. You cannot commission a study to establish a link to adverse health effects, and yet also announce your policy intentions. It's akin to a judge saying "we are convening this trial to find out whether the defendant committed the crime and then sentence him for the said crime". In science, it is vital that you never lead with your conclusion.

It is safe to assume that Commissioner Várhelyi plans on riding the wave of actions and statements of RFK Jr. on processed foods. Last year, Kennedy pushed for the regulation of synthetic food dyes and said that the administration promotes "eating real food". The narrative fits with Kennedy as a former presidential candidate, blaming food producers for chronic diseases and famously questioning the necessity for vaccination.  

In a world of tiers and ranks, nuances usually get steamrolled

The concept of focusing on the degree of processing rather than ingredients is considered to be recent nutritional science. The NOVA classification, developed by researchers at the University of University of São Paulo in 2009, first introduced the term "ultra-processed foods". The premise of this new denomination is precision: processing food can describe actions as simple as selling pre-cut fruit, while most people would be more likely to associate a pre-made lasagna with the term "processed". Calling the latter "processed" and the former "minimally processed" would have been the more sensible solution, but in a world of headline-grabbing news and hyperbole, the use of a superlative such as "ultra" probably seemed more opportune at the time.  

In a world of tiers and ranks, nuances usually get steamrolled. The reason the Nutri-Score nutritional labelling remains controversial is because while it made sense to the French researchers who came up with it, it contravenes the Mediterranean diet with its nutrient-dense products with high fat and salt content such as olive oil and cheese. In a similar sense, merely identifying the degree of processing or the palatability – which the NOVA classification does – is not an indicator of whether they can or cannot be part of a healthy diet.  

The general and eternal problem of nutritional science is always the same: you cannot realistically create a representative control group in which, for instance, consumers are observed eating no sugar for thirty years, to then compare it with a similar group that does. That is why nutritional science is always an approximation subject to political priorities. However, what we do know is that many specialised foods are also UPFs under the NOVA rules. These include high-calorie shakes for elderly patients, gluten-free alternatives for consumers with intolerances or Celiac disease, as well as the wide array of protein powders, energy gels, and meal replacement bars used by consumers engaged in sports.  

Merely identifying the degree of processing or the palatability – which the NOVA classification does – is not an indicator of whether they can or cannot be part of a healthy diet

For the sake of argument, let's make the charitable and unverified assumption that specialised nutrition used in medicine or sports would not be thrown under the bus of a processed food directive. This would mean that the Commission would need to intervene in the formulation of what it would deem to be unnecessary or recreational consumption of palatable and processed foods. And that would inevitably lead to the precise thing that the Commissioner pretends not to do, i.e. telling consumers what and when to eat.  

Nutrition has changed because our lives have changed. In a fast-paced professional world, our food choices have adapted to our break time and preferences. Food companies don't produce what they deem us to eat, but they respond to the market incentives consumers give. And yes, those incentives aren't perfect. Some people overeat, some people ignore the diversified needs of a healthy diet. But deriving from the excesses of some towards the regulation of the many, or otherwise said, assuming that the lack of organisation of some consumers necessitates organisation out of the offices of Berlaymont, is fallacious.

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