The race to define ultra-processed foods (UPFs) is exposing the limits of the category itself. As the Food and Drug Administration (FDA) acknowledges the difficulty of developing a scientifically robust definition, the debate is shifting from processing methods to ingredients, risking a new battle over competing lists, criteria, and national rules.
Key Messages:
- A single, scientifically robust definition of ultra-processed foods (UPFs), one capable of supporting global regulation, may never exist.
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The debate is already shifting from food classification to individual ingredients, paving the way for different standards and national ingredient lists.
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The real public policy challenge is not how to define foods, but how to empower citizens to make informed food choices in a complex world.
What’s Happening?
Defining ultra-processed foods (UPFs) has almost become a trend.
New definitions are increasingly presented as the answer to the UPF debate: researchers refine classification systems; governments promise new regulations; organizations defend the criteria they consider most appropriate; and food companies propose alternative approaches.
Everyone seems convinced that the next definition will finally settle the debate. But perhaps the exact opposite is true.
No Definitive Definition
The race to define UPFs reveals a deeper reality: there may be no definition robust enough to support every policy built around it.
As Karl Popper reminded us, science does not produce definitive truths. It builds models that remain open to criticism, revision, and replacement as knowledge advances. Classifications are tools, not endpoints.
America Is Also Grappling with the Limits of the UPF Category
After months of work, the Food and Drug Administration (FDA) has acknowledged just how difficult it is to develop a definition of UPFs that is both scientifically robust and workable in practice.
This should come as no surprise: food processing is not a single, clear-cut characteristic. It is a continuum involving ingredients, technologies, formulations, purposes, and contexts of consumption.
Trying to compress this complexity into a single category risks creating an illusion of certainty rather than greater scientific clarity.
Beyond NOVA: The Ingredient Wars Begin
The debate is already moving beyond NOVA. Rather than regulating a single broad and heterogeneous category of foods, the latest initiatives in the United States are increasingly focusing on specific ingredients and additives.
Whether this approach is right or wrong is not the point. It simply confirms how difficult it is to regulate a category with such ambiguous boundaries.
But this raises another question: who decides which ingredients are acceptable? And based on what evidence, thresholds, and conditions of use?
Each country could adopt different rules, banning or discouraging ingredients that are permitted elsewhere. The risk is replacing one controversial classification with dozens of different, competing classifications.
A Category Cannot Explain How We Eat
Consumers do not decide what to eat based on the NOVA classification. They choose their meals based on taste, price, convenience, habits, culture, and the time available.
Health, too, does not depend on a single factor, but on the interaction between diet, physical activity, sleep, stress, metabolic variability, and many other factors. No label can capture all this complexity.
Fewer Shortcuts, More Tools for Informed Choices
Classifications are valuable tools for research. But they become less reliable when turned into regulatory shortcuts.
Public policy should spend less time searching for the perfect definition and focus more on food education, the quality of information, and empowering citizens to make informed choices.
Perhaps, then, the real question is not how to define ultra-processed foods.
The real question is whether defining them is truly the problem we should be trying to solve.