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Can Public Policy Regulate What Science Has Not Yet Defined?

The debate over ultra-processed foods reveals a growing gap between scientific uncertainty and political certainty. My recent statement on Rome’s decision to exclude ultra-processed foods (UPFs) from school meals was widely covered by Italian news agencies and media. The reason is simple: before banning a category of foods, policymakers should first be able to define it. The controversy goes far beyond school meals. It raises a broader question about how science, regulation and public health should interact.

Key Takeaways

  • Public policy should not regulate categories that science has not yet clearly defined.
  • Ultra-processed foods (UPFs) remain the subject of scientific and regulatory debate worldwide.
  • Even the U.S. FDA is still working toward an operational definition of UPFs.
  • Processing is a characteristic of food production, not a direct measure of healthfulness.
  • The future of nutrition policy lies in precision nutrition and personalised prevention, not simplistic food classifications.

Can Public Policy Move Faster Than Science?

Rome’s decision to exclude “ultra-processed foods” from school meals may appear straightforward. In reality, it highlights one of the biggest weaknesses in today’s nutrition debate.

Everyone seems ready to regulate ultra-processed foods.Far fewer can explain precisely what they are. This is not a semantic issue. It is a scientific one.

Different research groups use different classification systems. NOVA is the most widely known, but it is not the only one. Other frameworks classify foods differently, and researchers continue to debate where many products belong. That uncertainty is precisely why regulatory authorities, including the U.S. Food and Drug Administration, are still working toward a practical and consistent definition.

Yet political decisions are increasingly treating UPFs as though they were already a clearly established scientific category.

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This reverses the normal relationship between science and policy.

Science should reduce uncertainty before regulation transforms uncertainty into law.

The objective should never be to defend processed foods or to oppose healthier school meals. Better nutrition for children is an objective everyone shares.

The question is different. Can a public authority build procurement rules around a concept that remains scientifically contested?

The answer matters because food is more complex than a label.

Processing alone does not determine whether a food contributes positively or negatively to health. Nutritional composition, food matrix, portion size, frequency of consumption, overall dietary pattern, lifestyle and individual metabolic responses all influence health outcomes.

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Reducing this complexity to a binary category, processed versus ultra-processed, may simplify political communication, but it does not necessarily improve scientific accuracy.

Our brains naturally prefer simple categories. They reduce cognitive effort and make complex decisions feel easier.

Public policy should resist that temptation.

Nutrition is moving toward a different future.

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Artificial intelligence, wearable devices, continuous health monitoring, and precision nutrition will increasingly allow recommendations to be tailored to individuals rather than imposed on entire populations.

The question is no longer simply “What food is this?”

It is becoming “For whom, in what quantity, how often, and under which circumstances?”

That represents a profound shift.

The future of public health is unlikely to be built around universal labels.

It will be built around personalised knowledge.

Final Thought

The UPF debate is no longer just about food.

It has become a test of how modern societies make decisions under scientific uncertainty.

Good science accepts uncertainty while searching for better evidence.

Good policy should do the same.

Otherwise, we risk replacing evidence with certainty long before certainty actually exists.

Can Public Policy Regulate What Science Has Not Yet Defined?

Author

PNR