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The Endless Race to Define UPFs – PNR316
The race to define ultra-processed foods (UPFs) is exposing the weakness of the category itself. As the FDA acknowledges the difficulty of producing a scientifically robust definition, policymakers are shifting from process to ingredients – risking a new war of competing lists, criteria, and national rules.

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WHAT IS HAPPENING?   Defining ultra-processed foods (UPFs) has become fashionable.

Increasingly, new definitions are presented as the solution to the UPF debate.
  • Researchers refine classifications. Governments promise new regulations. Advocacy groups defend their preferred criteria. Food companies respond with alternative frameworks.

Everyone seems convinced that the next definition will finally settle the debate. Perhaps the opposite is true.

NO DEFINITION   The race to define UPFs reveals a deeper reality: there may never be a definition robust enough to support all the policies being built upon it.
  • As Karl Popper reminded us, science does not produce final truths. It builds models that remain open to criticism, revision, and replacement as knowledge advances.
  • Definitions are tools, not destinations.

READ IT AGAIN: UPFS NEED AN ALGORITHM

US SKEPTICISM   The recent statement by the U.S. Food and Drug Administration (FDA) illustrates this perfectly. After months of work, the agency acknowledged how difficult it is to develop a scientifically sound and operational definition of UPFs.
That should not surprise anyone.

  • Food processing is not a single characteristic. It is a continuum involving ingredients, technologies, formulations, purposes and contexts. Trying to compress that complexity into a single category risks creating the illusion of certainty rather than scientific clarity.
GOODBYE NOVA?   Interestingly, the debate is already moving beyond NOVA.
  • Rather than regulating one broad and heterogeneous category of foods, recent initiatives in the United States increasingly focus 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 an ambiguous category.

But this opens another question.

A WAR OF INGREDIENTS   If the debate shifts from foods to ingredients, who decides which ingredients are acceptable? According to which evidence? Will every country develop its own list?
The risk is replacing one uncertain classification with dozens of competing ones.

ARE WE ASKING THE WRONG QUESTION?   Consumers do not choose foods because they belong to the NOVA classification.

  • They choose meals based on taste, affordability, convenience, habits, culture, family routines and available time.
  • Health emerges from the interaction of dietary patterns, movement, sleep, stress, metabolic variability and many other factors.
A single label cannot capture that complexity.
Classifications are valuable research tools. They become far less reliable when transformed into regulatory shortcuts.

Perhaps public policy should spend less time searching for the perfect definition and more time helping citizens understand food, evaluate evidence and make informed choices.

  • Maybe the real question is not how to define ultra-processed foods.
  • The real question is whether defining them is the problem we should be trying to solve.

The Endless Race to Define UPFs – PNR316

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