FDA Considers Action on Ultra-Processed Foods Despite Definition Disputes

The Origins and Limitations of the Nova Classification

The term “ultra-processed food” stems from the Nova grading system, a framework introduced by researchers in Brazil in a 2009 paper. The system was designed to categorize food based on its level of processing, distinguishing between what is considered “food” and “ultra-processed food products.” Critics argue that the Nova scale possesses fundamental limitations. The system creates a dichotomy, labeling foods as either ultra-processed or not, which effectively categorizes items into a binary of good versus bad. Some versions of the scale attempt to bridge this gap by including a “processed” category between minimally processed and ultra-processed, yet the classification remains broad. Furthermore, the Nova scale does not objectively measure industrial processing. It does not account for the number of industrial steps required to produce a food item. Instead, the classification is based on what researchers perceive a UPF should look like. In practice, researchers often group foods based on personal opinion, leading to inconsistencies. For example, while simple homemade corn chips might be considered minimally processed, commercial versions are generally labeled as UPFs regardless of the actual processing methods used.

Defining the “Ultra” Label

The ambiguity of the term “ultra” has led to calls from some to remove it entirely, as it is viewed by critics as an emotional, meme-like descriptor rather than a scientific one. In the original 2009 research, the definition suggested that any food requiring cooking—including bread or cured sausages—could be classified as ultra-processed. Professor Carlos Augusto Monteiro, the researcher behind the Nova system, clarified in a 2017 paper that food processing itself is not the primary issue, as all foods undergo some form of processing. Instead, he argued that the problem lies in products being “separated from nature,” describing UPFs as items that are branded, convenient, highly profitable, and marketed intensively. Critics point out that these criteria are subjective and vague, complicating the development of clear regulatory standards.

Reviewing the Scientific Evidence

The scientific foundation for the health risks associated with UPFs is also a subject of intense scrutiny. Much of the public concern is driven by observational studies that rely on self-reported food intake. These papers show associations between diet and health outcomes, but they are generally limited in their ability to prove causation. More rigorous randomized trials, where participants are assigned specific diets, have shown few negative impacts. While some studies suggest that a diet consisting entirely of UPFs might lead to minor weight gain, these findings remain uncertain. A recent report in the journal *Science* suggested that even the modest negative effects observed in these trials may not be caused by processing at all. Instead, researchers noted that UPF diets used in studies often have higher energy density—meaning more calories per bite—which is a known factor in weight gain.

Summary of Challenges in UPF Regulation

| Challenge | Impact on Policy | | :— | :— | | Lack of Definition | No standardized, objective metric for “ultra-processed.” | | Subjectivity | Classification often relies on researcher opinion rather than industrial process measurement. | | Weak Causation | Observational studies struggle to isolate processing from other dietary factors. | | Confounding Variables | Potential negative health outcomes may be tied to energy density rather than processing. | As the FDA weighs its next steps, the scientific community remains divided over whether the current classification system provides a sound basis for public health action, or if it conflates the nature of food processing with other nutritional concerns.

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