by Marion Nestle

Currently browsing posts about: Ultraprocessed

May 13 2025

A busy week at the FDA: Opportunity for action

The FDA is an agency within the Department of Health and Human Services, now headed by Robert F. Kennedy, Jr.  It is getting busy on carrying out Secretary Kennedy’s stated agenda.  It took four actions of interest last week.  Check out #3; it requires action.

I.  Approved Three Food Colors from Natural Sources

Since the HHS and FDA announcement last month during a press conference at HHS on petroleum-based food dyes, more U.S. food manufacturers have committed to removing them within the FDA’s set time frame of the end of next year.

“On April 22, I said the FDA would soon approve several new color additives and would accelerate our review of others. I’m pleased to report that promises made, have been promises kept,” said FDA Commissioner Martin A. Makary, M.D., M.P.H. “FDA staff have been moving quickly to expedite the publication of these decisions, underscoring our serious intent to transition away from petroleum-based dyes in the food supply and provide new colors from natural sources.”

FDA approved color additive petitions for:

  • Galdieria extract blue, a blue color derived from the unicellular red algae Galdieria sulphuraria (by petition from Fermentalg).
  • Butterfly pea flower extract, a blue color that can be used to achieve a range of shades including bright blues, intense purple, and natural greens (Sensient Colors LLC)
  • Calcium phosphate, a white color approved for use in ready-to-eat chicken products, white candy melts, doughnut sugar, and sugar for coated candies (Innophos Inc).

II.  Announced top priorities for the Human Foods Program

FoodNavigator-USA report that Mark Hartman, who directs the new Office of Food Chemical Safety, Dietary Supplements, and Innovation, says the FDA soon will:

  • Reveal how it will deal with the safety of chemicals in the food supply
  • Create a new Office of Post Market Review to conduct risk reviews of chemical additives
  • Increase transparency and stakeholder engagement in the review process
  • Work through 70,000 comments on the FDA’s proposal for reviewing the safety of chemical additives
  • Partner with the NIH to research how food additives affect children’s health
  • Work with the food industry to phase out synthetic color additives
  • Work through comments on sodium guidance
  • Think about ways of addressing added sugars
  • Identify ultra-processed foods as an “area of emerging study”

III.  Extended the comment period for front-of-package labeling until July 15

We are taking this action in response to requests to extend the comment period to allow interested parties additional time to submit comments. Comments should be submitted to Regulations.gov and identified with the docket number FDA-2024-N-2910.

Recall: This is what the Biden FDA proposed.  Here’s what I said about it (basically, we need something better).

The proposed FOP nutrition label, also referred to as the “Nutrition Info box,” provides information on saturated fat, sodium and added sugars content showing whether the food has “Low,” “Med” or “High” levels of these nutrients.

Here’s a real opportunity.  If you want a front-of-package warning label like those in Latin America, here’s your chance to weigh in.

RFK Jr says he wants to Make America Healthy Again.  One way to do that is to discourage sales of food products high in saturated fat, sodium, and added sugars, but also discourage sales of ultra-processed foods.  Identifying foods as ultra-processed, on the basis of their chemical additives as well as their fat, sugar, and salt, would be an excellent step forward.

If you like the warning labels used in Latin American countries, send a note to the FDA Docket.  You have until July 15 to do that.

IV.  Announced a joint research initiative with NIH to address, among other unspecified questions,

  • How and why can ultra-processed foods harm people’s health?
  • How might certain food additives affect metabolic health and possibly contribute to chronic disease?
  • What is the role of maternal and infant dietary exposures on health outcomes across the lifespan, including autoimmune diseases?

Comment

OK.  This represents action or proposed action.  My question: What will the FDA actually do?  I’m particularly interested in the joint NIH research initiative on ultra-processed foods.  Will NIH reverse its stance on Kevin Hall, whose research aimed to answer precisely that question?  I will be watching all this with much curiosity.

Mar 31 2025

Industry-influenced opinion of the week: Ultra-processed foods

If you have any doubts about the value of the concept of ultra-processed, the breadth and extent of industry pushback against the idea is excellent evidence.  The concept is an existential threat to the processed food industry, and it is fighting back.  The Italian food industry is especially concerned because it also has the Nutri-Score front-of-pack labeling system to contend with; the letter grades on ultra-processed products tend to be C’s, D’s, and E’s—as bad as they come.

Here’s an example of the pushback.

The opinion piece: Visioli, F., Del Rio, D., Fogliano, V., Marangoni F, Ricci C, Poli A.  Ultra-processed foods and health: are we correctly interpreting the available evidence?. Eur J Clin Nutr 79, 177–180 (2025). https://doi.org/10.1038/s41430-024-01515-8

Conclusions: In summary, the available evidence regarding how different UPF were associated with health and the results of studies investigating specific food additives question the possibility that ultra-processing per se is the real culprit. Possibly, other unaccounted-for confounding factors play major roles. Consequently, the recommendation of limiting or avoiding foods carrying an unspecific “ultra-processed food” label based on the NOVA classification currently has poor scientific grounds and should be regarded as scientifically weak and in need of experimental confirmation. Furthermore, prompt public policy interventions on this topic, as advocated by some authors are premature and should be thoroughly reconsidered before being released.

Competing interests: AP and FM are the Chairman and Scientific Director, respectively, of NFI—Nutrition Foundation of Italy, a non-profit organisation partially supported by Italian and non-Italian Food Companies. All other authors declare no conflict of interest associated with this publication.

Comment: The senior (last) author and one other run the Italian Nutrition Foundation, an organization sponsored by food companies, Italan and international.  This makes the Foundation an industry front group, pretending to be independent, but not.  Its job is to further the commercial interests of its corporate sponsors, which is what it is doing here.  It is using the tobacco industry playbook: cast doubt on the research, suggest alternatives, argue against regulation.  The foundation’s authors are joined by academic and government authors, who have their own, not necessarily commercial, reasons for unhappiness with the UPF concept, which focuses on degree of processing, not nutrient content.  Yes, nutrients matter, but there are better ways of getting them than through UPFs.

Jan 16 2025

The latest on ultra-processed foods

I’ve been interviewed a lot lately about ultraprocessed foods.  See, for example:

And Gary Ruskin of US Right to Know sent me this collection of fact sheets.

I’m hearing an awful lot of fuss about difficulties defining ultra-processed foods and how some conditionally ultra-processed foods (e.g., whole wheat bread and yogurt) are healthy.  Maybe so, but the overall concept makes a lot of sense to me, especially with research demonstrating that ultra-processed foods encourage greater calorie intake.  That alone is reason to minimize intake.

Jan 9 2025

A Thursday giggle: Politics makes strange bedfellows

How did a nice girl like me end up in New York Magazine’s MAHA issue?  I was amazed to find myself in this.

MAHA is the Trump Administration’s Make America Healthy Again campaign.

For the record: I’m totally for making America healthy, and especially for doing everything possible to reduce risks from chronic disease.  I’m for some of what RFK, Jr wants to do (reduce intake of ultra-processed foods, get toxins out of the food supply, reduce conflicts of interest) but by no means all.

Oh well, I didn’t want you to miss this. Enjoy (?).

Dec 18 2024

The first lawsuit against ultra-processed foods

The Dietary Guidelines Advisory Committee may not think there is much to ultra-processed foods (UPF), but companies making them have just been served with a lawuit.

I learned about this from a tweet (x) from Carlos Monteiro, the Brazilian public health professor who coined the UPF term.

CMonteiro_USP (@Carlos A. Monteiro) posted: A first-of-its-kind lawsuit against 11 UPF industries alleging they engineer their UPF products to be addictive with details on the actions taken to target children including internal memos, meetings & the research conducted to create addictive substances.

The lawsuit, filed by several law firms, is aimed at Big Food: Kraft, Mondelez, Post, Coca-Cola, PepsiCo, General Mills, Nestle, Kellanova, WK Kellogg, Mars, and Conagra.

The suit charges that these firms, through their deliberate marketing, are making people sick.

Due to Defendants’ conduct, Plaintiff regularly, frequently, and chronically ingested their UPF, which caused him to contract Type 2 Diabetes and Non-Alcoholic Fatty Liver Disease Plaintiff is now suffering from these devastating diseases, and will continue to suffer for the rest of his life.

The suit makes interesting reading.

Some examples:

  • Big Tobacco companies intentionally designed UPF to hack the physiological structures of our brains.  These formulation strategies were quickly adopted throughout the UPF industry, with the goal of driving consumption, and defendants’ profits, at all costs.
  • The same MRI machines used by scientific researchers to study potential cures for addiction are used by UPF companies to engineer their products to be ever more addictive.
  • Big Tobacco repurposed marketing strategies designed to sell cigarettes to children and minorities, and aggressively marketed UPF to these groups.
  • The UPF industry now spends about $2 billion each year marketing UPF to children.
  • UPF increase the risks of disease because they are ultra-processed, not because of how many grams of certain nutrients they contain or how much weight gain they cause. Therefore, even attempts to eat healthfully are undermined by the ultra-processed nature of UPF. One cannot evade the risks caused by UPF simply by selecting UPF with lower calories, fat, salt, sugar, carbohydrates, or other nutrients.
  • The UPF industry is well aware of the harms they are causing and has known it for decades. But they continue to inflict massive harm on society in a reckless pursuit of profits.

Can’t wait to see what happens with this one.  Stay tuned.

Resources

Consumer Federation of America: “Ultra-processed Foods: Why They Matter and What to Do About It.”

With government officials reluctant to issue advice on ultra-processed foods (UPFs), Consumer Federation of America aims to raise awareness about research on UPFs, explain the leading theories of how they harm health, and build support for public policies to reduce harms from UPFs in our diet.

The report pushes back on arguments that researchers have not consistently defined UPFs, or that the categorization lacks scientific rigor. In fact, researchers have operationalized the “Nova classification” system behind UPFs in a largely consistent manner, defining foods based on whether they contain ingredients that are “industrial formulations” or “rarely used in home kitchens,” with little serious disagreement about which ingredients should be considered “ultra processed.” Consumers can take CFA’s online quiz to test their knowledge of which ingredients are markers of “ultra processing.”

New research: Trends in Adults’ Intake of Un-processed/Minimally Processed, and Ultra-processed foods at Home and Away from Home in the United States from 2003–2018.  J Nutr 2024, https://doi.org/10.1016/j.tjnut.2024.10.048.  The data show that 50% or more of calories are consumed from UPF at home, away from home, and by pretty much everyone.

New research: Hagerman CJ, Hong AE, Jennings E, Butryn ML. A Pilot Study of a Novel Dietary Intervention Targeting Ultra-Processed Food Intake. Obes Sci Pract. 2024 Dec 8;10(6):e70029. doi: 10.1002/osp4.70029.  Behavioral interventions to reduce UPF intake cut calories by about 600 calories per day.

My post summarizing the three studies demonstrating that diets high in UPF induce intake of an excess of 500, 800, and 1000 calories per day.

Dec 3 2024

Ultra-processed foods and calories: more evidence!

Two previous short-term studies demonstrated that if you eat a diet based largely on ultra-processed foods, you are likely to consume far more calories than you would eating less processed diets–and not notice that you are overeating.

The big question: why.

Study #1:  Hall K, et al.  Ultra-Processed Diets Cause Excess Calorie Intake and Weight Gain: An Inpatient Randomized Controlled Trial of Ad Libitum Food Intake .  Cell Metabolism 2019; 30:67–77.

When study subjects ate the ultra-processed diet, they consumed 500 calories a day more than when they were eating the unprocessed diet.  This is a staggering difference.  They seemed to eat the ultra-processed diet faster.

Study #2: Hamano S, Sawada M, Aihara M, Sakurai Y, Sekine R, Usami S, Kubota N, Yamauchi T. Ultra-processed foods cause weight gain and increased energy intake associated with reduced chewing frequency: A randomized, open-label, crossover study. Diabetes Obes Metab. 2024 Nov;26(11):5431-5443. doi: 10.1111/dom.15922.

These investigators reported a difference of 813 calories.  They attributed it to less chewing.

Study #3 (as yet unpublished): Its results appeared as a Tweet (X) from Dr. Hall describing a presentation he gave at a meeting in London (Apparently, X is where science gets discussed these days).  The recording of the entire meeting is now available.  Dr Hall’s presentation begins at minute 38.

The latest result: a difference of 1000 calories a day!

Dr. Hall was kind enough to send me the slides from his presentation.

My translation:

  • Blue bar: Minimally processed diet, low in energy density (calories per gram) and low in irresistably delicious (hyper-palatable) foods.
  • Red bar: Ultra-processed diet high in energy density and high in hyper-palatable foods.

The big result: Difference between blue (unprocessed) and red (ultra-processed): 1000 calories a day.

  • Purple bar: Ultra-processed high in energy density, low in hyper-palatable.
  • Green bar: Ultra-processed low in energy density, low in hyper-palatable.

Difference between purple (high, low) and red: 200 calories a day.

Difference between green (low, low) and red: 630 calories a day.

Participants reported no differences in appetite or pleasantness of the meals on the various diets.  There also were no observable differences in eating rate.

Obviously, participants who ate more calories gained more weight.

Comment

My summary: We love and cannot stop eating yummy high-calorie foods.

All of this reminds me of the work of Barbara Rolls, who for years has argued for diets low in energy density, and whose low-energy-dense Volumetrics diet is consistently ranked at the top of diet plans.

It’s great to see all this research coming together.  Whatever the reasons—energy density, hyper-palatability, less chewing—the take-home-message seems utterly obvious: reduce intake of ultra-processed foods.

As Jerry Mande summarized the significance of this study, also in a Tweet (X) :

BREAKING..@KevinH_PhD  presents preliminary data from long awaited (6yrs!) follow-up study. Confirm initial findings. Energy dense, hyper-palatable UPF foods result in 1000 kcal/day greater intake than minimally processed food. Time to regulate UPF #MAHA

Indeed, yes.

Nov 22 2024

Weekend reading: Real Food, Real Facts

Charlotte Bilekoff.  Real Food, Real Facts: Processed Food and the Politics of Knowledge.  University of California Press, 2024.  267 pages.

Food processing is a big issue these days (witness RFK Jr’s pledge to get ultra-processed foods out of school meals) and I was interested to see what food studies scholar Charlotte Biltekoff had to say about it.

Her thesis: When people say they want to eat “real food” rather than highly processed food, the food industry responds with “real facts,” science-based discussions of the benefits of food processing (“food scientism”).

The industry’s response is based on the idea that if you could only correct public ignorance and misperceptions, you could sell your products more easily.

But public concerns are about politics, not science.  And food scientism is a form of antipolitics.

She cites as an example, the FDA’s ongoing inability to define the term “natural.”

Concerned about health, sustainability, and risk and wanting change in the food system, the public sought to act on its values and aspirations in the marketplace.  Narrowly reframing those concerns as demands that could be met through product reformulations and new approaches to marketing—but without serious, systemic engagement with the broader issues they reflected—the food industry produced products that appeared to be more natural, less processed, and therefore better…articles in the industry press and comments to the FDA show that many perceived the consumers of “real food” as irrational and misinformed.  Seen through the lens of food scientism of the Real Facts frame, consumer perceptions of processing and what “natural” meant, or should mean, were further proof that the public lacked the skills and understanding to meaningfully participate in the regulatory processess, let alone act as knowledgeable participants in the governance of technology and the shaping of the food system. (p. 143)

What Biltekoff has done here is to translate the classic two-culture risk communication problem to food.

Her book made me go back and look at what I wrote about the two-culture problem in Safe Food: The Politics of Food Safety.  The book contrasts the differing perceptions of industry and the public about the potential harm of microbial foodborne illness versus GMOs.

These differences in approaching questions of risk were understood long before anyone invented the techniques for genetically modifying foods. In 1959, for example, the scientist and writer C. P. Snow characterized the ways in which people trained in science tend to think about the world—as opposed to those without such training—as representing two distinct cultures separated from one another by a “gulf of mutual incomprehension” [1]. Much more recently, the anthropologist Clifford Geertz wrote, “The ways in which we try to understand and deal with the physical world and those in which we try to understand and deal with the social one are not altogether the same. The methods of research, the aims of inquiry, and the standards of judgment all differ, and nothing but confusion, scorn, and accusation—relativism! Platonism! reductionism! verbalism!—results from failing to see this” [2].  [1. Snow CP. Two Cultures and the Scientific Revolution: The Rede Lecture. London: Cambridge University Press, 1959; 2. Geertz C. Empowering Aristotle (book review). Science 2001;293:53].

Science-based approaches to food safety, I pointed out, count cases and estimate costs, whereas what I called “value-based” approaches, are about feelings of dread and outrage.

Biltekoff’s analysis applies the two-culture framework to public responses to food processing and to the ways the food industry deals with those responses.

Her analysis explains much about the current pushback against the concept of ultra-processed foods from the food industry and some nutritionists.  If you want to understand why the Dietary Guidelines Advisory Committee has chosen not to recommend reducing intake of ulra-processed foods, read this book.

And, amazingly, the book is available as open source.  Read the book online here.

Read Charlotte Biltekoff’s interview with UC Press here.

Nov 15 2024

Weekend reading: food addiction

Ashley N. Gearhardt, Kelly D. Brownell, Mark S. Gold, and Marc N. Potenza, editors.  Food & Addiction: A Comprehensive Handbook, Second Edition.  Oxford University Press, 2024.  570 pages.

This is the second edition of a book I wrote about in 2012.

At the time, I said:

Brownell and Gold have produced an instant classic.  Food and Addiction presents a comprehensive, authoritative, and compelling case for considering whether food is addictive.  Its chapters raise serious questions about our current laissez-faire attitude toward food marketing, especially to children.  This book is a must read for everyone who cares about the causes and consequences of obesity and the need for food policies that better promote health.  It is a game changer.  Readers will never look at food the same way again.

Much has happened since then to focus greater attention on the ways food triggers addictive-like eating behavior.

All of this makes an increasingly convincing case that the word “addiction” applies to food as well as to other addictive substances, and that similar proportions of people (10% to 15%) meet criteria for addiction; everyone eats, but not everyone meets those criteria.

The editors’ introductory and concluding chapters lay out the diagnostic and policy issues.

The short chapters address biological, behavioral, clinical, and legal correlates of food addiction.

They are written by a authors who address these issues from enormously different , but highly critical, perspectives ranging from the exceedingly personal to the big-picture political.

Is anything missing here?  As with any multi-authored book, this one undoubtedly took years to produce.  That makes it a few years out of date in fast-moving areas.  It does not cover recent research on ultra-processed foods, Kevin Hall’s experiment, the concept of food “noise,” or the way the new GLP-1 drugs might interact with addictive behavior.

But, this is the resource of food addiction, a great gift to the addiction-perplexed and an enormous public service at a time when it is badly needed.