by Marion Nestle

Currently browsing posts about: Ultraprocessed

Apr 16 2026

Coming soon to a supermarket near you: Non ultra-processed!

With all the fuss over defining the term ultra-processed, public and private groups are filling the gap with labels that identify foods that are not ultra-processed.

I know of three ultra-processed labeling initiatives so far.

I.  Leading the way is the Non GMO Project. It already is licensing foods meeting its non ultra-processed standards to carry this seal.

II.  California is considering a front-of-package label to indicate foods that are not ultra-processed; it expects only about one-third of processed supermarket foods to meet its criteria.

 

III.  And in Europe, Nutri-Score (as I written about previously) is considering adding something about ultra-processing to its current labels.  Even food products meeting its A criteria can be ultra-processed.

Comment: While fusses about the definition of ultra-processed continue, labels like these ought to help people recognize and cut down on such foods.  As for me, I’m not too worried about the definition.  As one of my colleagues put it, as with pornography. everyone recognizes an ultra-processed food when they see one.

Addition

Thanks to Jim Krieger for sending two more.

 

 

 

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Mar 25 2026

USDA school food rules allow plenty of ultra-processed snacks

A reader, Jennifer Windh, has done some serious investigation of loopholes in USDA’s school food rules that allow lots of ultra-processed snacks to be sold a la carte (“competitive foods”) outside of the USDA’s school meals program.

USDA’s nutrition tandards also apply to competitive foods: Smart Snacks in Schools.

The final rule for these standards, effective as of 2016, sets requirements or limits for whole grains, saturated and trans fat, sugar, sodium, and calories.

This sounds good, but as Jennifer Windh found out, even though snacks are required to be either 50% whole grain or have as a first ingredient fruit, vegetable, dairy product, or protein, the rules allow for plenty of loopholes.

She summarizes the findings of her investigation in The Smart Snacks Loophole: How Junk Food Companies Target America’s Students in School.

One reason for the loophole is the generous sugar standard: “Acceptable food items must have ≤35% of weight from total sugar as served.”

She points out the irony of Robert F. Kennedy, Jr’s visit to an elementary school where cooks make healthy meals from scratch (parents protested his visit because of his stance on vaccination, not food).

This school, she notes, offers plenty of loophole snacks.

She is particularly concerned about the loophole for ice cream.  For this, she has analyzed sales in 12 Houston area school districts: Ice Cream at School.

Schools usually sell ice cream at the same time they serve the main meal. There is no adult present who encourages students to eat their lunch before eating dessert. As expected, most children eat their ice cream first! This spoils their appetite for the more nutritious foods on their tray. School lunch periods are short, children eat slowly, and there are many distractions as students socialize with their friends. As a result, some students eat their ice cream first and then throw the rest of their lunch away.

There is so much money to be made from school meals that sellers of ultra-processed foods are happy to reformulate their products to meet USDA nutrition standards and get their products in through the loopholes.

Obviously, the standards could use some tightening.

The big question: Will USDA tighten the loopholes when it issues new school food standards to reflect the new dietary guidelines?  Recall:  These emphasize eat real food and reduce intake of highly processed foods.

Stay tuned.

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Mar 13 2026

Weekend reading: the debate about ultra-processed foods

In a previous post, I wrote about the series of papers on ultra-processed foods published in The Lancet (I am a co-author on papers II and III)

As might be expected, the papers generated a fair amount of discussion and debate.  The Lancet has now published five letters raising issues about the series, along with a letter of response (which I signed).

Here are the letters:

I.  Ultra-processed foods in research and policy.  David Ludwig argues that the Nova classification of food procesing is imprecise and ideological.

II.  Ultra-processed foods in research and policy:  Dirk Jacobs and Rafael Sampson say the papers look like a campaigning platform to shut down criticism and reject expertise out of hand.

III.  Ultra-processed foods in research and policy:  Gunter Kuhnle says the papers give “insufficient attention to the central methodological challenge of this field: the assessment of UPF intake itself,” a concern because “most of the evidence against UPF relies on observational data.”

IV.  Ultra-processed foods in research and policy: Tatiana Campos and Aintzane Esturo, representing the International Fruit and Vegetable Juice Association, disagree with the classification of reconstituted fruit juices as ultra-processed; they say the juices should be classified as unprocessed or minimall processed (Nova 1, not Nova 4).

V.  Ultra-processed foods in research and policy:  Lilian dos Santos Raha,  Patrícia Chaves Gentil, Gisele Ane Bortolini, Felipe Silva Neves, and Bruna Pitasi Arguelhes point to actions in Brazil that offer “a blueprint for translating these recommendations into binding regulation.”

And here is Ultra-processed foods in research and policy – Authors’ reply   (full text)  Note: I am a co-author.

We thank the authors for their comments and interest in our Series on ultra-processed foods (UPFs) and human health.
We acknowledge David S Ludwig’s concern about the limits of any single classification system. The Nova framework does not replace nutrient science, but adds a complementary layer focused on food processing as a determinant of dietary patterns. Foods, nutrients, additives, and food matrices all matter, and the second Series paper explicitly proposed that all regulations should combine criteria on crucial nutrients with markers of food ultra-processing, rather than treating processing as a stand‑alone metric. Importantly, nationally representative surveys from multiple countries show that the dietary contribution of ultra-processed foods (UPFs) is the main driver of nutrient-imbalanced diets. For example, in the USA, 92·4% of diets excessive in added sugar, saturated fat, energy density, and insufficient in fibre are attributed to UPF consumption. UPFs, therefore, function not as an ideology but as structural drivers of dietary nutrient imbalance, as well as of other determinants of ill health including overeating, exposure to harmful additives and contaminants, snacking, and other harmful eating patterns. Nova explains dietary patterns in ways that nutrient-centric models alone cannot. Critiques based on isolated UPF products overlook the logic of dietary displacement and the relevant counterfactual: fresh and minimally processed foods and cooked meals. We have recently explained why UPF subgroup analyses suggesting differential health effects are conceptually and methodologically flawed, undermining the credibility of nutrition science and risking policy misinterpretation.
Rafael Sampson and Dirk Jacobs of FoodDrinkEurope characterise the UPF industry and industry-funded scientists as impartial brokers of evidence and argue that proposals to limit corporate influence go too far. FoodDrinkEurope’s membership includes many of the world’s largest UPF manufacturers and lobby groups, and the organisation is within a broader network of corporate interest groups that have actively promoted misinformation about Nova and the evidence on UPFs. Based on decades of evidence from food, tobacco, alcohol, and fossil fuel research, we question the credibility of industry-funded science when commercial imperatives conflict with public health goals. Transparency alone is insufficient. The empirical literature shows that disclosure does not neutralise bias, nor prevent the strategic use of funding to manufacture doubt, delay regulation, and frame debate in industry-favourable terms. Safeguards against conflicts of interest are pro-science, not anti-science. Editors exclude conflicted reviewers, governments restrict lobbying, and ethics committees limit funding sources for precisely these reasons. Food and nutrition research should be no exception.
We agree with Gunter G C Kuhnle that evidence on the harms of UPFs was generated using dietary instruments not designed to capture Nova groups. However, exposure misclassification is likely non‑differential in regard to outcomes, and therefore bias associations towards the null. As dietary tools for assessing food consumption aligned with Nova are adopted, associations strengthen rather than weaken. Misclassification has a greater effect on UPF subgroup analyses than on UPF-pattern analyses. Aggregating all UPFs partly mitigates food‑level measurement error, whereas attempting to distinguish fine subgroups with imperfect instruments amplifies instability, multiple testing, and false positives.
Tatiana Campos and Aintzane Esturo argue that reconstituted fruit juices should be treated as minimally processed. These products differ in matrix integrity, intrinsic fibre, and typical consumption patterns. Concentration, storage, reconstitution, and flavour restoration involves losses and reformulation that place these products beyond minimal processing. Some UPFs might perform better than others in specific comparisons, and relative harms might be modest in narrow contrasts. Policy, however, cannot be built on marginal cases. The relevant issue is displacement at scale: when reconstituted juices replace fresh fruit or freshly prepared juices, dietary quality deteriorates.
Gisele Ane Bortolini and colleagues illustrate how Nova can be operationalised in real-world policy. Brazil’s National Food Basket shows that processing criteria can coexist with nutrient standards, procurement rules, fiscal instruments, and broader food‑system policies. This directly addresses Ludwig’s concern that Nova is too imprecise for regulation. In practice, it has enabled coherent, multisectoral action adapted to national context rather than a universal, one‑size‑fits‑all template.
The global shift towards ultra-processed dietary patterns is a preventable driver of chronic disease, and effective policy action should prioritise protecting and restoring diets based on fresh and minimally processed foods and cooked meals. We continue to welcome any scientific inquiry related to the Series that might contribute to strengthening food policies for all.

Competing Interests

The Lancet Series on ultra-processed foods and human health was supported by funding from Bloomberg Philanthropies through a contract with Deakin University and subcontracts between Deakin and the University of Melbourne, University of Sydney, and University of São Paulo. The funder had no role in the study design, data collection, data analysis, data interpreta-tion, or writing of the Series. CAM was part of the team that developed the NOVA food classification system. BMP declares funding from the Eunice Kennedy Shriver National Institute of Child Health and Human Development, the National Institute on Aging, and Bloomberg Philanthropies, and has consulted for Resolve to Save Lives and the World Bank. PB reports funding from an Australian Research Council Future Fellowship awarded by the Australian Government, and from a Sydney Horizon Fellowship awarded by the University of Sydney. All other authors declare no competing interests.  [Note: I was advised not to include mine, since I do not accept funding from food and beverage companies with interests in this topic.  I do, however, earn honoraria for lectures and royalties from books about the politics of food].
References
1. Scrinis, G ∙ Popkin, BM ∙ Corvalan, C ∙ et al. Policies to halt and reverse the rise in ultra-processed food production, marketing, and consumption. Lancet. 2025; 406:2685-2702
2. Martinez Steele, E ∙ Marrón Ponce, JA ∙ Cediel, G ∙ et al. Potential reductions in ultra-processed food consumption substantially improve population cardiometabolic-related dietary nutrient profiles in eight countries. Nutr Metab Cardiovasc Dis. 2022; 32:2739-2750
3. Rezende, LFM ∙ Martinez-Steele, E ∙ da Costa Louzada, ML ∙ et al. Misleading narrative of healthy ultraprocessed foods. BMJ. 2026; 392, e087538
4. Baker, P ∙ Slater, S ∙ White, M ∙ et al. Towards unified global action on ultra-processed foods: understanding commercial determinants, countering corporate power, and mobilising a public health response Lancet. 2025; 406:2703-2726
5. Nestle, M. Unsavory truth: how food companies skew the science of what we eat. Basic Books, 2018
6. Willett, WC. Nutritional epidemiology. Oxford University Press, 2012
7. Werneck, AO ∙ Steele, EM ∙ Delpino, FM ∙ et al. Adherence to the ultra-processed dietary pattern and risk of depressive outcomes: findings from the NutriNet Brasil cohort study and an updated systematic review and meta-analysis. Clin Nutr. 2024; 43:1190-1199
8. Monteiro, CA ∙ Louzada, ML ∙ Steele-Martinez, E ∙ et al. Ultra-processed foods and human health: the main thesis and the evidence
Lancet. 2025; 406:2667-2668
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Feb 24 2026

60 Minutes: RFK Jr on non-regulation of ultra-processed food

On February 15, CBS News’ Bill Whitaker interviewed RFK Jr, former FDA Commissioner David Kessler, and journalist Michael Pollan about ultra-processed foods and what to do about them.
As far as I am concerned, this is the money quote:
This is classic RFK Jr: put everything on personal responsibility, never mind how hard it is for people to resist eating unhealthfully in today’s food environment.
As I explained last August, David Kessler gave RFK Jr a gift.  He sent him a letter presenting a  Citizen’s Petition arguing that if the FDA wanted to help people reduce consumption of ultra-processed foods, all it had to do was to define ultra-processed foods as Not GRAS.
The FDA is required to respond to citizens’ petitions within 180 days.
During the 60 Minutes program, RFK Jr said:
We will act on– on David Kessler’s petition. And the questions that he’s asking are questions that FDA should’ve been asking a long, long time ago.
“Act on?”  What does this mean?
Will the FDA act to regulate ultra-processed foods?
I will believe it when I see it.

Food Industry Comments (thanks to the invaluable Hagstrom Report)

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Dec 10 2025

San Francisco’s lawsuit against food companies

San Francisco’s city attorney has sued major food companies for marketing ultra-processed foods (UPF) that make people sick.

The lawsuit: COMPLAINT FOR: VIOLATION OF CALIFORNIA UNFAIR COMPETITION LAW AND PUBLIC NUISANCE

The arguments

I. UPF are dangerous: “No reason exists to believe that humans can fully adapt to these products.”

II.  UPF-like tobacco and illegal drugs–are addictive.

  • UPF cause compulsive use in the same ways as other addictive substances
  • UPF are psychoactive substances
  • UPF are reinforcing

III. Defendants designed UPF to be addictive to drive sales and profits.

IV. Defendants have created a public health crisis, especially for children.

V.  Defendants have deliberately targeted kids (harmful dyes, aggressive marketing, disproportionate targeting).

VI.  Defendants actively conceal the dangers of UPF.

VII.  UPF have contributed to a public health crisis in San Francisco.

This one will be fun to watch,

Resources

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Nov 19 2025

Out today: The Lancet series on ultra-processed foods

Today, the Lancet publishes three major papers on ultra-processed foods and human health: science, policy, and politics (I am a co-author on the policy and politics papers).  Here’s Peter Bond’s photo, the logo for the series.

THE PAPERS

I.  SCIENCE

Ultra-processed foods and human health: the main thesis and the evidence. Carlos A Monteiro, Maria LC Louzada, Euridice Steele-Martinez, Geoffrey Cannon, Giovanna C Andrade, Phillip Baker, Maira Bes-Rastrollo, Marialaura Bonaccio, Ashley N Gearhardt, Neha Khandpur, Marit Kolby, Renata B Levy, Priscila P Machado, Jean-Claude Moubarac, Leandro F M Rezende, Juan A Rivera, Gyorgy Scrinis, Bernard Srour, Boyd Swinburn, Mathilde Touvier.

This first paper defines ultra-processed foods and diets as including three specific elements:

  • Industrially produced
  • Made from cheap ingredients extracted from whole foods, combined with additives
  • Designed to maximize industry profits

It presents the evidence in support of three hypotheses about ultra-processed dietary patterns.  These:

  • Globally displace traditional diets based on whole foods.
  • Reduce dietary quality.
  • Are a key driver of the escalating global burden of diet-related chronic diseases.

II.  POLICY

Policies to halt and reverse the rise in ultra-processed food production, marketing, and consumption. [Full text here] Gyorgy Scrinis, Barry M Popkin, Camila Corvalan, Ana Clara Duran, Marion Nestle, Mark Lawrence, Phillip Baker, Carlos A Monteiro, Christopher Millet, Jean-Claude Moubarac, Patricia Jaime, Neha Khandpur.

This paper presents evidence in support of policies to:

  • Reduce intake of ultra-processed foods as well as those high in sugar, salt, and fats.
  • Restrict the marketing, availability, and affordability of ultra-processed foods (examples: taxes, warning labels, advertising bans, limits on use in schools, etc).
  • Restrict the marketing and political power of transnational food corporations (manufacturers, retailers, fast food chains, agricultural producers).
  • Support the production, availability, and affordability of minimally processed foods.

III.  POLITICS

Towards unified global action on ultra-processed foods: understanding commercial determinants, countering corporate power, and mobilising a public health response.  [Full text here] Phillip Baker, Scott Slater, Mariel White, Benjamin Wood, Alejandra Contreras, Camila Corvalán, Arun Gupta, Karen Hofman, Petronell Kruger, Amos Laar, Mark Lawrence, Mikateko Mafuyeka, Melissa Mialon, Carlos A Monteiro, Silver Nanema, Sirinya Phulkerd, Barry M Popkin, Paulo Serodio, Katherine Shats, Christoffer Van Tulleken, Marion Nestle, Simón Barquera.

This paper describes how the food industry is the main barrier to reducing intake of ultra-processed foods.

Food companies exert political power through corporate political activities, coordinated through a global network of front groups, multi-stakeholder initiatives, and research partners.  They:

  • Engage in direct lobbying,, infiltrate government agencies, and litigate
  • Promote corporate-friendly governance models, forms of regulation, and civil societies
  • Frame debate, generate favorable research evidence, and manufacture scientific doubt

To counter such corporate practices, actions are needed to

  • Disrupt the ultraprocessed business model
  • Redistributing resources to other types of food producers
  • Protect food governance from corporate interference
  • Implement robust conflict of interest safeguards in policy making, research, and professional practice.

This paper also addresses and responds to criticisms of the ultra-processed concept.

KEY MESSAGE: Reducing production and consumption of ultra-processed foods is a priority global health issue.

Thereore, ultra-processed foods require a global response to:

  • Confront corporate power,
  • Reclaim public policy space
  • Restructure food systems to prioritize health, equity, and sustainability over corporate profit.

No excuses.  Get to work!

RESOURCES

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Oct 16 2025

New terms in nutritional vocabulary: dark matter and foodomics

I wondered what this headline from FoodNavigator-Europe meant:

Nutritional dark matter: The next frontier in food science: The discovery of ‘nutritional dark matter’ is unlocking new paths for smarter food innovation, targeted health benefits, and precision nutrition… Read more

I went right to it:

What is Nutritional Dark Matter? A summary of key insights

  • Nutritional databases track only 150 of 26,000+ food compounds
  • Most food chemicals remain unstudied but may impact human health
  • Poor nutrition causes one in five adult deaths worldwide
  • Foodomics links diet to genes, microbes, and disease mechanisms
  • Industry must adapt to new science shaping future food innovation

As for foodomics, this term “brings together genomics (the role of genes), proteomics (proteins), metabolomics (cell activity) ad nutrigenomics (the interaction of genes and diet.”

Translation

  • “Dark matter” refers to the chemicals in food that have not (yet?) been identified as essential to the human diet but might have physiological functions.
  • “Foodomics” explains how all that might work.

Bottom line: While waiting for the scientists to investigate “dark matter,” the implications of the concept for dietary advice are obvious: Eat whole foods, processed as minimally as possible.

But we already knew that.

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Oct 14 2025

California defines ultra-processed foods and bans them from school meals—by 2035 (!)

California’s governor, Gavin Newsom, has just signed the bill, “Pupil nutrition: restricted school foods and ultraprocessed foods of concern: prohibition.”

This bill prohibits ultra-processed foods in federally funded school meals (K-12, breakfast and lunch), as well as competitive foods sold as snacks.

This means that

From the midnight before to 30 minutes after the end of the official schoolday, at each school, the only competitive foods that may be sold to a pupil are fruit, vegetable, dairy, protein, or whole grain rich food items; foods with a fruit, vegetable, dairy, protein, or whole grain item as its first ingredient; or combination foods containing at least one-quarter cup of fruit or vegetable.

These foods must also meet the following standards:

(1) Not more than 35 percent of its total calories shall be from fat. [This does not apply to individually sold portions of nuts, nut butters, seeds, seed butters, reduced-fat cheese or part-skim mozzarella cheese packaged for individual sale, eggs, fruits, vegetables that have not been deep fried, seafood, or a dried fruit and nut and seed combination.]
(2) Less than 10 percent of its total calories shall be from saturated fat. [This does not apply to reduced-fat cheese or part-skim mozzarella cheese packaged for individual sale, eggs, nuts, nut butters, seeds, seed butters, or a dried fruit and nut and seed combination.]
(3) Not more than 35 percent of its total weight shall be composed of sugar, including naturally occurring and added sugar. [This does not apply to fruits, vegetables that have not been deep fried, or a dried fruit and nut and seed combination.]
(4) Contains less than 0.5 grams of trans fat per serving.
(5) Contains not more than 200 milligrams of sodium per item, package, or container sold to a pupil.
(6) Contains not more than 200 calories per individual food item.
And then, beginning December 31, 2027, competitive foods may not contain color additives:
(A) Blue 1
(B) Blue 2
(C) Green 3
(D) Red 40
(E) Yellow 5
(F) Yellow 6
This is terrific, but don’t hold your breath.  The timeline:
  • June 1, 2028: The State Department of Public Health adopts regulations.
  • July 1, 2029: Schools begin to phase out restricted school foods
  • July 1, 2032: Vendors cannot offer restricted foods.
  • July 1, 2035: bill fully implemented.

Really?  Ten years to make this happen?  A lot can happen in that time….

Press reports

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