Ultra-processed food: myths, misconceptions and the regulatory gap

The stunt worked. Van Tulleken used the bar to demonstrate the blurred boundaries between health marketing and formulation reality. At the same time, Wicks highlighted how difficult it is for consumers and experts to define where processed foodstuffs become ultra-processed. The public reaction captured a truth the food industry has long grappled with: we lack a shared understanding of what ultra-processed really means, and how brands can innovate responsibly within that uncertainty. 

At ACI Group, we believe this moment underscores a vital point. The future of food cannot be built on ambiguity. To restore trust and support evidence-based reformulation, we need clearer definitions, better communication, and stronger alignment between science, regulation and industry practice. 

What does ultra-processed actually mean?

Every food undergoes some level of processing, from washing and freezing vegetables to fermenting dairy or baking bread. These are ancient, necessary interventions that ensure food safety and accessibility. The controversy lies in what happens when foods are formulated from multiple industrial ingredients, isolates, extracts, stabilisers, and flavourings, to mimic or enhance whole foods.

This is the foundation of the NOVA classification system, which categorises foods into four groups, from unprocessed to ultra-processed. Ultra-processed foods (UPFs) are typically industrial formulations built from fractionated components such as starches, proteins, oils, and additives not used in home kitchens.

NOVA was designed to highlight the social and nutritional impacts of industrialised diets but applying it in practice has proven difficult. Under its broad definitions, a fortified cereal, plant-based drink or convenient protein bar could all qualify as ultra-processed, regardless of nutritional value or purpose. Critics argue that this creates confusion, lumping together nutritionally beneficial innovations with indulgent products that genuinely deserve scrutiny.

The key challenge then isn’t just scientific but also linguistic. UPFs have become a cultural term as much as a nutritional one, weaponised in debate but poorly defined in law.

Myths, misconceptions and media narratives

The ‘Killer’ Protein Bar experiment illustrated how public conversation about processing often rests on misconceptions. 

One enduring myth is that UPFs are always unhealthy. But, while diets high in UPFs are linked to increased health risks, processing itself isn’t inherently harmful. Often, it’s the nutrient profile of the product that is high in sugar, saturated fat or sodium that drives poor outcomes, not the act of processing. Some UPFs are nutritionally valuable or essential for safety and shelf life. The question isn’t whether something is processed, but why and to what extent.

Another misconception is that products marketed as natural or clean label automatically escape the UPF category. Many of these items still rely on additives or industrially derived ingredients to achieve the desired texture, flavour or stability. Without clear definitions, the term natural can be more about perception than formulation. 

And the most limiting belief of all is that processing is bad by default. Processing has enabled food to become safer, more sustainable, more affordable, and more accessible. The issue is not the presence of processing, but the absence of transparency about its purpose.

What the science really tells us

The evidence based on UPFs is growing fast. Large-scale reviews have found associations between high UPF consumption and adverse health outcomes, from cardiovascular disease to cancer. However, many of these studies are observational and can’t isolate whether harm comes from the processing itself, the additives, or the broader dietary pattern.

Some research suggests that highly processed foods may disrupt appetite regulation or encourage overconsumption because of their engineered palatability. Other studies show that certain forms of processing, such as fortification or fibre enrichment, can improve nutritional outcomes. 

What’s clear is that the issue is complex and context dependent. Demonising all processing risks halts innovations that could make food healthier, more sustainable or more affordable. What’s needed is a nuanced, evidence-based conversation that distinguishes good processing from bad practice.

A regulatory blind spot

But here lies the heart of the problem: there is no legal definition of an UPF in the UK, EU or most other markets. Food law regulates safety, additive permissions, labelling and nutrition claims, but not the degree of processing.

This creates a regulatory void. A product can meet every safety and nutritional requirement and still be branded a UPF in the media. Brands genuinely trying to reformulate responsibly face uncertainty about which ingredients or techniques might later be criticised. Meanwhile, others can exploit the ambiguity with minimally processed or non-UPF claims that have no formal basis.

For consumers, this lack of clarity is just as problematic. Labels can’t tell the full story, and there’s no easy way to distinguish between beneficial processing and gratuitous complexity. At the same time, governments are tightening the net – with new UK policies on HFSS marketing restrictions, sugar levies and nutrient profiling set to expand significantly by 2026. These measures aim to improve public health but will also increase scrutiny of formulation practices and ingredient choices across the supply chain. Until regulators, scientists and industry agree on shared definitions, both trust and innovation will remain at risk.

Transparency and responsibility over fear

At ACI Group, we see this not as a crisis but as a crossroads. The current debate around UPFs offers a chance to rebuild trust through transparency, evidence, and responsibility.

Our approach begins with clarity of purpose. Every ingredient, every additive, every processing step should have a reason that can be explained clearly to regulators, to clients, and to consumers. Processing should never be hidden; it should be justified. 

We help manufacturers reformulate intelligently, reducing unnecessary complexity, improving nutritional balance, and selecting functional ingredients that add measurable value. Our philosophy is simple: if an additive or process doesn’t meaningfully enhance safety, nutrition or stability, it probably doesn’t belong. 

We also believe in collaboration over blame. Rather than pointing fingers at ingredients that are perceived as bad, ACI Group works with brands, scientists and policymakers to define practical frameworks for responsible processing. By bridging the gap between innovation and accountability, we aim to move the conversation beyond fear and toward informed progress.

Finally, we focus on empowering communication. Consumers are asking harder questions than ever before. Brands that can answer them with honesty and data will lead the next era of food innovation. Transparency isn’t just ethical; it’s a strategic advantage.

Looking beyond the protein bar

The documentary on the making of the ‘Killer’ Protein Bar was a provocation, not a product launch. It was designed to highlight how easily something can appear healthy while embodying the very traits that concern public health experts. But it’s true legacy lies in the question it raised: can we do better? 

At ACI Group, the answer is yes if we combine transparency, science and responsible innovation. Processing, when guided by purpose and accountability, can be a force for good. The challenge ahead is not to eliminate it, but to redefine it.

As the UPF debate evolves, ACI Group will continue to champion clarity and credibility, helping brands innovate with confidence, reformulate with evidence, and communicate with integrity. Because in the end, it’s not just what’s in our food that matters, but how openly we tell its story. For more information or to talk to our team, contact us today.