Why we should move from confusion to clarity in the UPF debate

This lack of clarity has real implications for food innovation, consumer trust and regulation. As health authorities, scientists and brands struggle to define and communicate UPFs, ingredient suppliers can bring clarity and science-led solutions to the table.

Blurring the line 

Food processing in itself isn’t the problem. Techniques such as pasteurisation, freezing, canning, fermentation and dehydration can enhance food safety and preserve nutrients. These methods are vital for reducing foodborne illness and improving global food security.

Ultra processing, by contrast, refers to industrial formulations made mostly or entirely from substances derived from foods and additives, with little resemblance to their original ingredients. According to the widely cited (and contested) NOVA classification, UPFs are foodstuffs that bear little resemblance to their original ingredients due to extensive industrial modification, including extrusion, hydrogenation, hydrolysis and use of artificial flavourings, colourings, sweeteners and texturisers that can mimic the functional and sensory qualities of whole foods.

Critics of the NOVA system view it as a rather blunt instrument that often fails to capture the degree of processing versus the purpose of it. For instance, a fortified breakfast cereal and a meat analogue/alternative may both be labelled ‘ultra-processed’ yet their nutritional profiles and impact on consumer health and wellbeing differ greatly.  

A charged debate

The UPF debate taps into broader anxieties about modern diets and trust in the food and beverage industry. Consumers correctly sense that some packaged foods are less nourishing than their whole food counterparts. But the lack of consistent definitions means that ultra-processed has become a catch-all term for anything industrial, chemical-sounding sounding or artificial. 

For regulators and manufacturers, this lack of clarity is a major challenge. Without hormonised definitions or risk-based frameworks, policies risk being ideologically driven rather than scientifically grounded. In addition, ingredient brands and food manufacturers face a more complex environment when it comes to balancing consumer sentiment, regulatory risk and innovation opportunities.

Nutrient depletion and functional additives

Criticism of ultra-processed food is not without merit. Studies show that intensive processing can deplete micronutrients, fibre and bioactive compounds. Higher heat, extended processing, solvent extraction and other harsh treatments can degrade vitamins, denature proteins and reduce beneficial polyphenols.

Moreover, UPFs often rely on refined starches, added sugars, unhealthy fats and sodium, designed to maximise sensory appeal rather than nutrition. This combination can alter metabolic responses and has been linked with higher rates of obesity, inflammation and cardiometabolic disease. 

Importantly, the issue is not processing in itself, but its purpose. If the goal is safety, minimal alteration or enhanced nutrient retention, then processing is beneficial. If the goal is hyperpalatability, cost-cutting, and long shelf life at the expense of nutritional value, then the risk of harm rises.

Ingredient suppliers can play a positive role by offering solutions that deliver functionality, including shelf life, texture and safety, without defaulting to heavy ultra-processing.

What California’s UPF Bill Signals 

In 2024, California passed Assembly Bill (AB) 1264, known as the ‘UPF Bill,’ the first US law to formally define ultra-processed foods. The law combines ingredient and nutrient-based criteria, considering both additive use (e.g., emulsifiers, stabilisers, non-nutritive sweeteners) and the thresholds for saturated fat, added sugars, and sodium.

Under the legislation, certain UPFs will be phased out of school environments between 2029 and 2035. Manufacturers supplying schools must submit annual reports detailing ingredients, nutrition panels, and UPF classification status.

Reformulation alone won’t be enough: reducing sugar, salt, or fat doesn’t exempt a product if it still contains targeted additives. This marks a deeper regulatory focus on processing methods, not just nutrient content.

Although the law applies only to schools, its influence could extend far beyond California. Given the state’s market size, similar measures may ripple across the US, and potentially globally, prompting food and ingredient companies to reassess formulations and transparency practices.

AB 1264 is therefore more than a regional rule; it signals a global shift toward regulating processing itself. For ingredient brands, it highlights the need to innovate with cleaner, naturally functional alternatives and engage early with policymakers to enable future food classifications.

Ingredient innovation with purpose

If the term ultra-processed has become a source of confusion and controversy, then ingredient brands and suppliers hold the key to clarity. They occupy a unique position in the food value chain as a bridge between science and consumer perception, between functionality and nutrition. By rethinking how ingredients are designed, processed, and communicated, they can lead the next evolution in food innovation: one defined by transparency, responsibility, and purpose.

The first step lies in reformulating with natural functional equivalents. For decades, food safety and sensory enhancement relied on synthetic emulsifiers, preservatives, and colourants. Yet advances in bio-based chemistry and food biotechnology now make it possible to replace many of these with natural, clean-label alternatives, including plant fibres that stabilise textures, fermentation-derived cultures that extend shelf life, or botanical extracts that deliver vibrant, stable colour. These innovations don’t just satisfy regulatory expectations; they actively rebuild consumer trust.

Equally important is the shift toward clean technology processing systems. These are viewed as the next generation of techniques designed to preserve nutrition while ensuring safety and quality. Low-shear and enzyme-assisted processes, cold-pressing, high-pressure processing (HPP), and controlled fermentation are proving that functionality and freshness need not be mutually exclusive. Such technologies can help manufacturers maintain product integrity without crossing into the ultra-territory that increasingly attracts scrutiny.

Transparency must also become a core part of product development. Consumers are no longer content with long opaque ingredient lists or ambiguous claims. They want to understand why a certain additive or process is used, and how it contributes to safety, nutrition, or shelf life. Ingredient suppliers can lead this narrative shift through ingredient storytelling that is clear, evidence-backed communication that demystifies food science and demonstrates intent. When brands explain the ‘why’ behind processing, they turn potential scepticism into confidence. 

Finally, ingredient companies need to engage proactively with regulators and campaign ecosystems. As demonstrated by California’s AB 1264, large-scale regulatory shifts are no longer hypothetical but are already being enacted. Suppliers who monitor and contribute to these discussions, who publish white papers, join advisory groups, or form data-sharing partnerships, will help shape definitions rather than react to them. Developing internal roadmaps for phasing out flagged additives and aligning product portfolios with evolving definitions of ‘clean’ will also be key to staying ahead of policy and perception alike.

The ultimate goal is collaboration on evidence-based frameworks. Working alongside scientists, health bodies, and regulators, industry can move toward a definition of ultra-processing grounded not in emotion or optics, but in measurable outcomes around nutrient density, bioavailability, metabolic impact, and long-term health relevance. When the term ‘ultra-processed’ is defined by science rather than semantics, the term becomes actionable, not adversarial.

From confusion to credibility

The movement to rethink food processing is accelerating. NGOs, policymakers, and consumers alike are demanding reform. For ingredient brands, this is both a challenge and an opportunity.

To lead, the industry must anticipate regulation, audit ingredient portfolios, and invest in compliant innovation. The message must also evolve; processing isn’t inherently bad, but irresponsible processing is. By demonstrating that smart, responsible processing supports nutrition and sustainability, companies can position themselves as part of the solution.

Credibility grows from commitment and transparency. Public pledges, measurable targets, and open data, including studies showing nutrient preservation or synthetic replacement signal accountability to both regulators and consumers. In today’s environment, visibility is not a risk but an advantage.

For more insights into UPFs and what they mean to the industry, contact our team by visiting.