Dear Anthony and Mike, 

You’ll be aware that ultra-processed foods (UPF) have been in the spotlight of late, prompting a lively and often heated debate. It’s my contention that the UPF concept and associated NOVA system, applied appropriately, advance our understanding of dietary health and food system politics. I believe governments should respond accordingly. This letter is written in anticipation that our views may differ, in the spirit of furthering the debate.

As an opener, allow me to outline the contexts in which the UPF concept is commonly applied (or misapplied). To my mind there are (at least) four. UPF may be understood as (i) a designation describing the degree and purpose of processing applied to a food product; (ii) a frame within which to assess the health outcomes associated with dietary patterns; (iii) a conceptual lens for viewing the political economy of the food system; and (iv) part of a body of evidence that might inform policy. Let’s take these one at a time.

As a designation applied to food products, you’ll know that ‘ultra-processed’ derives from the NOVA system devised in 2009 and honed over subsequent years to describe four categories: N1, minimally processed foods; N2, processed culinary ingredients; N3, processed foods; and N4, ultra-processed foods.

It’s worth stressing that this is all NOVA does. In popular discourse, ‘ultra-processed’ is sometimes taken to imply a value judgement (‘UPF = bad!’) or as a blanket condemnation of diverse products as uniformly ‘unhealthy’. There are lots of reasons ‘UPF’ carries such connotations, but they are not intrinsic to NOVA. There is no value judgement in NOVA; the system doesn’t tell you whether a food is good, healthy, ethical, or sustainable. All NOVA does is categorise food products according to the degree and purpose of processing.

What’s the value in that? Well, researchers have harnessed NOVA to assess the health outcomes associated with different dietary patterns. Diets rich in UPF have been associated with poorer health outcomes, and for reasons which appear to extend beyond nutrient composition.

As with nutritional epidemiology more broadly, scientists have had to grapple to accurately measure intake and isolate confounding factors, and no doubt NOVA-based research will continue to grow in sophistication in years to come, but the evidence is already compelling. Dozens of cohort studies controlling for salt, fat, sugar, and overall diet quality, have found UPF-rich dietary patterns robustly and independently associated with poorer health outcomes. A randomised controlled trial similarly found a UPF-rich diet caused an increase in ad libitum calorie intake and weight gain. Hypothesised mechanisms underlying this association relate to properties that blunt satiety signalling, organoleptic characteristics associated with higher energy intake rate, and additives that might act as endocrine disruptors or disturb the microbiome. It’s likely that multiple mechanisms are simultaneously at play across the span of an ultra-processed diet. 

UPF are defined by the ‘purpose’ as well as ‘degree’ of processing. That purpose, broadly speaking, is product design for profit maximisation. UPF are often designed to either displace NOVA 1-3 foods or generate novel eating opportunities (snacking etc) and engineered for repeat purchase. UPF might also be designed to be convenient, safe, or rich in chosen nutrients, but there are few incentives in the system to motivate manufacturers to prioritise public health over corporate profit. The UPF concept thereby contributes to our understanding of the commercial determinants of dietary health.

In the context of a globalised food system, the UPF business model has been very successful. UPF is displacing traditional cuisines and indigenous food cultures worldwide, part of a dietary transition shaped by social, biological, and economic drivers. Underpinning this transition is a food production paradigm predicated on trade liberalisation, agrochemical intensification, and mass production of cheap commodity crops. The externalities for climate, nature, and health are well documented.

These are broad brush statements (as demanded by the format) and as such open to dispute. Allow me to plough even deeper into disputed territory by commenting on potential policy implications. How should governments respond?

We probably agree that governments should invest in research concerning UPF. The case can be made, however, that this research should not impede more immediate action, the evidence having now reached a ‘critical mass’. I would argue that there are ‘no regrets’ policies that should be implemented now, and that we are obliged to take a precautionary approach, especially in relation to child health. This line of reasoning would lead to NOVA being employed alongside nutrient profiling to inform policies aimed at re-balancing diets across the social gradient towards minimally processed foods and healthier processed foods, away from UPF.

If such proposals are controversial, it is partly because they threaten the industry’s business model. If ultra-processing is the issue, and not only salt, fat, or sugar, and if reformulation has limited potential as a public health strategy, then how is industry to respond? Both legitimate and illegitimate lines of critique have been levelled against NOVA, the latter sometimes deriving from this thorny challenge posed to industry. Paradigm shifts are uncomfortable, especially for those in eclipse. 

For these reasons, in these contexts, I find the UPF concept to be of utility and value. Would you agree? I look forward to your response. 

Yours sincerely,

Rob

Dear Anthony and Mike,

I’d like to unpack one line of criticism that recurs across your responses. You both seem to agree that the purported ‘subjectivity’ of NOVA is problematic. Mike writes: “Adding ‘purpose’ to ‘degree’ in the NOVA definition of UPF introduces considerable subjectivity… the definition needs to be more objective if the concept is to be useful.” Anthony similarly warns that NOVA’s political dimension is “foolish and anti-science”.

Implicit in these comments appears to be the view that, beyond NOVA, there are areas of nutrition science which are objective and apolitical. NOVA is undesirable in that it sullies these clear waters.

In response, I’d like to return to the origins of NOVA and to Carlos Monteiro as its architect. I enjoyed Anthony’s description of Carlos as “a Brazilian nutritionist, motivated by the anti-capitalist impulse of reducing the influence of large corporations.” This conjured (to my mind, at least) the image of a Che Guevara figure – Monteiro in a leather motorcycle jacket, biking around Latin America, preaching the Brazilian dietary guidelines as his neo-Marxist creed. But that’s not quite how this began. Monteiro was indeed concerned that multinational corporations were trampling over indigenous food cultures, but he was also grappling with a more mundane paradox. People in Brazil were eating less sugar and fat, yet they were becoming heavier and unhealthier. This ran counter to the prevailing wisdom.

You’ll be aware that for the past half century dominant strands of nutrition science have focussed narrowly on single nutrients as determinants of health, an outlook characterised as ‘nutritionism’. Within this reductive paradigm, nutrients are systematically decontextualised from the foods, dietary patterns, social contexts, and food systems in which they are embedded. The problem to be solved is fat, or fibre, or sugar. Monteiro understood that this perspective could not explain the trends he was observing in Brazil. NOVA was conceived to illuminate the bigger picture.

It’s important to recognise that ‘nutritionism’ did not become the prevalent paradigm by accident. A narrow focus on ‘nutrients of concern or benefit’ neatly coheres with an ultra-processed business model, for it allows UPF companies to fortify, functionalise, or reformulate their products, and to market them with a health claim. UPF companies have accordingly engaged in a range of ‘corporate scientific activities’ aimed at creating and perpetuating a body of knowledge characterised by reductive nutritionism. These activities include the funding and framing of nutrition research; sponsoring scientific seminars and events; involvement in scientific standards and policy committees; and funding scientific front groups to influence policy, regulation, and media narratives.

These front groups are active in the UK, where the UPF industry is deeply embedded at the interface of science and policy. Financial ties to ultra-processed food companies can be observed in high-level UK Government committees, including the Scientific Advisory Committee on Nutrition (SACN) which recently formed a view on UPF. Anthony claims that in reaching this view, SACN reviewed “the actual totality of evidence”. They did no such thing. The committee critically analysed twelve studies related to UK consumption – a worthwhile exercise, but far from the “actual totality” of the available evidence, especially if one looks beyond nutritional epidemiology to relevant evidence pertaining to commercial determinants and food system politics. SACN’s review was nutritionism in action.

I willingly concede that NOVA’s conjoining of ‘purpose’ with ‘degree’ can feel disorienting, but this is primarily because we’re not (at least in our culture) accustomed to thinking in such a hybrid manner. NOVA makes salient a political domain that is often obscured from view. If UPF discourse was to vanish overnight, we would not be left with a research and policy agenda purged of ‘subjectivity’. No area of science is apolitical or wholly objective – the accumulation and implementation of scientific knowledge does not take place in a social or psychological vacuum. It’s a human endeavour.

That is not to say that NOVA cannot be employed in an ostensibly ‘objective’ (even reductive) manner. One can readily use NOVA to categorise foods according to a defined set of physical transformations or characteristics. Many scientists are employing the system in this way, investigating the molecular and physio-chemical components of UPF and their relation to bodily health. But the inclusion of ‘purpose’ within NOVA’s definition provides an in-built ‘telescoping’ mechanism that persistently draws attention back to the big picture, micro to macro – from the molecular level to whole foods, dietary patterns, commercial determinants, and food system drivers.

And herein lies the system’s value. NOVA punctures the pretence of the apolitical. Implicit in NOVA is the understanding that dietary health can only be understood in this larger context, which encompasses corporate profit motives. It compels us to recognise that another decade of UK dietary health policy myopically focussed on reformulation and ‘nutrients of concern’ is a decade wasted. We either pursue more structural transformations to food systems and diets, or we will continue to fall sick. The ‘purpose’ component does not muddy the waters but deepens them. What you perceive to be the system’s weakness may be its greatest strength.

All best wishes,

Rob

Dear Anthony and Mike,

You’ve raised concerns regarding meat consumption, suggesting NOVA might be misaligned with efforts to shift diets (as is needed in affluent populations) from animal foods towards plants. Of particular concern is the appropriation by the meat industry of the term ‘ultra-processed’, which has been selectively employed by lobbyists to dissuade people from consuming plant-based products, thereby entrenching meat-rich dietary patterns. I share your concern in this regard. 

But, as ever, it’s important to differentiate science from industry spin. NOVA does not give a green light to uninhibited meat consumption. On the contrary, NOVA-based research strongly associates UPF-rich diets – and those are diets rich in burgers, sausages, nuggets, and other reconstituted meat products, also often lacking in pulses and vegetables – with poorer health outcomes. In the UK, UPF represents the largest category of meat consumed. NOVA-based science implies we should be eating much less, and NOVA-informed dietary guidelines, such as those in Brazil, accordingly advise people to consume foods “mainly of plant origin” and to eat animal foods “in small quantities” only.

On a food system level, ultra-processing and industrial animal farming are symbiotic. Both are driven by the intensive production of cheap commodity ingredients and the incentive to add profit along consolidated supply chains, typically either by manufacturing commodity crops into saleable ultra-processed products or by forcing those crops through a factory farmed animal (whose flesh is often subsequently processed into UPF). Indeed, the defining feature of the global ‘nutrition transition’ is the displacement of diverse indigenous food cultures by a ‘Western’ monocultural diet rich in both UPF and factory farmed meat. They are two sides of the same coin.

Of course, this is not how the meat lobby has presented NOVA, especially in the U.S., where the term ‘ultra-processed’ has been weaponised to attack plant-based products and mask the harms caused by industrial meat and dairy. This is dishonest. While one segment of the industry (selling snacks, drinks, and so on) is voraciously dismissing concerns about ultra-processing, saying, ‘NOVA is nonsense, keep buying our product!’, another segment (selling burgers, nuggets, and so on) is simultaneously appropriating the term, saying, ‘NOVA (our warped version of it) is gospel, keep buying our product!’ Neither tells us much about NOVA itself; both speak of the wilful contortion of science by corporate interests.

This contortion is pervasive in UPF discourse. Anthony suggests that, “Under NOVA, we can all eat plenty of unprocessed steak cooked in butter, so long as we avoid wholemeal bread”, and that NOVA “defines bacon cooked in lard as a healthier breakfast choice than muesli and yogurt”. NOVA says no such thing. These statements might bear resemblance to meat lobby rhetoric, or claims made on social media, but neither is substantiated by NOVA-based science. Neither reflects the nuance or balance of NOVA-informed dietary guidelines, which repeatedly caution (on both health and environmental grounds) that meat and animal foods should be eaten “sparingly”. Anthony is perhaps alluding to the recommendation that people “avoid ultra-processed foods”. Some yoghurts and breads fall into this category. But the guidelines stress that one should choose less highly processed versions of the same product or category, where available. The advice is to eat less highly processed bread and yoghurt, not to gorge on lard.

Why is misinformation about ultra-processing so rife? It’s partly because industry-linked actors have deliberately sought to sow confusion and doubt. The UPF industry bears resemblance in this regard to the fossil fuel, tobacco, gambling, mining, and pharmaceutical industries, where the same pattern of ‘corporate political activity’ has been observed. In each case, industry voices have sought to co-opt the fields of policy making, science production, and public opinion, making it difficult to disentangle propaganda from reality, rendering corporate-sponsored values and narratives dominant.

The purported difficulty (which Mike alluded to in an earlier letter) of applying NOVA in a consistent manner provides a salient example. Evidence for this difficulty primarily derives from industry-linked studies. In studies where the authors have no financial or non-financial competing interests to declare, and where NOVA is applied by trained individuals, there is less than 5% disagreement in product category assessments. 

It bears repeating that NOVA can readily be used to categorise foods according to a defined set of physical transformations or characteristics. Many scientists have employed the system in this way – across large, long-duration, carefully conducted cohort studies, and randomised control trials, both published and in development – to investigate the impacts of UPF-rich diets on bodily health. This research is advancing apace and is already informing policy in diverse contexts, a trend that is likely to grow exponentially once a ‘regulation friendly’ iteration of NOVA is published. Such an iteration, further enhancing the system’s specificity and granularity, is already in development.

NOVA offers an avenue beyond the reductive nutritionism that industry cleaves to, an opportunity to build on those health improvements obtained through the hard work of nutrition scientists and public health advocates. It is ‘fit for purpose’ in science and policy, and there is growing public appetite for a political response. 74% of UK citizens say they would welcome government action on UPF. This need not involve ‘demonising’ or ‘damning’ ultra-processed products; it has nothing to do with ‘banishing’ veggie burgers or ‘moralising’ everyday food choices. The challenge is simply to reconfigure food systems so that everyone can access and enjoy a healthy and sustainable diet. NOVA reinforces the understanding that such a diet should be based around diverse, minimally processed foods, mostly plants. Climate, nature, and human health all stand to benefit. It is only industry obfuscation that stands in our way. 

All best wishes,

Rob