Last month, we brought together a group of experts to explore how the ultra processed food (UPF) debate is shaping the future food and drink system and the unintended consequences that may unfurl following knee-jerk responses.
The session saw a number of questions directed at the panel - here we answer the ones we didn’t get time to addressing on the day.
You can read a key takeaways article of the session here and watch the webinar for free here.
Meet the experts
Alan Jones (AJ) - head of R&D innovation and regulation, Baker & Baker
Elin Roberts (ER) - co-founder and co-CEO, Better Nature
Genna Freeman-Dennis (GF) - application specialist, Healy Group
Kate Halliwell (KH) - chief scientific officer, FDF
Matt McAuliffe (MM) - plant based & futures innovation director, The Compleat Food Group
Paul Sheldrake (PS) - group application & technical director, Healy Group
Q: What are your opinions on the NOVA classification system?
MM: I think it is a useful but a rather blunt way to classify the food we eat. My suggestion would be to spend more time researching the impact rather than creating other ways to classify.
AJ: The NOVA classification system could be improved. Its core purpose is to improve core health outcomes; however, because the classification groups together a broad range of product groups that could be construed as healthy and unhealthy, this causes a significant amount of confusion.
KH: One of the confusing aspects of the term ‘ultra-processed food’ is that there is currently no clear or consistent definition, either in research or legislation. When the government’s Scientific Advisory Committee on Nutrition (SACN) looked at this they found eight different definitions, although the NOVA classification was the most common.
The NOVA definition considers level of processing of food on a scale of 1-4, from minimally processed to ultra processed, based mainly on the level and type of ingredient. It does not consider the nutritional content of the food.
Whilst there are observational studies which link NOVA level 4 foods to poor health outcomes, SACN has deemed this evidence base to be weak. The evidence base which underpins our nutrition guidelines is much stronger, and so as an industry we’re focused on improving the nutritional profile of our products, and helping people meet the government’s dietary guidelines.
PS: Overall, the NOVA classification is endeavouring us to start to think and understand more about the range of foods that we are eating and how much they have been ‘processed’ in order to be able to manufacture them.
The classification is just that - a start. The fact that it is very difficult, if not impossible, to fully categorise and class every product makes the methodology further challenging. It is a continuum and thus has fuzzy boundaries. Within each food type, the range could stretch across a whole spectrum and thus further complicates it.
The generalisation that more processed means less wholesome is not always the case and so focusing on the nutritional profile of each product, in the context of a balanced diet, is essential to make the best out of this starting point.
Therefore, less ‘processed’ and more complete foods which are nutritious should be the ultimate goal in terms of healthy diet.
Q: What is the main source of misinformation around UPFs and what is driving it?
KH: The term ‘ultra-processed’ in itself is ambiguous and confusing for both consumers and manufacturers. It demonises a wide variety of foods that can be included in a healthy balanced diet, as shown by the Government’s Eatwell Guide – things like bread, breakfast cereals, yoghurts or vegetable pasta sauces.
Although there’s a lot of attention on the term UPF, the body of scientific evidence behind it isn’t strong. SACN and many other nutrition organisations – such as The British Dietetic Association (BDA) and the British Nutrition Foundation (BNF) – have noted that currently there’s insufficient evidence to show that the act of processing food has a link to poorer health outcomes. The recent House of Lords Food, Diet and Obesity Committee report ‘Recipe for Health’ also found there was not enough evidence to support using UPF in policy.
It’s important that any public discussions on the topic – be that by industry, in the media, or among political stakeholders – are clear on the current status of the scientific research or we risk causing unnecessary confusion and concern for consumers.
MM: Social media is certainly a major driver behind misinformation around UPFs. Recent research conducted by The Changing Markets Foundation found that a quarter (24%) of all social media posts analysed disparaged plant-based meat and dairy alternatives by alleging these lack nutrition, suggesting that they are ‘ultra-processed’ and ‘Frankenfoods’ that can cause serious disease and ‘turbo cancers’.
This narrative was found to be driven for the most part by a small group of social media accounts but demonstrates how quickly misinformation about this very nuanced topic can spread.
Q: Have any of the big retailers taken any action on UPF?
PS: In our meetings and discussions with the retailers, it is very clear that they are acutely aware of the issue and are trying to navigate what that means for them as businesses.
The one aspect that they seemed to have grasped at present is around the back of pack labelling where, by making the ingredient declaration more ‘consumer friendly’, there is the perception that there are less ‘nasties’ associated with UPFs.
The challenge is that in cleaning up the label, many of the clean label functional alternatives which work and ensure food safety and quality, are more expensive and/or need to be used at higher dosages which drives up cost. This is against a background of inflation, food affordability and price competitiveness; and so they are being selective as to where best to approach this.
The label changes are not necessarily addressing any improvements to nutritional profiles where, again, the same challenges of replacing relatively inexpensive ingredients such as sugars, salt and fat, with healthier but more expensive options comes back to inflation, food affordability and price competitiveness challenges.
Thus, if change needs to happen then a level playing field with achievable targets can allow the whole market to change.
Q: To what extent will food manufacturers need to invest capital in changing manufacturing processes to pivot away from UPF? Do we think this will delay the transition to healthier food offerings?
KH: Our members’ focus is on how to make healthier products, using the Government’s nutrient profile model as their guide, as well as offering smaller portion sizes.
Investment is critical to ensure we can create healthier food and drink choices for consumers – whether that’s R&D to develop new products that are lower in fat, salt and sugar, or in the machinery itself to adapt to new formulas or serving sizes.
Our members invested more than £160m in 2023 in healthier product development, so we’re already making great progress. However, accessing finance and support can be challenging, particularly for smaller businesses.
As the UK’s largest manufacturing sector, we want to continue working with government to help build on industry’s investment in this. In particular, we’re asking for a £4m fund to expand the very successful Scottish government funded ‘Reformulation for Health’ programme, to the rest of the UK.
This scheme has provided specialist support to 80+ Scottish SMEs in its first five years, removing billions of calories and tonnes of fat, sugar, and salt from popular Scottish products. Replicating this across the entire nation could have a significant impact on healthy product development in the UK.
PS: This is a complex question which manufacturers will need to address on a case-by-case basis.
In some cases, there will definitely be a need for capital investment to change manufacturing processes in order to pivot away from some UPF materials.
Then there are others where, due to the nature of the raw materials, they may not need to change.
I believe the bigger manufacturing and capital changes are related to improving the nutritional profiles where new technologies may be needed to achieve lower fat, salt, sugar, higher fibre type products. This is where new and innovative processing routes may be need to achieve good quality, sustainable, affordable and food safe to eat products.
AJ: Until there are clearer guidelines or evidence linking UPF with poorer health outcomes, manufacturers will not be willing to invest in alternative manufacturing processes, as it would remain unclear where and how such investment should be targeted.
Q. What do you think are the overlaps and potential for opportunity (if at all) between UPFs and net zero?
MM: Eating healthier and more natural food is directly linked to lowering impact on the environment, including saving water and helping to increase biodiversity. The ‘LiveWell’ diet and findings in response to following this diet is a good example of this.
A WWF report (Eating for Net Zero, 2023) reported that following the Livewell diet will result in a 36% reduction in emissions and a 20% reduction in biodiversity loss compared to the current average diet, while also supporting a transition to nature-friendly farming practices.
To deliver this we need to get 50% of our protein from plants, eat more beans, legumes and cereals, and a lot less high fat, salt and sugar-based food.
At Compleat, we are using this insight to develop products that are healthier for the consumer. Aligned with a balanced diet, delicious food and affordability, we call this ‘Food to Feel Good’.
AJ: By joining the net zero and UPF debates, there would be the significant potential for additional confusion and complexity. Food manufacturers already have significant challenges in addressing scope 3 emissions, and bringing UPF considerations into the mix would create additional challenges and roadblocks to tackling the climate crisis.
KH: Processed foods play an important part in the food sector’s ambition to reach net zero. First, they can help people transition to eating less red meat and dairy by providing plant-based alternatives that are easy to incorporate into their current diets, for example plant based dairy alternatives, fortified with calcium and vitamin D.
In addition, processing can play an important role in prolonging the shelf-life of foods, helping ensure less food gets wasted. This is a critical part of achieving net zero ambitions. As FDF’s recently published environmental strategy, Ambition 2030, reported: Globally around one third of all food produced is wasted, accounting for 8-10%of total global GHG emissions. This wasted food is driving additional nature loss, putting unnecessary pressure on land, nature and water resources, as well as having an economic and social impact.
Processing is one of the ways food manufacturers can drive down waste, both at farm-level and in the home.
GF: There are opportunities for aligning health and sustainability goals, and they intersect in many ways. Some examples are as follows:
- There is an environmental impact of UPF production. UPFs often rely on crops that require significant land, water and energy use, and those which contribute to deforestation, biodiversity loss and greenhouse gas emissions. They are also heavily packaged and distributed globally, increasing the carbon footprint.
- Dietary shift can influence greenhouse emissions - plant-based diets can reduce emissions compared to animal-based products.
- Food waste and sustainability - UPFs are often designed for longer shelf life, thus reducing food waste. The challenge is around fresh produce.
Addressing these overlaps presents opportunities to create more sustainable food systems. Reformulating products and cleaner production methods can align health and climate goals. However, there is a balance around improving nutritional quality with reducing environmental impact.
Q: Where do you see any lock-ins or path dependencies in the system that need to be tackled for achieving more improved health and nutrition outcomes that include UPFs in the picture?
AJ: One aspect of UPFs is the amount of and the type of ingredients used. We know the population should consume increased volumes of fibre, fruit and vegetables, but this aspiration goes against using a restricted amount of ingredients and of store cupboard ingredients.
PS: This is a complex challenge that can be seen, for example, in some of the recommendations from the recent UK House of Lords report: ‘Recipe for health: a plan to fix our broken food system’.
I see a few lock-in dependencies which are incredibly aspirational - but these need to be grasped if we are to achieve improved health outcomes.
The first is that we need to make it happen, and as many of the voluntary schemes do not appear to have worked, I see value in (appropriate) legislation to ensure that this happens.
We should set some targets and dates to work towards - and we need to start that process now.
This sea-change must happen on a level playing field, with every player having to achieve the same end goals/purpose.
The lock-in must start from the very first day our children are born so that we can put them on the path to having a nutritional diet from the beginning. This means education with practical ways to move from not just learning but to doing.
It also means making and giving people the time and resources to be able to prepare more healthy foods and choices.
Of the challenges, it is the cost/finance/affordability of healthy foods that is, in many ways, the biggest path dependency of all and will, by far, give us the most complex challenges but also the greatest long term health benefits.
Healthier foods appear, on the whole, to be more expensive and thus, those who are struggling financially find them harder to afford and yet are most likely to benefit from them.
This can be the actual costs of the food items, the cost of energy, and/or the cost of time to prepare more freshly made food (generally considered to be more healthy).
In UPF terms, the more ‘hyper-palatable’ products are generally higher in calorie density, more affordable and more convenient to prepare at home. So for those who are struggling financially, this is where they appear to turn to in order to be able to put food on the table.
We will need to invest in helping all food businesses to achieve healthier and more affordable food, with support in skills, processes, systems, knowledge and education. In particular, those that do not have sizeable resources to do this themselves on the level playing field.
Hence, the biggest path dependency is how to flip the above in a paradigm shift. How can we make better, more healthy foods, (both wholefood and also manufactured products), at a better price/value, that still taste good, thus making them more attractive to consumers and then getting us more onto the path of eating healthier? Potentially we could:
- Subsidise healthier foods to support those who cannot afford
- Penalise (tax) those that are seen as less good/healthy for our diet
- Introduce new regulations akin to HFSS
If the path dependency can be achieved, we could possibly see gains in the following areas:
- Physically healthier people are less likely to be ill; thus, the other gain is reduced pressure on health services/interventions which is where we know there are lots of costs and pressures.
- It is long term/generational, and we need to take this approach to invest in our health future.
Really, we should be asking, what is the cost of not doing this?
Q: Are there processing challenges with natural ingredients such as mixing challenges?
AJ: Changing recipes and adding more natural ingredients will always require additional testing to ascertain the quality, food safety and viability of a product, and this would include mixing and other steps along the NPD process.
GF: Many of the functional ingredients serve highly specialised roles in food and drink that cannot be easily substituted. There are challenges around stability of more natural ingredients.
Often, they do not offer the same degree of performance or cost efficiency as the synthetic counterparts used in UPF formulations.
Generally, higher dosages are required and possible the addition of other ingredients to support function.
Q: Do you foresee legislation or regulations being laid in government around UPF?
AJ: Not immediately – we believe the Government will ask for more scientific evidence to be available before taking any enforcement action on UPFs.
PS: In a word ‘yes’.
As noted in some of the recommendations from the recent UK House of Lords report, there have been a lot of voluntary schemes that have not achieved significant results. In contrast, where there has been legislation there has been action and success, for example the sugar tax on soft drinks.
Voluntary salt reduction targets have had a good level of success in some areas but, on the whole, we are still consuming more salt than we need in our diets and thus legislation and (relevant) fixed targets can add an extra level of drive.
For this to work, it must happen with a level playing field with every player having to achieve the same end goals/purpose (retail, food service, out of home, large and small businesses). This is why legislation has an impact: it doesn’t give special treatment to one over the other in the long-term target setting/achievements.
KH: Current legislation is focused on reducing foods that are high in fat, salt and sugar (HFSS), based on the scientific evidence that shows us that reducing these in your diet, alongside increasing fibre, fruit and vegetables, has a positive impact on health. And industry has made good progress on this – our members’ products now contribute a third (33%) less salt, and a quarter less sugar (25%) and calories (24%) to the British grocery market than they did in 2015. This has been the result of significant investment and R&D focused on this goal.
We advocate for legislation and regulation to be based on firm scientific evidence, which means maintaining a focus on nutrition. This clear focus also provides regulatory certainty to companies, which in turn encourages investment in providing healthier options.
ER: It’s not easy to reduce processing levels, as it often makes the food less tasty or convenient - two things that are very important to consumers.
For businesses, it’s hard to justify a choice like that, especially if consumers don’t understand why you’re doing it.
Often the pressure to create healthier options falls on small businesses who are struggling to make a profit and trying to make responsible, ethical choices. Whereas large corporations aren’t making the same choices.
There needs to be a more level playing field, and this can only come from the Government setting tighter regulations around the food and drink that can be sold in the UK.
Q: If you replace a food additive with a so called ‘natural alternative’ and if it is performing the function of the food additive, surely the alternative must also be authorised as a food additive (e.g. buffered vinegar) ingredient as ‘alternatives’ to regulated products like preservatives?
PS: In simple terms, this needs to be looked at on a case-by-case basis and within the framework of the relevant legislation.
Salt for example is heavily used for its preservative properties and so in many ways, is performing a function and yet is an ingredient.
With the natural and/or clean label ingredients that we supply we work closely with the manufacturer and the relevant legislation to ensure that we meet the relevant requirements. We understand that from time to time these are reviewed and then the legislation adjusted, such as the case of buffered/dried vinegar and certain types of rosemary extracts that have now been added to these lists.
KH: Whether or not an ingredient is deemed to be an additive can be confusing, as it depends on the form of the substance and the primary reason it’s added to food. But generally speaking, it will be an ingredient not usually consumed on its own, and that plays a defined technological function. Any substance that’s deemed to be an additive must be risk assessed and authorised for use by the regulator, regardless of whether it is considered to be ‘natural’.
Some regular food ingredients can provide specific technical functions but do not need approval, either because they have a history of being commonly consumed, or because the technical function is a secondary purpose. For example, sugar is not classified as a food additive, even though it adds sweetness and can perform a secondary preservative function in products such as jams and curds.
Occasionally, ingredients can be formally reclassified as a food additive by regulators. A few years ago the EU decided this was the case for buffered vinegar, and they have now approved it for use as an additive.
Q: What are the roles of technology in transforming the food system? Are robotics the answer?
GF: Technology plays a pivotal role in food systems for many reasons:
- Improving agriculture
- Enhancing food processing
- Efficiency in the food chain
- Addressing food waste using upcycling technology
- Environmental sustainability such as carbon measurement tools and renewable energy systems.
Robotics offer potential in food systems in terms of addressing labour shortages and increasing efficiency; however, they are not a one size fits all solution and should be viewed as a broader tool kit
PS: Technology (and science) are vital in transforming our food systems and many of the most advanced range of technologies are already used for the production of our food.
Technological advances in farming methods are incredibly progressive through the use of drones, satellites, real time evaluation, measuring and recording of crops etc., where the range of technologies is able to map and improve the planting, quality, yields and harvesting of the broad range of the foods we eat.
Manufacturing technologies that improve production accuracy, efficiency and the reduce errors can in turn reduce waste whilst improving product quality and value. These are also critical in helping to lower the overall costs of our foods.
Methods to help reduce waste, improve the shelf-life and sustainability in manufacturing can also lead to reductions in the biggest area of food waste that happens: in the home, by giving consumers more opportunities to eat their purchases rather than waste them.
The use of AI is advancing at a rate that is probably faster than anyone could anticipate, and the use of this technology is already having a significant impact on our food systems from growing through to the logistics and delivery of them to the consumers.
Robotics plays a part in this where it can add value to repetitive (human) tasks to allow improved efficiency, accuracy and productivity.
For farming this can be planting, cultivation and harvesting of foods. In manufacturing, examples are around raw materials handling, measuring and then into the manufacturing of the actual products. Further robotics are involved in handling and packaging of goods.
The supply chain benefit and accuracy of robots is beyond doubt in areas such as order picking and handling for outbound logistics and customer/consumer deliveries.
