Experts Tasked with Evaluating Basis for UPF Policies

More specifically, GCSA has been tasked with determining what scientific considerations should underpin EU policies intended to foster healthier diets based on current knowledge about UPF consumption and health.

The advisors have been asked to examine:

• Prominent UPF definitions and classification systems and whether they provide an appropriate basis for policymaking
• The current scientific evidence regarding health effects
• Patterns of UPF consumption across the EU
• Possible criteria or markers for assessing health effects.

Potential criteria identified for consideration include the degree or type of processing, energy density, nutrient composition, ingredients such as food additives and flavorings, portion sizes, consumption frequency, and individual foods' contributions to essential nutrient intake and dietary recommendations.

Importantly, the paper noted that the safety of individual substances is already subject to European Food Safety Authority (EFSA) risk assessment under the EU's premarket authorization system.

In parallel, EGE has been asked to examine ethical considerations surrounding UPFs across the food chain. Its work will consider health protection, access to adequate and nutritious food, consumer protection and autonomy, social justice, corporate responsibility, animal welfare, and environmental impacts. It will also examine socioeconomic inequalities, pricing, market concentration, labor, data ownership, and environmental externalities associated with UPF production and consumption.

Both groups have been directed to identify where available evidence is credible, limited, or missing and to highlight research gaps. Their respective scientific and ethical opinions are expected in the first quarter of 2027.

Unclear UPF Definitions and Evolving Evidence on Health Effects

Setting the stage for GCSA and EGE to form their opinions, the Scoping Paper highlighted both the growing evidence associating UPF consumption with adverse health outcomes and ongoing questions about how UPFs should be defined for research and policymaking.

The term “ultra-processed food” is most commonly associated with the Nova food classification system, which divides foods and beverages into four categories, with UPFs comprising products that contain mostly little to no whole food. The paper highlighted frequent criticisms of the Nova criteria, which lack the specificity required to consistently classify foods without subjective interpretation.

Observational research has associated diets high in UPFs with noncommunicable diseases, obesity, and negative mental health outcomes, including anxiety and depression. However, the Commission characterized the science as an evolving field and said environmental and social effects of UPFs appear to be less well understood.

The Functional Importance of Food Processing

The paper also emphasized that food processing itself serves important functions. Processing can improve microbiological safety, remove toxins, extend shelf life, increase nutrient bioavailability, enable fortification, and reduce food waste and domestic labor burdens. At the same time, newer processing technologies can be used to create highly shelf-stable formulations and alter sensory characteristics, raising questions about possible effects on human, animal, and planetary health.

UPF Consumption Varies Across the EU

According to evidence cited by the Commission, the percentage of total energy intake derived from Nova-defined UPFs varies considerably across Europe. UPFs account for less than 25 percent of energy intake in some southern European countries, including Italy, Cyprus, Greece, and Portugal, but exceed 35 percent in the Netherlands and Germany and reach approximately 40 percent in Sweden.

The Commission also pointed to socioeconomic disparities associated with UPF consumption. Research cited in the paper has linked higher UPF intake with lower socioeconomic and parental educational status, while other evidence has associated food insecurity with a greater likelihood of meeting criteria for what researchers termed “UPF addiction.”

Existing EU Food Safety Rules and Potential UPF Policy

The paper framed UPFs as an issue extending beyond nutrition and public health. Potential policy considerations identified by the Commission included food safety, agriculture, industry and trade, consumer protection and autonomy, social justice, environmental sustainability, animal welfare, biodiversity, packaging, and food waste.

Although the EU does not specifically regulate UPFs as a category, existing legislation already governs many aspects of foods that could fall under UPF classifications. For example, the EU General Food Law establishes the overarching legal framework for food safety and provides for risk management measures ranging from consumer information to product bans and withdrawals. Separate regulations govern food additives, flavorings, contaminants, and food contact materials.

The Commission's Safe Hearts Plan could provide a more direct pathway for UPF-related policy. One initiative calls for work toward a “comprehensive food processing assessment system” intended to provide consumers with science-based information about food processing. Another calls for examining potential tools, including financial actions, to support disease prevention, food reformulation, and healthier consumer choices. The latter initiative is explicitly intended to draw on the forthcoming scientific and ethical advice.