Ultra-Processed Foods (UPFs) have become one of the most debated topics in nutrition science.
Studies have associated diets high in foods classified as ultra-processed with a range of adverse health outcomes, while the NOVA classification has brought the concept firmly into scientific, public-health and consumer conversations.
Yet translating this evidence into policy is far from straightforward.
What exactly makes a food “ultra-processed”? Is it the number or type of processing steps? Its nutritional composition? The presence of particular ingredients or additives? Its energy density? Or the way it is consumed within the overall diet?
These questions are now moving higher up the European policy agenda.
In July 2026, the European Commission published its scoping paper, “Scientific and ethical assessment of ultra-processed food consumption and recommendations for related policies in the EU.”
Rather than assuming that existing UPF classifications provide the answer, the Commission is asking its scientific advisers to examine the evidence—and determine whether sufficiently meaningful and specific criteria can be developed to support future policymaking.
For the food industry, this could mark an important evolution in the UPF debate.
From scientific debate to policy question
The new work sits within a broader EU policy context, including the Safe Hearts Plan, the Vision for Agriculture and Food and the Strategy for European Life Sciences.
The Commission has asked its Group of Chief Scientific Advisors (GCSA) to address a central question: what scientific considerations should underpin EU policies aimed at fostering healthier diets, given what is currently known about the health effects of consuming so-called UPFs?
To answer that, the advisers have been asked to investigate several fundamental issues.
These include the prominent definitions and classifications of UPFs and whether they could provide an appropriate and effective basis for policymaking; the current scientific evidence concerning health effects; patterns of UPF consumption across the EU; and, importantly, the criteria or markers that might allow the health effects of these foods to be assessed more meaningfully.
That last question may prove particularly significant.
Beyond a single UPF label?
One of the most interesting aspects of the scoping paper is the range of characteristics the Commission wants its scientific advisers to consider.
The paper does not restrict the assessment to whether a food falls within an existing UPF category.
Instead, potential criteria and markers include:
- the degree and type of ultra-processing;
- energy density;
- nutrient composition;
- ingredients, including food additives and flavourings;
- portion size and consumption frequency; and
- the contribution individual foods make to essential nutrient intake and dietary recommendations.
This could signal a potentially more multidimensional way of thinking about the issue.
Rather than assuming that the degree of processing alone determines a food’s health impact, the mandate asks advisers to examine processing alongside nutritional composition, ingredients and how foods are actually consumed.
For nutrition science—and potentially for food policy—that distinction matters.
Is NOVA enough for policymaking?
The NOVA classification has played a central role in UPF research. It has provided researchers with a framework for examining associations between food processing and health and has helped bring attention to changes in modern food systems.
But a research classification and a regulatory tool do not necessarily need to perform the same function.
The Commission is therefore explicitly asking whether prominent UPF definitions and classifications can constitute an appropriate and effective basis for policymaking.
That opens the door to a more fundamental examination of what policymakers actually need from a UPF framework.
A policy tool needs criteria that can be consistently identified, measured and applied. It also needs to distinguish between foods in a way that is meaningful for health.
And this is where the UPF debate becomes particularly complex.
Food processing itself is not inherently negative. As the Commission’s Scientific Advice Mechanism notes, processing can improve food safety, shelf life and even nutrient availability. Modern processing technologies can also make foods more accessible, convenient and stable.
The scientific challenge is therefore not simply to determine whether a food has been processed, but to understand which characteristics of foods or types of processing may contribute to health effects—and under what circumstances.
Why the food matrix and dietary context matter
The scoping paper’s inclusion of nutrient composition, energy density, portion size, consumption frequency and essential nutrient contribution is particularly noteworthy.
It recognises that foods do not exist in isolation.
Two foods classified within the same broad processing category may differ considerably in their nutritional composition and in the role they play within the diet.
Similarly, frequency and quantity matter. A food eaten several times each day may have a very different impact on dietary intake from the same food consumed occasionally.
This is why the Commission is asking for criteria or markers that are sufficiently specific not only to help consumers shift towards healthier diets but also potentially to inform national or EU public-health measures.
The challenge will be identifying which characteristics provide meaningful additional information beyond the nutrition metrics already used in public-health policy.
What could this mean for food innovation and reformulation?
For food manufacturers, this is perhaps the most important question.
If future European policy moves towards assessing foods through a combination of processing, nutritional composition, ingredients, energy density, portion size and dietary contribution, reformulation strategies could become more multidimensional.
Traditionally, reformulation has often concentrated on specific nutrients: reducing salt, sugars or saturated fat, increasing fibre or improving nutrient density.
The emerging UPF discussion potentially introduces additional questions.
Could the purpose and extent of processing become relevant? Could ingredient choices matter differently? How should additives be considered? Should portion architecture form part of the discussion? And how should products that make a meaningful contribution to essential nutrient intake be treated?
There are no definitive answers yet—and the scoping paper should not be interpreted as establishing them.
Instead, these are precisely the questions the Commission is asking its advisers to investigate.
That makes March 2027, when the GCSA’s scientific advice is expected, an important milestone to watch.
The debate is also becoming bigger than nutrition
There is another important dimension to the Commission’s approach.
Alongside the scientific assessment, the European Group on Ethics in Science and New Technologies (EGE) has been asked to examine the wider ethical and societal implications of UPFs.
Its mandate extends into issues including access to adequate and nutritious food, consumer autonomy, social justice, corporate responsibility, economic dimensions of food environments, animal welfare and environmental impacts.
This broadens the debate considerably.
UPFs are increasingly being considered not only as a question of nutritional composition or processing technology, but as part of a wider discussion about food systems, affordability, consumer choice, health inequalities and sustainability.
For companies operating within Europe’s food system, that wider perspective may ultimately prove just as important as the scientific definition itself.
What happens next?
The publication of the scoping paper is the beginning of the scientific-advice process, not its conclusion.
The Group of Chief Scientific Advisors will now consider the evidence, supported by evidence gathering through SAPEA, before providing its scientific advice and policy recommendations. The advice is currently scheduled for March 2027.
What the European Commission ultimately does with that advice remains to be seen.
It could contribute to consumer information, dietary guidance, research priorities or broader public-health policy. Any move towards specific regulation or a formal EU definition would require further policy development; neither has been established by this scoping paper.
For now, however, one thing has changed:
UPFs are no longer only a scientific and consumer debate. They are becoming a structured European policy question.
The Nutricomms Perspective
At Nutricomms, we see the Commission’s scoping paper as an important opportunity to bring greater scientific nuance to the UPF conversation.
The particularly interesting development is the move towards examining processing alongside nutritional composition, energy density, ingredients, portion size, consumption frequency and the contribution foods make to nutrient intake. This could help move the discussion beyond binary classifications towards a more comprehensive assessment of foods and their role within the diet.
For the food industry, now is the time to follow the science closely. Future discussions around UPFs could have implications for reformulation, ingredient choices, product innovation, consumer communication and potentially public-health policy.
The challenge will be to ensure that future approaches remain evidence-based and sufficiently specific to support healthier diets—without reducing the complexity of nutrition to a single label.
Reference
- European Commission (2026). Scoping paper: Scientific and ethical assessment of ultra-processed food consumption and recommendations for related policies in the EU. European Commission, Scientific Advice Mechanism, Brussels, July 2026.
