dementia, anxiety depression, cancers, and early death from all causes (7,8). It has equalled or overtaken tobacco as the leading cause of early death globally and in the UK it is a close second (6).

This pandemic of diet related disease which has engulfed the UK is not just an accidental side effect of our food system; it is the necessary result. Most of our calories now come from companies with obligations to deliver relentless growth to their owners. This requires the use of the cheapest ingredients and the most hyperpalatable formulations.

When it comes to regulation we need to consider the seriousness of the situation we are in. It is not only morally indefensible to allow human suffering on such a scale, but also economically absurd. An analysis by Frontier Economics, commissioned by the Tony Blair Institute, found that Britain’s weight problem costs £98 billion a year, equivalent to almost 4 per cent of gross domestic product (GDP) and of which, costs the health service £19 billion a year (9) without accounting for the intangible cost on quality of life and workplace sickness.

We also need to consider the absolute failure of the current approach which has favoured partnering with the food industry. This means that we have no functional restrictions on marketing or sale of unhealthy food in this country.

Despite the government suggesting a 9pm watershed ban on TV and online junk food advertising in July 2020 as part of the Obesity Strategy, this still has not been actioned (expected October 2025). Furthermore, there are concerns that the suggested plans are ‘watered down’ and has loophole which the food industry can easily get around e.g., companies will be able to continue using ads if they use generic pictures of pizza, burgers and other HFSS foods and not images of their foods.

This means that my children and I are exposed to a deluge of food advertising on social media, television, billboards, and in shops. Products are marketed by athletes and influencers, using games, toys and cartoon characters. My children age 3 and 6 can buy almost any food or drink without restriction. By contrast they have never even seen a cigarette advertisement nor a pack of cigarettes.

These facts should encourage us to create bold and novel policy using the best evidence which is currently more than sufficient for proposing action without any delay.

All policies must acknowledge that for many people the industrially processed products linked to harm are the only affordable, available food for those most vulnerable in our society, such as those experiencing food insecurity, and must seek to reduce health inequalities.

I propose three necessary but insufficient first steps taken from successful approaches to tobacco control. There are valid comparisons between the companies that make UPF and tobacco companies in terms of incentives, actions and regulatory approaches. Diet related diseases are fundamentally “commerciogenic”: caused by the marketing and consumption of industrially processed food just as a pandemic of lung disease was caused by the marketing and consumption of cigarettes. Any approach that fails to acknowledge this fact will fail to curb the problem.

I propose that we

1. end conflicts of interest between the food industry and the government’s Scientific Advisory Committee on Nutrition.

2. apply mandatory warning labels to food high in saturated fat, sugar and salt using existing UK Dietary Recommendations.

3. put a warning in our national nutrition guidance about avoiding UPF using the Nova 4 definition.

This submission will provide evidence and justification for these proposals.

Proposal 1: Ending Conflicts of Interest.

The most important characteristic of any policy approach is that there must be financial separation between regulators and those who are regulated. Regulators include policymakers and designated regulatory agencies but also de facto regulators; charities, politicians, academics, clinicians and activists who inform policy. All of these groups must understand the constraints and incentives of the food industry. In some cases they should meet industry representatives and seek advice from industry. But there can be no financial relationships. This was a crucial first step with tobacco control.

Dissenting opinions are the engine of scientific progress, but there are areas of science where industry linked voices are rightly excluded from public debate. Tobacco funded scientists created doubt and delayed progress in tobacco control very effectively until they were excluded. The food industry is doing the same thing today.

If the proposal to limit the influence of industry funded scientists seems extreme it should be considered in the context of the health crisis we are in and the huge influence that industry currently has over the way we think about diet and health.

They fund charities, academic research groups, individual academics, social medica influencers, doctors and members of the government’s Scientific Advisory Committee on Nutrition (SACN). These institutions and individuals give legitimacy to views that are critical of nutrition evidence that favour industry and harm public health. This is especially true recently with the evidence that UPF causes health harms.

Consistent with this, it is striking that the debate around Ultra-Processed Food has become polarised by conflicts of interest: the main voices questioning the evidence are funded by the companies that make UPF.

These include (10).

- The Science Media Centre (SMC), funded by Proctor and Gamble, Nestle and Food Drink Europe.

- The British Nutrition Foundation (BNF), funded by many of the major UPF producers including funded by Coca-Cola, Nestlé, Mondelēz, PepsiCo, Mars, Danone, Kerry, Cargill, McDonald’s and others.

- Members of the government’s Scientific Advisory Committee on Nutrition (SACN). Around half of the members of this committee have declared conflicts with industry institutions including the British Nutrition Foundation, the American Society for Nutrition (funders include Mars, Nestlé and Mondelēz), Cargill, the meat industry, the dairy industry, CBC Israel (make and market Coca-Cola and Sprite, among other fizzy drinks ), Tate & Lyle, Sainsbury’s and Danone, and a member of the Subgroup on Maternal and Child Nutrition has links with Nestlé.

- The nutrition department at Reading University, which has received significant recent funding from Mars, PepsiCo and Roquette Freres.

Why industry can’t be partners in changing the system.

The companies that grow, supply, process and sell most of our food are owned to varying degrees by large institutional investors who, understandably, prioritise returns over all other concerns especially public health and the environment. Whilst many of the companies make sincere efforts to improve their product portfolios the food environment in the UK, that they create and lobby to maintain, is damaging to population health.

A 2023 paper published by colleagues in Australia used financial data to show that the largest food companies spend revenue on share buybacks and dividend pay outs whilst institutional investors vote down public health proposals at board level(11). Nestle have as their strapline “Good Food, Good Life” even as they release KitKat cereal as an addition to a product portfolio that is, by any definition of unhealthy food, extremely unhealthy – 75% of global sales come from unhealthy products (12). Coca Cola claim to be dedicated to creating “A World Without Waste” even as they are consistently found to be the world’s leading plastic polluter year after year. The paper tested these extravagant claims common on food company websites that they care about plastic, carbon emissions and human health and found them to be false.

Even the senior management are unable to improve things if doing so might negatively impact profit. Emmanuel Faber, was a poster CEO for ESG (i.e. environmental, social and governance) objectives. He tried to lead a revolution within Danone, making it the first company to legally dump the primacy of shareholders in place of other objectives around protecting the environment, their employees and suppliers. A public campaign was launched by Bluebell Capital and Faber lost his job in March 2021(13) These obligations to investors are not different to those that confine companies in other sectors and understanding them is crucial because it shows that companies cannot be partners in change.

Regulations that will improve public health are incompatible with their current business models – there is no more alignment of agendas between the aims of those who wish to limit the harm and suffering that comes from diet related disease and the transnational food giants that profit from causing it, than there is between those who wish to reduce rates of lung cancer and tobacco companies,

How industry buys influence: press reports on UPF - a case study.

In September 2023 a series of headlines appeared in all the major national papers questioning the research around Ultra-Processed Food. ‘Is ultra-processed food bad for you?’ in the Times. ‘10 ultra- processed foods that are actually good for you.’ in the Independent.

New Scientist magazine ran an article titled ‘Ultra-processed food isn’t always unhealthy, say UK food officials,’ which began like this: ‘UK officials have dismissed recent concerns that highly processed food, also known as ultra-processed food (UPF), is automatically unhealthy because of the way that it is made or its artificial ingredients.’

The stories followed a press conference held the previous day at which five scientists said that the science around UPF ‘cannot show cause and effect’ and that some items classed as UPF were foods that should be encouraged, such as wholemeal bread, wholegrain breakfast cereals, and yoghurts.

Four out of the five speakers had had significant relationships with companies that make UPF. One was on the scientific advisory council for Kerry Group (a multi-billion-dollar manufacturer of UPF) chair of the advisory committee of the industry funded British Nutrition Foundation, one had previous research funding from Unilever and the Sugar Bureau and one had previous research funding Unilever, Mondelēz and Nestlé (10,14,15).

And although two of the five scientists were UK government officials, this wasn’t a press conference held by a government agency – it was held by something called the Science Media Centre (SMC), a press office that claims to provide accurate information about science for the public and policymakers through the media. It’s hard to overstate the SMC’s influence over public discourse around science in the UK: many, perhaps most, of the science stories you read in the press will have come from the SMC.

The SMC claims that it is ‘completely independent in both our governance and funding’. But a subsequent British Medical Journal investigation revealed that the SMC is funded by many of the industries it reports on, including by a food industry body, FoodDrinkEurope (whose members include Cargill, Coca-Cola, Danone and Mars), as well as Nestlé and Proctor & Gamble (manufacturers of Pringles amongst other UPF) (10). The SMC has also previously received direct funding from Tate & Lyle, Northern Foods, Kraft Foods and Coca-Cola.

Many of the academics who are quoted on the SMC website have industry funding. Over the past two years, up to the time of writing, the SMC has produced responses to sixteen published scientific papers about UPF. Over 70 per cent of the comments are from ‘experts’ with ongoing or previous financial relationships with companies that make UPF. Many of these scientists fail to declare these conflicts.

The British Nutrition Foundation

One of the scientists who spoke at the press conference was the chair of the advisory committee of the British Nutrition Foundation (BNF) and many of the scientists used by the SMC and who are quoted in stories about UPF also work with the BNF. This is a ‘public-facing charity which exists to give people, educators and organisations access to reliable information on nutrition’. It describes itself as a ‘sounding board for policy development’ and has held contracts with numerous government departments, focusing on nutrition policy, communications and school food education. Members of it sit on government advisory groups. The BNF is majority funded by ultra-processed food companies including Coca-Cola, Nestlé, Mondelēz, PepsiCo, Mars, Danone, Kerry and Cargill. In 2023 their healthy eating week was funded by Coca Cola amongst others (16).

SACN

One of the scientists who spoke at the press conference seemed especially credible as they were a member of SACN. This body advises the government on nutrition and related health matters. Around half of the members of this committee have declared conflicts with industry institutions including the British Nutrition Foundation (funded by Coca-Cola, Nestlé, Mondelēz, PepsiCo, Mars, Danone, Kerry, Cargill and others), the American Society for Nutrition (whose funders include Mars, Nestlé and Mondelēz), Cargill, the meat industry, the dairy industry, CBC Israel (they make and market Coca-Cola and Sprite, among other fizzy drinks ), Tate & Lyle, Sainsbury’s and Danone, and a member of the Subgroup on Maternal and Child Nutrition has links with Nestlé (17).

How Industry Influence Research Outcomes

Many of the scientists quoted by the SMC and who partner with the BNF are industry funded or work for industry funded institutions. Scientists from the University of Reading were mentioned in the BMJ investigation of the press conference and a freedom of information request revealed that the nutrition department has three main industry funders, all of whom make UPF: Mars, PepsiCo and Roquette Frères. Between 2018 and 2023, Mars has given £262,832 in research funding to the department.

This type of research funding distorts our understanding of health and medicine.

There are many studies showing that industry-funded science is more likely to find results that are beneficial to industry than is independently funded research across different sectors including tobacco, alcohol and pharmaceuticals(18–22).

The effects of industrial influence extend beyond bad faith actors deliberately sowing confusion; unconscious bias may be just as important. Additionally, when an industry funds science they choose the research agenda, determine what questions get asked, how results are interpreted, and which values and narratives are perpetuated. Industry funds research conducive to its commercial interests, framing research agendas and methodologies to produce desired results.

A useful example is a 2016 review (23) of the evidence that sugar-sweetened beverages are linked to weight gain and obesity. Of the thirty-four studies in the review that showed a link between sugar- sweetened beverages and obesity and type 2 diabetes, thirty-three – or 97 per cent – were independent (i.e. not funded by the food and beverage industry).

By contrast, of the twenty-six studies that suggested there was no link, twenty-five were funded by industry – including Coca-Cola, PepsiCo, Dr Pepper Snapple Group Tate & Lyle and other companies that make money from sugary drinks. So, 96 per cent of industry-funded studies suggested that drinking soft drinks is fine, meaning that independent studies were thirty-three times more likely to link sugary drinks with harm. We find similar patterns across all of science. Industry funding creates bias – which we might also call corruption.

The importance of eliminating conflicts in SACN

It would be impossible to mandate that charities and universities refuse industry funding, though they should disengage from major UPF and junk food manufacturers as UNICEF have (see below). However it should be very achievable to require that SACN is conflict free. This would set a cultural precedent that might encourage other institutions to do the same, and would bring UK government dietary advice in line with governments around the world that have taken a stronger regulatory approach including France, Belgium and many governments in South and Central America (see below).

Some on the committee have already made the argument that this would limit the talent available. These are the same arguments used to exclude women and minority groups from positions of power. They have no validity. There are a huge number of exceptionally talented scientists who are independent of industry. A more junior unconflicted committee would make less biased and more credible decisions than a conflicted group of experts.

As well as limiting the access of industry funded scientists to influence policy we must increase government / public funding for research that would make it easier for scientists to be conflict free.

The UNICEF policy is the the simplest distillation of how all policymakers and regulators should interact with the food industry:

UNICEF will avoid all partnerships with ultra-processed food and beverage (UPF) industries. To preserve our thought and action leadership, align with our programming strategies, and maintain our credibility as a trusted advisor for public policy, normative guidance, and programme implementation for children, UNICEF will avoid all forms of financial and non-financial partnerships and collaborations with the UPF industry. This includes individual companies as well as associations, platforms, and front groups representing UPF industries and their interests (24).

Proposal 2: Mandatory Warning Labels – the first step in regulation

How should we define harmful food?

The way we define unhealthy food for research may be different to the way we define it for consumer advice, which in turn, may be different to a definition used in legislation around marketing restrictions. In the UK we have four complex, confusing and occasionally contradictory definitions of unhealthy food used by various groups from scientists to consumers.

1. UK Dietary Recommendations

2. Traffic Lights

3. Ofcom HFSS

4. UPF

I propose that we can use UK Dietary Recommendations in combination with the evidence that salt, sugar, saturated fat and UPF are harmful to create robust regulation.

1. UK Dietary Recommendations - evidence

The UK dietary recommendations (25) are robust and internationally aligned. They set out well evidenced recommended intakes for macro and micronutrients based on high quality evidence. They’re objective and clear but in practical terms invisible to consumers and complex to use. People don’t eat to numbers nor keep track of their food very well so knowing that, for example, only 5% of your calorie intake should be from free sugars is not useful for people.

2. Traffic Lights - evidence

We have a system of voluntary traffic lights on packaged goods which display four traffic lights which may be red, amber or green depending on the quantities of saturated fat, sugars, sodium and fibre.

The traffic lights do not use UK Dietary Recommendations. For example 17% of the calories in Kellogg’s Coco Pops come from free sugar – more than three times the recommended amount – yet there is only an amber traffic light for sugar. 20% of the calories in Heinz Baked Beans come from sugar and, per calorie they have three times more salt than guidance recommends as a maximum. Yet, confusingly, there is a green light for sugar and an amber for salt.

Coca Cola voluntarily put the traffic lights on their cans of Cola which should be a clue that perhaps it is not an effective labelling system. A can of high sugar coke - a product which really is almost purely harmful - gets three green traffic lights and a single red (the red is invisible against the red can of course).Meanwhile a can of diet Cola (a mixture of non-nutritive sweeteners, an addictive drug caffeine and phosphoric acid) gets four green traffic lights. What is signalled to the consumer is that this is not just harmless but positively beneficial for health.

Traffic lights do not change consumer behaviour in other countries (26), and it has failed to arrest the spread of diet related disease in the UK. I propose below however, that mandatory traffic lights could be a step toward introducing more robust front of pack warning labels as used in Latin America.

3. Ofcom HFSS - evidence

Whether a food is “HFSS” is calculated using a Nutrient Profile Model (the UK NPM 2004/5) developed by the Food Standards Agency (FSA) as a tool to enable the Office of Communications (Ofcom), the UK broadcast regulator, to identify ‘less healthy’ foods and drinks that were to be subject to restrictions during children’s television programming. The nutrient model is almost 20 years old and no longer reflects current UK dietary recommendations, in particular those for free sugars and fibre.

It is also not applicable to products marketed for infants and young children (the under 3s), which remain largely unregulated with respect to nutrition composition, labelling and marketing (traffic lights also not applicable).

Ofcom has been using this model for broadcast media since the restrictions came into force in April 2007 (and for non-broadcast media including print, cinema, online and in social media since 2017). Over this period there has been a significant increase in the rates of diet related disease along with a huge proliferation and change in product variety, composition and marketing platform.

It might be expected that HFSS was a simple definition describing packaged foods which exceed recommended levels of fat, sugar and salt according to UK dietary recommendations. Determining HFSS status requires a complex calculation so that a product could be high in salt and sugar and yet not be defined as HFSS if there were other ingredients (fruit and vegetable content, fibre or protein) which improved the score.

This definition is complex and aspects of it are arbitrary (there are rules such as, if a food or drink scores 11 or more ‘A’ points then it cannot score points for protein unless it also scores 5 points for fruit, vegetables and nuts). It divides food into two binary groups and there is little or no research that investigates whether “less healthy food” as defined by Ofcom is in fact associated with negative health outcomes. Additionally there are many foods which have excessive salt, sugar or fat according to dietary recommendations and which are UPF but which escape HFSS designation. For example Coco Pops and Frubes both have excess sugar and salt and are UPF but are not HFSS.

4. Ultra-Processed Food - evidence

The definition UPF was created in 2009 to test a hypothesis – that it was an influx of industrially processed foods that was causing an epidemic of diet related disease in Brazil. For a food to meet the definition it must be made using ingredients and processes exclusive to industrial production. These ingredients and processed are used for a reason – “to create highly profitable products (low-cost ingredients, long shelf-life, powerfully branded, convenient) for transnational corporations that use “pervasive advertising and promotion” to create “market advantages.”

Ultra-processing is very different to processing. Humans are “obligate processivores” – we must process our food. We’ve been grinding, pounding, fermenting, drying, salting, and cooking food for hundreds of millenia. Our bodies bear witness to the long history of food processing in the number of genes we have for enzymes to digest starch, milk, sugar and alcohol, and in the size of our eating apparatus: our teeth, jaws and gut are tiny compared to other mammals.

Ultra-processed food is designed, produced and marketed to drive financial growth – it is this principle that means that every facet of every product is optimised to increase consumption and reduce costs to the producer/retailer.

The definition UPF (27) has proved to be an extremely powerful research tool for hundreds of studies conducted by independent research groups worldwide. We now have a large body of evidence linking a dietary pattern high in UPF to negative health outcomes.

The Bradford Hill criteria are the most frequently cited framework for causal inference in epidemiologic studies (28) and comprise nine “aspects of causation”: strength of association, consistency, specificity, temporality, biological gradient, plausibility, coherence, experiment, and analogy. Using these criteria UPF meets the threshold for causality.

Strength and consistency of association are the first two criteria. A PubMed search identified multiple epidemiologic studies (32 systematic reviews or meta-analyses) using a variety of locations, populations, and methods that show a consistent association between UPF and multiple negative health outcomes with respect to the null hypothesis including

Obesity
T2D
Cancer
CVD
non-alcoholic fatty liver disease (NAFLD) (now Metabolic Dysfunction-Associated Steatotic Liver Disease (MASLD))
Dementia
All-cause mortality.

The association is specific (in the sense of there have been large sudden population exposures in Latin America following the North American Free Trade Agreement), temporal (population health changes following exposure) and there is a dose response relationship seen between UPF and harm (29).

In terms of plausibility and coherence it is reasonable to turn the question around - is it plausible that industrially processed foods made to create financial growth for institutional investors would NOT cause, for example, weight gain or drive increased intake?

Evidence drawn from experimental studies may lead to the strongest support for causal inference. As well as the much discussed randomised controlled trial conducted by Kevin Hall(30) there are more than one thousand clinical and pre-clinical studies on properties and additives unique to UPF linking them to negative health outcomes in humans and animals. These include studies on food texture (softness) (30–32), energy density (33) and additives including emulsifiers(34–40), non-nutritive sweeteners(41–44), plastics (8).

Additionally many ultra-processed foods meet the criteria of addictive substances using the standards set for tobacco products (45). The addictive potential of ultra-processed foods is commonly amplified by aggressive marketing strategies including super-size meal deals, advertising slogans that explicitly encourage overconsumption (‘I Bet You Can’t Eat Just One’, ‘Once You Pop You Can't Stop’), and brand names such as ‘Krave’. This marketing is exclusive to ultra-processed foods and is associated with significant increases in UPF intake and purchase requests (8).

Much of the discussion around UPF focuses on whether it is merely salty, fatty sugary food and whether the “processing” makes any difference. Most of the epidemiologic evidence has made adjustments for nutritional content of food and whilst these are imperfect in almost all cases the association with the negative health outcome remains unchanged in both significance and magnitude (29).

But trying to disentangle the effect of fat, salt and sugar is to misunderstand the relationship between nutrients and processing. Using large quantities and particular ratios of fat, salt and sugar are some of the ways in which the food industry drive excess consumption and this is why the vast majority of UPF in the UK exceeds UK guideline amounts (46). Modelling with colleagues from the Pan American Health Organisation (PAHO - unpublished) shows that using UK dietary guidance we can identify >95% of UPF as being high in at least one of saturated fat, total fat, sugar, salt or trans fats.

A recent BMJ meta-analysis (7) brought together much of the epidemiology. Industry funded commentators have pointed out that much of it is rated as “low quality”. This is because of the formal way we grade evidence using the GRADE (Grading of Recommendations, Assessment, Development, and Evaluation) system - a systematic approach to rating the certainty of evidence in systematic reviews and other evidence syntheses (47). The GRADE approach initially considers all observational studies as evidence of “low quality” - 22 pooled analyses were rated as low quality, with 19 rated as very low quality and four rated as moderate quality. This form of critique has been used before by industry funded scientists (48,49) and using the GRADE system all the epidemiologic evidence linking smoking to cancer would have been initially graded as low quality or very low quality.

Limitations of the evidence around UPF.

The evidence around UPF describes a dietary pattern and whilst there is value in understanding which UPFs are driving most associations with poor health outcomes, the degree to which “worse” or “better” products can be disentangled is missing the main issue of UPFs. The issue is the ultra-processed food system in general.

Although some groups have attempted subgroup analyses their results are more plausibly explained as methodological artefacts than as indicator that a particular UPF group is protective(50). A WHO funded study(51) was reported in the Guardian as showing “Some ultra-processed foods are good for your health, WHO-backed study finds”(52). The report claimed that ultra-processed bread and cereals reduce the risk of developing cancer, heart disease and diabetes.

I corresponded with the authors of this study who disagreed with the press report. The study had not compared UPF bread with non-UPF bread. Rather it was saying that the harms associated with a higher proportion of total UPF in the diet were less driven by the subgroup of UPF bread. This means that a higher proportion of UPF breads in the context of a UPF diet, can attenuate some of the detrimental associations of UPF overall. It doesn’t mean that UPF bread is better than non-UPF bread or other non- UPF food of any kind.

UPF is not a regulatory tool

The main weakness of the UPF definition is that it was not designed as a regulatory tool. The evidence tells us the category and the corporations that we should try to regulate. It tells us why the approaches we have been using have failed, but for regulation we need a different approach for two reasons.

1. If we try to label individual products using the research definition, industry will protest about every one of the thousands of additives which they might argue are not of exclusively industrial use. We see for example that in research setting the ingredient Xanthan gum would qualify a food as being UPF but it is also sold as an ingredient for home baking for coeliac disease and the food industry could credibly claim that this makes it a typical domestic additive.

2. The second problem is that UPF has a loophole. The scientists in Brazil were trying to describe a group of products that were different to the current landscape in the UK, which has a significant proportion of “clean label” UPF. Commercial baby foods are perhaps the most important examples of foods with poor nutrient profile and for adults products like M&S Lasagne or Heinz Organic Baked Beans are not technically UPF but they are designed by the same product development teams with the same incentives by the same companies. (Indeed many of the ingredient companies now have “clean label” departments aimed at circumventing UPF legislation (53).) These products are high in fat salt and sugar and have many of the other UPF properties that potentially drive harm and excess consumption. They should be regulated.

An approach that uses existing dietary guidance to apply warning labels to food solves these problems.

Octagonal Warning Labels with UK Dietary Recommendations

Octagonal stop signs have been used with great effect across South and Central America as the cornerstone of food regulation(26,54–57).

Octagons force a definition of harmful food that is robust and evidenced based. Using dietary recommendations for calories, salt, free sugar, and saturated fat allow the creation of definition.

Once a product has a warning label other regulatory approaches can be applied to these products. The most harmful products (those excessive in saturated fat, totally fat, salt and sugar) can be taxed and any product with an octagon is restricted when it comes to making health claims or being marketed to children. As new evidence emerges for example around synthetic emulsifiers or non-nutritive sweeteners, more warning labels can be added.

This graphic shows the widespread adoption and the countries like Ecuador which adopted traffic lights instead.

A map of the south america

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Early evaluation data from Chile show that these labels switch purchases not simply to food with fewer octagons but to whole and minimally processed food instead (26,55,56).

This simple nutrient profile below is based on UK dietary guidance and using this 95.1% (95%CI 94.0- 96.1) of ultra-processed products would be required to feature at least one warning label (sugar, total fat, saturated fat, trans fat, and/or sodium) with a maximum of five warning labels. Unprocessed foods, minimally processed foods and culinary ingredients would not be subject to the application of these criteria.

I suggest that all processed products (according to the UK existing definitions in legislation) with harmful nutrient profiles according to UK dietary recommendations should have warning labels. Nutrient thresholds urgently need to be defined for under 3’s – First Steps Nutrition are a resource for more on this.

Importantly this model uses the percentage of energy that comes sugars and fats rather than a weight. Since there is wide agreement about the proportion of energy that should come from sugars and wide agreement about recommended calorie intake this gives clear thresholds for warning label application. Salt again is determined per calorie.

If ≥5% of the product’s energy comes from free sugars the product should feature an EXCESS SUGAR front-of-pack warning label)
If ≥2.25% of the product’s energy comes from trans fats it should feature an EXCESS TRANS FAT front-of-pack warning label
If ≥11% of the product’s energy comes from saturated fats it should feature an EXCESS SATURATED FAT front-of-pack warning label)
If ≥35% of the product’s energy comes from total fat it should feature an EXCESS FAT front-of-pack warning label)
If there are ≥1.2mg/kcal of sodium OR >=360mg/100g or ml (if in 100kcal of the product there is 120mg or more of sodium, OR if in 100g of products there is 360mg or more of sodium it should feature an EXCESS SODIUM front-of-pack warning label.

Proposal 3: UPF advice in National Nutrition Guidance

The evidence has more than reached a threshold where it would be safe and sensible to advise reducing the proportion of UPF in the diet according to the NOVA 4 definition (or an agreed simplified version). Canada, France, Israel, Belgium and most South and Central American countries have done this. Simultaneously, guidelines should promote whole and minimally processed foods as the basis of a healthy diet. More of the good, as well as less of the bad.

This guidance should force government to consider why it is that so many of the most disadvantaged people in our country are unable to follow it.

I have put below guidance from other countries. Some of this would be unacceptable/impractical for the UK population but it gives an indication of how cautious we are about giving advice around diet.

Belgium

Choose as few ultra-processed products as possible. UPF has no real added value in a healthy and environmentally responsible diet.

Brazil

Avoid UPF. Always prefer natural or minimally processed foods and freshly made dishes and meals. Do not offer UPF to children.

Canada

Limit highly processed foods and drinks because they are not part of a healthy eating pattern. If you eat highly processed foods, try to:

• eat them less often

• eat them in small amounts

• replace them with healthier options.

Ecuador

Avoid the consumption of UPF.

Israel

Reduce the consumption of UPF as much as possible. Avoid processed, industrialised and packaged foods as much as possible. There is no need to buy food made especially for children and babies.

Mexico

Avoid UPF. UPF promotes preference for very sweet or salty flavours, and increases the risk of both obesity and malnutrition.

Peru

Avoid the consumption of UPF.

Uruguay

Base your diet on natural foods and avoid the regular consumption of ultra-processed products with excessive contents of fat, sugar and salt.

I’ll end on the French guidance which is stylish and clear.

France

Limit sugary drinks, fatty, sweet, salty and ultra-processed foods. Avoid giving ultra-processed products to under-threes. Avoid giving commercial baby foods and ready meals to under-threes.

I especially love this quote from the French guidance:

‘Pour varier les goûts et les textures, le fait maison a tout bon . . . Plus de goûts, plus de textures, plus de miam!’

This translates roughly as

‘To vary tastes and textures, home-made food includes everything good . . . More tastes, more textures, more yum!’

2 May 2024

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DR CHRIS VAN TULLEKEN – SUPPLEMENTARY WRITTEN EVIDENCE (FDO0145)

Introduction