The growing scientific consensus—that Ultra-Processed Food (UPFs) pose a “seismic threat” to global health—is finally translating into decisive policy action, though the global response is still described as “nascent,” akin to where tobacco control was decades ago. The most comprehensive and progressive policies are emerging from Latin America, providing a roadmap for the rest of the world. Firstly I will dig into some South American countries that are taking the lead within the field. And secondly I compare this development with the policies in Europe.Â
🏛️ Current Global Policy Interventions
Governments are deploying a few key strategies to reshape the food environment:
1. Front-of-Package Warning Labels (FOPWL)
This is arguably the most effective and globally influential policy.
The Chilean Model (The Pioneer): Starting in 2016, Chile mandated the use of large, black, octagonal warning labels (often called the “black stop sign”) on the front of packages for foods high in sugar, sodium, saturated fat, and calories. This mandatory system is designed to be highly visible and immediately comprehensible.
The Impact: Studies show this led to a significant decrease in the purchase of products high in the “nutrients of concern,” and a substantial reduction (over 70%) in children’s exposure to regulated food advertising.
The Latin American Wave: Chile’s success inspired a wave of similar policies across the region, including in Mexico, Peru, Uruguay, Argentina, and Colombia. These systems are designed to make the unhealthy choice difficult to ignore, and crucially, they are often linked to marketing restrictions.
2. Marketing Restrictions
Recognizing the power of advertising, particularly on children, many jurisdictions are clamping down.
The Link to FOPWL: In countries like Chile and Mexico, any product bearing a warning label is often prohibited from being advertised to children, using popular mascots, or being sold in schools.
Institutional Bans: Some countries and jurisdictions are moving to ban UPFs entirely from public sector environments, such as schools, hospitals, and government cafeterias. Brazil’s national school food program, for example, is shifting towards requiring 90% of food to be fresh or minimally processed by 2026.
3. Fiscal Measures (Taxes)
Taxes are increasingly used to raise the price of unhealthy products while generating revenue for public health programs.
Sugar-Sweetened Beverage (SSB) Taxes: While not exclusively targeting UPFs, these taxes—now active in over 50 jurisdictions globally—significantly raise the price of one of the most widely consumed UPF categories, namely soda.
Specific UPF Taxes: Calls are growing among public health experts for a broader tax on the manufacturers of UPFs, based on the degree of processing or the presence of specific markers like certain additives, to incentivize reformulation and generate funds to subsidize healthy alternatives.
🇪🇺 Europe’s Approach: The UPF Policy PuzzleÂ
Europe’s response to the challenge of Ultra-Processed Foods (UPFs) is a complex picture, marked by national leadership (particularly in France) and EU-level friction. Unlike the swift, unified approach seen in parts of Latin America, the European strategy is characterized by a voluntary, nutrient-focused system that is currently battling significant industry pressure and internal disagreements over the very definition of “ultra-processed.”
🏛️ Key European Actions Undertaken
European efforts primarily focus on two areas: Front-of-Package Labelling (FOPL) and broader food sustainability goals under the Farm to Fork Strategy.
1. The Dominance of Nutri-Score (FOPL)
Instead of adopting the “black warning label” model used in Latin America (which flags only high-risk nutrients), several major EU countries have embraced the Nutri-Score system:
The System: Nutri-Score is a voluntary, five-colour, letter-based (A to E) system that evaluates the overall nutritional quality of a food product using an algorithm that factors in both positive components (like fiber and protein) and negative components (calories, sugar, fat, and salt). France pioneered its official endorsement, followed by countries like Belgium, Germany, Spain, and the Netherlands. While Nutri-Score is effective at guiding consumers toward nutritionally better choices within a category (e.g., choosing a “B” cereal over a “D” cereal), it does not explicitly flag a food as “ultra-processed” according to the NOVA classification. A nutritionally-fortified UPF (like a diet soda or certain high-fiber packaged breads) might receive a better score (A or B) than a single-ingredient processed food (like pure olive oil), leading to criticism from UPF policy advocates.
2. The Farm to Fork Strategy (Stalled Ambition)
The EU’s overarching strategy for sustainable food systems, the Farm to Fork Strategy (part of the European Green Deal), initially contained ambitious health goals:
Reformulation: Encouraging food manufacturers to reformulate products to reduce salt, sugar, and saturated fats across Europe.
Harmonized FOPL: A commitment to propose a mandatory, harmonized FOPL across the entire EU by 2022 to prevent trade barriers and ensure clarity for all consumers.
UPF Discussion: The strategy opened the door to include food processing, though it stopped short of directly regulating or officially endorsing the NOVA classification across all policies.
The Current Reality: The political momentum for mandatory EU-wide FOPL has stalled due to intense lobbying from the food industry and disagreements among Member States over whether to adopt Nutri-Score or an alternative. The explicit, Europe-wide regulation of UPFs has been effectively sidelined from this key strategy.
3. New Fiscal Measures (Proposed)
There are signs that the EU may be moving toward more direct fiscal intervention, though this is still in the draft stage:
Cardiovascular Health Plan: Recent reports indicate that the European Commission’s draft Cardiovascular Health Plan includes a proposal for EU-wide levies (taxes) on highly processed, high-fat, sugar, and salt foods, and alcopops by 2026.
The Challenge: This proposal, while targeting many UPFs, faces immediate internal and external opposition from the food industry, which argues that taxes are “discriminatory” and may not achieve the intended health improvements.
⚖️ Europe vs. South America on Ultra-Processed FoodÂ
The approaches taken by Europe and several South American nations to combat Ultra-Processed Food consumption represent a fundamental difference in regulatory philosophy: a nutrient-focused, voluntary standard (Europe) versus a processing-focused, mandatory mandate (South America).
Here is a detailed comparison of the two regulatory models based on the actions mentioned:
🔎 Comparison Table: Europe vs. South America
| Policy Feature | Europe (EU/Key Nations: France, Germany) | South America (Key Nations: Chile, Mexico, Uruguay) |
| Regulatory Model | Voluntary, Consensus-Based. Relies on industry participation and Member State agreement. | Mandatory, Top-Down. Imposed by national governments for immediate public health impact. |
| Primary Focus | Nutrients. Targets the final nutrient composition (fat, sugar, salt, protein, fiber). | Processing and Nutrients. Targets the level of processing (NOVA classification) and excess critical nutrients. |
| Key Policy Tool | Nutri-Score (Traffic light system). Uses a letter/color grade (A to E) for overall healthiness. | Front-of-Package Warning Labels (FOPWL). Uses black, octagonal “stop signs” for specific nutrient excesses. |
| Goal of FOPL | To guide consumers toward better choices within a food category. | To force consumers to avoid the product entirely due to high risk, and force manufacturers to reformulate. |
| Marketing Restrictions | Limited and often voluntary (e.g., industry self-regulation). | Mandatory and strict. Products with FOPWLs are often banned from advertising to children and cannot be sold in schools. |
| Stance on UPF (NOVA) | Implicit, not explicit. UPF is not officially integrated or regulated by the EU’s main FOPL (Nutri-Score). | Explicitly embraced. Policies are built on the foundational understanding of the NOVA classification and its link to health outcomes. |
🧠Analysis of Regulatory Philosophies of Ultra-Processed Food
1. Europe: The “Reformulation” Approach
Europe’s strategy, centered on Nutri-Score, is primarily designed to encourage reformulation. The system allows a manufacturer to improve a product’s score by adding fiber or reducing salt, thus incentivizing healthier ingredients within the processed food category.
Strength: It provides granular information and nudges consumers toward nutritionally superior options.
Weakness: By focusing on the final nutrient score, it can grant an “A” or “B” score to an Ultra-Processed Food that is fortified or uses artificial sweeteners, completely obscuring the health risk associated with the processing, additives, and the disrupted food matrix. It prioritizes the health halo over the structural risk.
2. South America: The “Discouragement and Avoidance” Approach
South America’s model, pioneered by Chile, operates on the principle of radical discouragement. The black warning labels are designed to be immediate, undeniable, and universally understood warnings.
Strength: It is highly effective in reducing purchases of targeted products and forces manufacturers to either drop the negative nutrients below the threshold or face severe marketing restrictions. It also addresses the addictive and hyper-palatable nature of UPFs by making the product politically unviable to promote.
Weakness: It provides binary information (good/bad) and does not give consumers granular data on overall nutritional quality, though its goal is simply to direct consumers away from the most harmful products. It prioritizes the public health mandate over subtle consumer guidance.
đź“Š Analysis: What More Has to Be Done
Europe’s current approach is a functional start but lacks the necessary regulatory bite and focus to address the UPF crisis fundamentally.
| Area of Deficiency | Why It’s Insufficient | What More Must Be Done |
| Focus on Nutrients | Nutri-Score and most taxes target nutrients (sugar, fat), not processing. This encourages manufacturers to swap one UPF ingredient for another (e.g., sugar for artificial sweeteners) without improving the food’s structural or additive profile. | Explicitly Adopt NOVA: The EU must integrate the NOVA classification into its dietary guidelines and regulatory assessments to target the degree of processing itself, not just the final nutrient score. |
| Lack of Mandatory FOPL | The current voluntary nature of FOPL (Nutri-Score) allows manufacturers to selectively apply the label only to products that score well, minimizing its public health impact and allowing trade barriers to persist. | Implement Mandatory FOPL: Make a single, highly visible FOPL system (whether warning labels or Nutri-Score) mandatory across all EU Member States to ensure consistency and prevent evasion. |
| Corporate Lobbying | Strong food industry lobbying successfully pressures the EU to rely on “self-regulation” and voluntary agreements, stalling initiatives under the Farm to Fork Strategy. | Protect Public Health Policy: Implement protocols to safeguard policymakers from conflicts of interest, and impose mandatory regulations rather than relying on the industry to police itself. |
| Affordability of Healthy Food | UPFs are engineered to be the cheapest source of calories, making them the default choice for low-income families, despite their health risks. | Rebalance Incentives: Use revenue from UPF taxes to subsidize the cost of fruits, vegetables, and minimally processed staples (e.g., VAT reduction) to make the healthy choice the easy and affordable choice for all Europeans. |
In summary, Europe has the analytical tools and the national commitment (France/Nutri-Score), but it has yet to overcome the political and economic hurdles necessary to implement a mandatory, EU-wide policy that tackles the core problem: the industrial engineering of food for profit over health. The next major step is to shift the policy debate from what nutrients are in the food to how the food is made.
🛑 Conclusion: Policy Effectiveness
The evidence strongly suggests that the mandatory, processing-focused approach of South America has been more effective in rapidly altering consumption behavior and forcing industry change.
By explicitly linking mandatory warning labels to strict marketing restrictions (e.g., banning a cartoon mascot if the cereal has a black stop sign), these nations have successfully countered the industry’s ability to market addictive products to children. Europe, by maintaining a voluntary, nutrient-focused system, remains highly susceptible to industry lobbying and risks overlooking the fundamental health issues stemming from the degree of industrial processing itself.
Written by
LarsGoran Bostrom
More about ultra-processed food
The Engineered Crisis: Why Ultra-Processed Food is the New Public Health Target Part 1
Hidden Ingredients, Big Consequences: The Impact of UPF Additives Part 2
 The Corporate Playbook: How Ultra-Processed Food is Marketed to Our Kids Part 3
Sources:
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