Ultra-processed foods in research and policy.
Summary
Ultra-processed foods in research and policy The Lancet 2026 Correspondence classified as ultra-processed foods in 4 Monteiro CA, Cannon G, Moubarac J-C, in 2033.6 The tax reform uses the panel 1 of the Review. We respectfully Levy RB, Louzada MLC, Jaime PC. The UN National Food Basket’s criteria to decade of nutrition, the NOVA food disagree with this classification and classification and the trouble with ultra- ensure a zero-tax rate for fresh and request a review by the authors. processing. P
Content
# Ultra-processed foods in research and policy
*The Lancet 2026*
Correspondence
classified as ultra-processed foods in 4 Monteiro CA, Cannon G, Moubarac J-C, in 2033.6 The tax reform uses the
panel 1 of the Review. We respectfully Levy RB, Louzada MLC, Jaime PC. The UN National Food Basket’s criteria to
decade of nutrition, the NOVA food
disagree with this classification and classification and the trouble with ultra- ensure a zero-tax rate for fresh and
request a review by the authors. processing. Public Health Nutr 2018; 21: 5–17. minimally processed foods, while
The Codex Alimentarius Comm ission2 selective taxes on sugar-sweetened
defines fruit juice from concentrate We read with great interest the beverages were simultaneously
as 100% fruit juice obtained by second paper in the Lancet Series introduced. These measures collectively
reconstituting concentrate with potable on ultra-processed foods (UPFs) by address the commercial determinants
water. The Codex requires that both Gyorgy Scrinis and colleagues,1 which of the burden of malnutrition.
directly expressed and reconstituted comprehensively identifies the need The second strategic axis expands
juice preserve the essential physical, for robust market and regulatory access to healthy foods by realigning
chemical, organoleptic, and nutritional interventions. The authors rightly call public expenditure. Following the logic
characteristics of the original fruit for large-scale food system measures to of production to consumption, the
juice. Processing is restricted to counter the industrial logic dominating new National Food Basket serves as
physical means, and all aroma, volatile global diets. We complement their a normative reference for the Family
flavour components, pulp, and cells analysis by highlighting a recent Farming Harvest Plan (Plano Safra),
must originate from the same fruit. structural breakthrough in Brazil offering lower interest rates for agro-
Therefore, reconstituted juice remains that offers a blueprint for translating ecological production than general
unequivocally a fruit juice. these recommendations into binding agricultural credit lines.7 Downstream,
The Nova classification system regulation. the National Food Basket criteria direct
defines group 1 (unprocessed or As the largest nation in Latin America, the Food Acquisition Programme
minimally processed foods) as foods with over 212 million people, Brazil (Programa de Aquisição de Alimentos)
subjected to physical processes to has been at the forefront of global and the Solidarity Kitchens (Cozinhas
preserve or facilitate storage without food and nutrition debates since Solidárias). These initiatives, which have
adding substances or altering their the publication of the 2014 Dietary mobilised more than 324 000 tonnes
fundamental nature.3,4 Guidelines for the Brazilian Population,2 of fresh food since 2023, directly
Classifying reconstituted 100% fruit which pioneered the use of the Nova replace calories potentially derived
juice as ultra-processed is therefore classification in public policy. Building from UPFs with healthy and culturally
inconsistent with both the General on this legacy, in March, 2024, the appropriate food on the tables of people
Standard for Fruit Juices and Nectars2 Brazilian Government enacted Decree in situations of social vulnerability and
and Nova’s framework. We respectfully Number 11.936, establishing the risk, addressing historical inequalities of
request that the authors and editorial new National Food Basket.3 Signed race, gender, and class.
team reconsider this classification and by the President and the Ministers of Lastly, this approach addresses the
provide a correction or clarification. Finance, Health, Social Development, syndemic of obesity, undernutrition, and
and Agrarian Development, this policy climate breakdown. Operating in strict
TC is the Executive Director and AE is the Technical
Director of the International Fruit and Vegetable represents a high-level intersectoral alignment with Brazil’s Food Systems
Juice Association. alignment anchored in planetary health and Climate Framework8 and the New
Tatiana Campos, *Aintzane Esturo principles,4 which operationalises the Intersectoral Strategy for Obesity
aintzane@ifu-fruitjuice.com constitutional right to adequate and Prevention,9 this framework shows that
healthy food through a dual-front overcoming hunger and malnutrition
International Fruit and Vegetable Juice Association,
Paris 75002, France (TC, AE) strategy to transform food systems. should not entail capitulating to the
1 Monteiro CA, Louzada MLC, Steele-Martinez E, The first strategic axis of this policy expansion of UPFs. By placing traditional
et al. Ultra-processed foods and human health: is the statutory exclusion of UPFs from diets and food culture at the centre of
the main thesis and the evidence. Lancet 2025;
406: 2667–84. state-supported baskets and public the political economy, Brazil serves as
2 Codex Alimentarius Commission. General procurement. This definition functions a proof of concept, inspiring nations
standard for fruit juices and nectars. 2005.
as powerful regulatory guidance across all income and development
https://www.fao.org/fao-who-
codexalimentarius/ that creates policy coherence across contexts to reclaim their food systems
sh-proxy/p/?lnk=1&url=https%253a%252f%25 sectors, and now reinforces the recent from industrial uniformity, assert food
2fworkspace.fao.org%252fsites%252fcodex%
252fstandards%252fcxs%2b247- redesign of school food environments,5 sovereignty against corporate capture,
2005%252fcxs_247e.pdf (accessed protecting children and adolescents and drive a transformation rooted in
Feb 10, 2026).
from UPFs exposure, and guides social and environmental justice.
3 Monteiro CA, Cannon G, Levy RB, et al. Ultra-
processed foods: what they are and how to the national tax reform (underway All authors are employed as technical staff or hold
identify them. Public Health Nutr 2019; since 2023), with a transition period leadership at the National Secretariat for Food and
22: 936–41.
commencing in 2026, and concluding Nutrition Security, Ministry of Social Development,
948
Correspondence
Family and Fight Against Hunger, Brazil. The Authors’ reply to limit corporate influence go too
Secretariat is the governmental body responsible We thank the authors for their far. FoodDrinkEurope’s membership
for the design and implementation of the National
Food Basket and related initiatives discussed in this comments and interest in our Series includes many of the world’s largest For the Series on UPFs and
Correspondence. on ultra-processed foods (UPFs) and UPF manufacturers and lobby groups, human health see https://www.
human health. and the organisation is within thelancet.com/series-do/ultra-
Lilian dos Santos Rahal, processed-food
Patrícia Chaves Gentil, We acknowledge David S Ludwig’s a broader network of corporate
*Gisele Ane Bortolini, concern about the limits of any single interest groups that have actively
Felipe Silva Neves, classification system. The Nova promoted misinformation about
Bruna Pitasi Arguelhes framework does not replace nutrient Nova and the evidence on UPFs.4
gisele.bortolini@mds.gov.br science, but adds a complementary Based on decades of evidence
layer focused on food processing as from food, tobacco, alcohol, and
National Secretariat for Food and Nutrition
Security, Ministry of Social Development, Family a determinant of dietary patterns. fossil fuel research, we question
and Fight Against Hunger, Brasília 70054-906, Foods, nutrients, additives, and food the credibility of industry-funded
Brazil (LdSR, PCG, GAB, FSN, BPA); Group for
matrices all matter, and the second science when commercial imperatives
Studies, Research and Practices on Food
Environment and Health, Department of Nutrition, Series paper1 explicitly proposed that all conflict with public health goals.5
School of Nursing, Federal University of Minas regulations should combine criteria on Transparency alone is insufficient.
Gerais, Belo Horizonte, Brazil (FSN); Department of
crucial nutrients with markers of food The empirical literature shows
Nutrition, Institute of Biological Sciences, Federal
ultra-processing, rather than treating that disclosure does not neutralise
University of Juiz de Fora, Juiz de Fora, Brazil (FSN)
processing as a stand-alone metric. bias, nor prevent the strategic use
1 Scrinis G, Popkin BM, Corvalan C, et al. Policies
to halt and reverse the rise in ultra-processed Importantly, nationally representative of funding to manufacture doubt,
food production, marketing, and
surveys from multiple countries show delay regulation, and frame debate
consumption. Lancet 2025; 406: 2685–702.
2 Ministry of Health Brazil. Dietary guidelines for that the dietary contribution of ultra- in industry-favourable terms.4,5
the Brazilian population. 2015. https://bvsms. processed foods (UPFs) is the main Safeguards against conflicts of interest
saude.gov.br/bvs/publicacoes/dietary_
driver of nutrient-imbalanced diets. are pro-science, not anti-science.
guidelines_brazilian_population.pdf. (accessed
Feb 10, 2026). For example, in the USA, 92·4% of diets Editors exclude conflicted reviewers,
3 Da Silva LIL, Ferreira LPT, Dias JWBdA, excessive in added sugar, saturated fat, governments restrict lobbying, and
Haddad F, Lima NVT. Decree no 11 936 of
energy density, and insufficient in fibre ethics committees limit funding
March 5, 2024. 2024. https://www.planalto.
gov.br/ccivil_03/_ato2023-2026/2024/ are attributed to UPF consumption.2 sources for precisely these reasons.
decreto/d11936.htm (accessed Aug 20, 2025).
UPFs, therefore, function not as an Food and nutrition research should be
4 Rockström J, Thilsted SH, Willett WC, et al.
The EAT-Lancet Commission on healthy, ideology but as structural drivers of no exception.
sustainable, and just food systems. Lancet dietary nutrient imbalance, as well We agree with Gunter G C Kuhnle
2025; 406: 1625–700.
as of other determinants of ill health that evidence on the harms of
5 Neves FS, Mendes LL, Rocha LL, et al.
Redesigning school food environments in including overeating, exposure to UPFs was generated using dietary
Brazil: public sector innovation to protect harmful additives and contaminants, instruments not designed to
children and adolescents and promote food
and nutrition security. Lancet Reg Health Am snacking, and other harmful eating capture Nova groups. However,
2025; 52: 101273. patterns. Nova explains dietary exposure misclassification is likely
6 Ministry of Health. Selective taxes in the
patterns in ways that nutrient-centric non-differential in regard to outcomes,
context of Brazilian tax reform: evidence and
perspectives for the prevention of chronic non- models alone cannot. Critiques based and therefore bias associations
communicable diseases. 2025. https://www.
on isolated UPF products overlook towards the null.6 As dietary tools for
gov.br/saude/pt-br/centrais-de-conteudo/
publicacoes/svsa/analise-de-situacao-de- the logic of dietary displacement and assessing food consumption aligned
saude/impostos-seletivos-no-contexto-da- the relevant counterfactual: fresh with Nova are adopted, associations
reforma-tributaria-brasileira.pdf/view
(accessed Feb 10, 2026). and minimally processed foods and strengthen rather than weaken.7
7 Ministry of Agrarian Development and Family cooked meals. We have recently Misclassification has a greater effect on
Farming. 2025/2026 crop plan. 2025. https://
explained why UPF subgroup analyses UPF subgroup analyses than on UPF-
www.gov.br/mda/pt-br/noticias/2025/06/
plano-safra-2025-2026 (accessed suggesting differential health effects pattern analyses.3 Aggregating all UPFs
Aug 20, 2025). are conceptually and methodologically partly mitigates food-level measure-
8 Ministry of Social Development and Assistance.
flawed, undermining the credibility ment error, whereas attempting
Food systems and climate: framework for public
policies. 2025. https://www.gov.br/mds/pt-br/ of nutrition science and risking policy to distinguish fine subgroups with
acoes-e-programas/promocao-da-alimentacao-
misinterpretation.3 imperfect instruments amplifies
adequada-e-saudavel/marco-de-referencia-
sobre-sistemas-alimentares-e-clima-para- Rafael Sampson and Dirk Jacobs of instability, multiple testing, and false
politicas-publicas/food-systems-and-climate. FoodDrinkEurope characterise the positives.3
pdf (accessed Feb 10, 2026).
UPF industry and industry-funded Tatiana Campos and Aintzane
9 Neves FS, Leister GA, Jardim MZ, et al. Obesity
and intersectionality: Brazil’s experience in scientists as impartial brokers of Esturo argue that reconstituted
advancing equity through transformative
evidence and argue that proposals fruit juices should be treated as
public policies. Nutr Rev 2025; 00: 1–5.
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DOI: 10.1016/S0140-6736(26)00109-1