A rationale for policy change, nudging and commercial regulation of ultra-processed foods

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Ultra-processed foods encompass a wide range of items, spanning from carbonated beverages to breakfast cereals and from pre-packaged snacks to cured meats. These products are notorious for their extensive use of additives, which are often detrimental to health. Among these additives are oils, fats, sugars, starches, and sodium, which not only diminish the nutritional value of the food but also pose potential health risks[1].

Additionally, emulsifiers such as carrageenan, mono- and diglycerides, carboxymethylcellulose, polysorbate, and soy lecithin are commonly employed in these processed foods, further compromising their nutritional integrity and potentially impacting human health negatively via alteration in barriers and microbiomes[2].

Thus, the consumption of ultra-processed foods not only deprives individuals of essential nutrients but also introduces potentially harmful substances into their diets, contributing to various health concerns[3].

Recent findings

Physicians from Florida Atlantic University’s Schmidt College of Medicine have delved into the impact of ultra-processed foods on health outcomes, shedding light on a political and commercial issue that stands at odds with the priorities of various industries and public policies[4]. In their commentary published in The American Journal of Medicine, they address the concerning trend where the interests of the entertainment and food industries often diverge from the health needs of patients and members of the public, yet to be qualified as a patient.

The authors add that public health organisations in the USA are increasingly making use of the NOVA classification system, which divides foods into four categories — whole foods, culinary ingredients (items like butter, oil and salt), traditionally processed foods (such as bread and yogurt made with few ingredients), and ultra-processed foods — or those foods that are industrially made and use ingredients not normally found in a domestic kitchen[5].

Mechanisms of disruption

According to the authors, one plausible mechanism to explain the hazards is that ultra-processed foods contain emulsifiers and other additives that the human gastrointestinal tract mostly does not digest. They may then act as a food source for our microbiota, and create a dysbiotic microbiome that can, in the right host, promote disease.

For example, maltodextrin may promote a mucous layer that is friendly to certain species of bacteria that are found in greater abundance in patients with inflammatory bowel disease[6]. When the mucous layer is not properly maintained, the epithelial cell layer may become vulnerable to injury, as has been shown in feeding studies using carrageenan in humans and other studies in mice models, using polysorbate-80 and cellulose gum, triggering immunologic responses in the host[7].

The authors add that there have been marked increases in colorectal cancer and IBD in the U.S., especially among younger adults[8][9]. They opine that increased ultra-processed food consumption may be a contributor, as well as to several other gastrointestinal diseases.


It is incumbent upon all healthcare professionals to discuss the benefits of increasing the consumption of whole foods and reducing the consumption of ultra-processed foods with their patients. Just as the dangers of tobacco began to emerge during the middle of the prior century, decades passed before the preponderance of the evidence and the efforts of forward-thinking health officials prompted policy changes to discourage the use of cigarettes. Political and healthcare professional pressure needs to be applied to avoid a similar timeline for ultra-processed foods.

Indications of change

Supermarkets could face fines of up to 1% of their annual turnover from the Food Standards Agency (FSA) if they fail to comply with a system of mandatory healthy food targets, proposed by an influential nudge unit.

The innovation charity Nesta claims the impact of a sustained programme of calorie reduction across the UK’s biggest 11 food retailers could lead to obesity rates falling by almost a quarter within three years of implementation[10].

Nudging – does it work?

In the realm of forecasting the extent of support for nudges, researchers have identified a pivotal factor influencing acceptance: the perceived infringement on free choice. This perception emerged as the primary catalyst for resistance to nudges, indicating a deep-seated concern among individuals regarding the preservation of autonomy in decision-making processes. Conversely, the perception of effectiveness emerged as the predominant driver of acceptance, underscoring the pivotal role of perceived efficacy in garnering public endorsement for nudging interventions[11].

It is imperative to grasp the nuances of public support and its underlying drivers to craft nudges that not only align with ethical principles but also navigate the complex terrain of political viability – we are all too familiar with the ‘nanny state’ proposition by the more right-wing members of the government. By dissecting the interplay between factors such as perceived intrusiveness, effectiveness, and ethical considerations, policymakers can tailor nudges that strike a delicate balance between promoting positive behavioural outcomes and respecting individual autonomy.

This has been explored by the team at Nesta and is also an important part of inducing behavioural change in individual clients and patients.

Moreover, an in-depth understanding of the dynamics shaping public attitudes towards nudges is indispensable for the development of interventions that resonate with diverse societal perspectives. By elucidating the factors driving both acceptance and resistance, researchers can inform the design of nudges that are not only empirically sound but also sensitive to the values and preferences of the communities they aim to serve.

In essence, unravelling the intricate web of factors influencing public support for nudges lays the groundwork for the creation of interventions that are not only efficacious and ethical but also garner widespread acceptance, thereby maximising their potential to catalyse positive societal change.

I am not sure any political party has the will or capability we need to make this shift away from commercial short-term interests to long-term societal health – but remain hopeful that economic realities will drive even the most hardened ‘markets know best.’ MP to recognise that the route we are on is unsustainable.



[1] Sherling DH, Hennekens CH, Ferris AH. Newest updates to health providers on the hazards of ultra-processed foods and proposed solutions. Am J Med. 2024 Feb 9:S0002-9343(24)00069-X

[2] De Siena M, Raoul P, Costantini L, Scarpellini E, Cintoni M, Gasbarrini A, Rinninella E, Mele MC. Food Emulsifiers and Metabolic Syndrome: The Role of the Gut Microbiota. Foods. 2022 Jul 25;11(15):2205.

[3] Levy RB, Barata MF, Leite MA, Andrade GC. How and why ultra-processed foods harm human health. Proc Nutr Soc. 2024 Feb;83(1):1-8.

[4] Sherling DH, Hennekens CH, Ferris AH. Newest updates to health providers on the hazards of ultra-processed foods and proposed solutions. Am J Med. 2024 Feb 9

[5] Rodrigo Rodrigues Petrus, Paulo José do Amaral Sobral, Carmen Cecília Tadini, Cintia Bernardo Gonçalves, The NOVA classification system: A critical perspective in food science, Trends in Food Science & Technology, Volume 116, 2021, Pages 603-608,

[6] Zangara MT, Ponti AK, Miller ND, Engelhart MJ, Ahern PP, Sangwan N, McDonald C. Maltodextrin Consumption Impairs the Intestinal Mucus Barrier and Accelerates Colitis Through Direct Actions on the Epithelium. Front Immunol. 2022 Mar 14;13:841188.

[7] Ogulur I, Yazici D, Pat Y, Bingöl EN, Babayev H, Ardicli S, Heider A, Rückert B, Sampath V, Dhir R, Akdis M, Nadeau K, Akdis CA. Mechanisms of gut epithelial barrier impairment caused by food emulsifiers polysorbate 20 and polysorbate 80. Allergy. 2023 Sep;78(9):2441-2455.

[8] Vassilev ZP, Guo H, Lin W, Xu J, Khan N, Fan X. Age-related trends in the incidence of metastatic colorectal cancer from 2010 to 2019 in the USA. Future Oncol. 2023 Sep 13

[9] McCauley M, Haynes K, Yang JY, Schaubel DE, Hurtado-Lorenzo A, Kappelman MD. Incidence, Prevalence, and Racial and Ethnic Distribution of Inflammatory Bowel Disease in the United States. Gastroenterology. 2023 Nov;165(5):1197-1205

[10] Developing targets for the food industry to improve health. https://www.nesta.org.uk/project/industry-targets-to-improve-health/ (accessed 28.2.24)

[11] Dominic Lemken, Simone Wahnschafft, Carolin Eggers. Public acceptance of default nudges to promote healthy and sustainable food choices. BMC Public Health, 2023; 23 (1)






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