Ultra-processed and under-regulated: why ultra-processed foods lack regulation despite evidence of harm

In their article for Future Healthcare Journal (FHJ), Professor John O Warner from Imperial College London and Alisha Khan, a medical student at The University of Sheffield, explore the reasons for ineffective regulation and what urgently needs to change to protect vulnerable groups from the harms of UPFs.

>> FHJ is an RCP journal. It has editorial independence and the views expressed by journal article authors are not necessarily the views of the RCP.

Describing UPFs as ‘hazardous to long-term health’ and closely linked to rising noncommunicable diseases, the authors argue that weak regulation reflects ‘excessive influence of UPF manufacturers’ alongside fragmented and outdated policy frameworks, rather than a lack of scientific evidence.

What are UPFs and how do they affect the body?

Ultra-processed foods are characterised by their long list of ingredients that are not typically found in freshly prepared homemade food. They often contain non-nutritious additives such as azo-dye colourants (the largest group of synthetic dyes that are added to foods and textiles to provide colour), non-caloric sweeteners, emulsifiers and preservatives.

Professor Warner and Alisha Khan warn that these additives disrupt the gut microbiome and the mechanisms that normally protect against chronic disease, affecting gut barrier integrity, immune pathways and metabolic signalling. Some additives, such as azo food dyes, can also be metabolised into DNA‑damaging compounds, adding to concerns about carcinogenic risk.

UPFs also trigger what the authors describe as ‘hedonistic hunger’ (eating when not physically hungry), therefore promoting overeating and contributing to obesity. Their low cost, appetising appearance and convenience make them a popular but non-nutritious food choice worldwide.

Recent studies have even compared UPFs to tobacco, claiming that they are both designed to encourage addiction and overconsumption, and are linked to similar health harms.

Why isn’t there better regulation?

The authors outline three main reasons, including industry influence over government policies, outdated regulatory frameworks, and inconsistent public health strategies.

Industry influence over policy change

Professor Warner and Alisha Khan argue that the food and advertising industries are slowing down public health action on junk food and UPFs. Lobbying has blocked local advertising restrictions through threats of lost advertising income. Industry-funded reports have downplayed evidence of harm, and past examples, such as sugar industry-funded research around heart disease, show how companies can shape science and public opinion to protect their products. They warn that this may be happening again with UPFs.

They expose other tactics such as ‘healthwashing’, where marketing presents unhealthy products, such as highly processed plant-based meat, as healthier than they truly are.

Inadequate and outdated frameworks

The authors highlight that current regulatory frameworks for food additives and UPFs are fragmented, inconsistent and often outdated. For example, some European countries have withdrawn approval of the azo food colourant, Allura Red, due to concerns about ‘DNA damaging metabolites,’ yet the Food and Drug Administration (FDA) and the European Food Safety Authority still approve it. The FDA withdrew another synthetic food dye known as Red No.3 in 2025 for potential carcinogenicity, while UK and EU regulators continue to permit its use.

The authors argue that inconsistent decisions across regulators create confusion, as some additives are tightly controlled, while the wider health risks of UPFs are overlooked. They note that focusing on single additives, such as azo dyes, can distract from comprehensive nutrition policies that address the full spectrum of UPF‑related risks. In addition, widespread use of ambiguous classifications (like the NOVA framework) adds further uncertainty, making it easier for industry to challenge proposals for stronger regulation.

Inconsistent public health strategies

The article shows that public health strategies around UPFs are often inconsistent and undermined by political and commercial pressures. Manufacturers have shifted from sugar to noncaloric sweeteners, even though there is no evidence that these are healthier. Some Californian cities tax sugary drinks, but it’s unclear whether drinks with noncaloric sweeteners are included. In the US, industry lobbying at state level has limited local authorities’ ability to introduce their own health measures.

A similar pattern is seen in the UK. The article describes how the Department of Health and Social Care altered its guidance for food outlets following pressure from the Food and Drink Federation, whose members include major multinational corporations. As a result, new legislation will cover only high-fat, salt or sugar foods and omit processed and ultra-processed foods altogether.

Authors’ recommendations on what needs to change

Professor Warner and Alisha Khan call for clearer, stronger regulation of UPFs. They propose replacing the outdated E number system with labels that distinguish genuinely safe additives, and introducing bold front-of-pack warnings on products containing ingredients linked to harm. They argue for immediate bans on high-risk additives like azo dyes, tighter restrictions on UPF marketing, especially to children, and removal of UPFs from schools and public institutions.

To reduce dependence on cheap UPFs, they recommend making fresh foods more affordable through subsidies. Finally, they call for an independent national taskforce to evaluate evidence, limit industry influence, and drive coherent policy reform focused solely on public health.

Read the full article: Why is there no regulation despite evidence that ultra-processed foods are hazardous to long-term health?

If you’re interested in this, read our interview with Dr Chris Van Tulleken in Commentary magazine, where he discusses his FHJ issue on the commercial determinants of health, such as ultra-processed foods and tobacco.