Ultraprocessed Foods and Public Policy: the Argument for Use-Case Consideration

The advent of an operational definition of “ultraprocessed foods” (UPFs) intrinsic to the Nova classification has meaningfully advanced research on the topic. A large volume of studies, including metabolic ward trials, have begun to enumerate the many potential harms of UPFs. This inventory of harms is in turn conducive to public policy responses. The connection between the two is on clear display in the 2025 Dietary Guidelines for Americans , which inveigh directly against consumption of “hyperprocessed food,” generally interpreted to mean UPFs. The harms of UPFs, however, are no less subject to the “ instead of what? ” consideration than any other component of diet. Whereas most UPFs displace more wholesome, more nutrient dense, more satiating alternatives from the diet; and whereas most foods in this category may be expressly engineered to minimize satiety and maximize consumption in the service of profit - there are notable exceptions with regard to intention, substitution, and effects. Salient among these is the category of plant-based meats, expressly designed to substitute for meat, and beef most particularly. The case is made that application of “ instead of what? ” as a use-case filter helps to differentiate between the majority of UPFs apt to confer net harm, and the rarer but potentially important exceptions to that rule. Another key consideration is variation by population and culture; the net effects of a subset of UPFs on overall diet quality could conceivably be favorable in one population, detrimental in another. These distinctions suggest the importance of nuance in the development of public policies responsive to the harms of UPFs, allowing for use cases with the potential to confer net benefit. Optimal policy responses to the burgeoning study of UPFs will accommodate the limited, but important, heterogeneity of that food class.