Editor: Caleb Acquah (PhD)

GFI | GLOBAL REGULATORY WATCH

A new perspective in npj Science of Food argues that the NOVA system cannot be applied consistently and fits poorly with the populations it aims to protect. The critique lands as the United States prepares its first federal definition of ultra-processed foods.

Key Takeaways

• A perspective published October 21, 2026 argues that NOVA’s ultra-processed category rests on imprecise, culturally specific criteria. It is an argument piece, not a new study or systematic review.
• The author contends the result is a classification that cannot be applied consistently and regulatory proposals that cannot be consistently enforced.
• Earlier testing supports part of the concern. A 2022 study found low agreement among specialists assigning foods to NOVA groups, even with ingredient lists.
• The critique does not show ultra-processed diets are harmless. A 2025 Lancet series reported that 92 of 104 long-term studies linked higher intake to greater risk of chronic disease or early death.
• The timing matters. FDA and USDA sent a proposed federal definition for final review in August 2026, and California’s school-meal law already uses its own.
• Manufacturers face regulatory convergence without regulatory harmonization: a shared concern about ultra-processed foods, expressed through incompatible definitions.

What the Perspective Argues

Jimmy Chun Yu Louie of Swinburne University of Technology argues that NOVA’s Group 4 relies on criteria reflecting the culinary norms of high-income, food-secure populations [1]. Because those criteria are operationally imprecise, he contends, the classification cannot be applied consistently, produces regulatory proposals that are difficult to enforce, and generates advice that is hardest to follow for the people most affected by diet-related disease.

He concludes that progress requires either a more rigorous, reproducible successor framework or clearer recognition of NOVA’s limits. Louie declares an intellectual competing interest as the leader of a programme of critical scholarship on NOVA, and reports no industry funding [1].

The Consistency Problem Is Not New

Reproducibility has been tested before. In a 2022 study, French food and nutrition specialists assigned 120 marketed products and 111 generic foods to NOVA groups. Agreement among evaluators was low overall, even when ingredient information was available [2]. A 2026 systematic review found that NOVA-based intake tools showed acceptable reproducibility but variable validity, with agreement between different processing classification systems ranging from fair to substantial [3].

In research, some misclassification is tolerable noise. In regulation, it is a different problem. A labelling requirement, procurement rule or tax needs two inspectors to reach the same answer about the same product.

The Health Evidence Still Stands

The perspective should not be read as exonerating ultra-processed diets. The 2025 Lancet series, led by NOVA’s creator Carlos Monteiro, reviewed 104 long-term studies and found that 92 reported higher risk of chronic disease or early death with higher intake [4][5]. Supporters argue NOVA captures features of industrial formulation that nutrient-based systems miss.

The real dispute is narrower: whether a framework built for epidemiology can be transplanted, unchanged, into law.

Governments Are Already Writing Their Own Definitions

In the United States, FDA and USDA issued a joint request for information in July 2025 and submitted a proposed federal definition to the Office of Management and Budget in August 2026. The text has not been published [6]. More than 5,000 comments split three ways: adopt NOVA, adopt a hybrid of processing and nutrition criteria, or reject processing as a proxy for nutritional quality [7].

California did not wait. AB 1264, signed in October 2025, defines ultra-processed foods through ingredients with specified technical effects alongside nutrient thresholds, and requires “UPFs of concern” to be phased out of school meals by July 2035 [8]. That already departs from NOVA’s descriptive groups.

Elsewhere, several Latin American countries have built dietary guidelines around NOVA, and France has set a goal of cutting ultra-processed food consumption by 20% [2]. Canada’s mandatory front-of-package symbol, by contrast, is nutrient-based [9].

What This Means for Food Companies

The same product could be ultra-processed under NOVA, compliant under a California-style ingredient test and untouched by a nutrient-based label. Manufacturers should map their portfolios against several candidate definitions, not NOVA alone, and identify which products change status under each. A reformulation that removes an emulsifier or flavouring may move a product across one definition but not another. Once the federal definition is published, its comment period will be the moment to press for reproducible criteria.

Ultra-processed food policy is moving faster than agreement on what an ultra-processed food is. That gap does not settle the health debate, but it matters to anyone who has to comply. A definition that two assessors apply differently is a research variable. It is not yet a regulation.

Related on GFI: 57,000 People, Wearable Data and Diabetes: A New Study Complicates the UPF Debate and India’s Front-of-Pack Label Fight Could Become a Global Test for Food Reformulation.

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Sources

1. Louie JCY. Nova was never built for the populations it claims to protect. npj Science of Food. 2026. Published October 21, 2026. doi:10.1038/s41538-026-01198-4. Journal page
2. Braesco V, Souchon I, Sauvant P, et al. Ultra-processed foods: how functional is the NOVA system? European Journal of Clinical Nutrition. 2022;76:1245-1253. PMC
3. Cavero-Redondo I, Saz-Lara A, et al. Validity and reliability of tools to measure ultraprocessed food intake under the NOVA system: A systematic review. American Society for Nutrition. 2026. Accepted manuscript
4. Monteiro CA, et al. Ultra-processed foods and human health: the main thesis and the evidence. The Lancet. Published online November 18, 2025. doi:10.1016/S0140-6736(25)01565-X.
5. EMJ. Ultra-Processed Foods Threaten Global Human Health, Experts Warn. November 2025. Article
6. Food Safety Magazine. FDA, USDA Submit ‘Ultra-Processed Foods’ Definition for Final Review. August 2026. Article
7. FoodNavigator-USA. FDA Weighs Competing Definitions for Ultra-Processed Foods. July 17, 2026. Article
8. Hogan Lovells. California Enacts Law Defining “Ultra-Processed Food.” October 2025. Analysis
9. Health Canada. Front-of-Package Nutrition Symbol Labelling.