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Certification or risk scale? Two approaches to the UPF debate

As the debate over ultra-processed foods intensifies, two frameworks have been developed to tackle the issue. One is a certification to identify non-UPF foods, the other is a risk scale to measure processed foods.

One problem, two opinions

In April 2025, the Non-GMO Project, a US nonprofit for food transparency and labelling, announced its Non-UPF Verified certification, a third-party label to assist brands in communicating that their products are not ultra-processed.

Also in April, ZOE, a personalised nutrition company and app, announced its “Processed Food Risk Scale”, a food classification system developed to assess the health impact of processed foods.

Both approaches are in response to the mounting concern and growing debate around ultra-processed foods (UPFs), and while both are calling for food reform, their diverging approaches represent the lack of consensus across the industry about what actually makes a food “unhealthy”.

Non-GMO Project’s Non-UPF Verified certification

The Non-GMO Project developed its Non-UPF Verified certification to help brands across North America communicate to consumers that their products are not ultra-processed while helping consumers make more informed food choices.

Before rolling out across North America, a pilot programme will launch this spring. Around 20 food brands have been invited to participate in the pilot.

“The purpose of the pilot is really to learn from food manufacturers, and to ‘pressure test’ the first draft of a standard, ultimately providing consumers with trustworthy informed choice that is also achievable and meaningful within the CPG space,” Megan Westgate, founder and CEO of the Non-GMO Project said in a press release.

The pilot programme is expected to finish in the summer of 2025, with applications for the certification expected to open in fall.

The label itself would appear on products’ front-of-package.

ZOE Processed Food Risk Scale

ZOE’s Processed Food Risk Scale is currently under development. According to ZOE, the tool is designed to offer a more nuanced approach to processed foods. Rather than a “blanket penalty for all processed foods or penalising foods based on the level of processing alone”, the classification aims to help consumers make more informed food choices with less confusion.

By integrating additional factors beyond the processing level, ZOE aims to improve upon the NOVA classification, a widely used framework system that categorises foods based on their processing level.

Instead of a blanket UPF vs non-UPF, the scale will include five risk levels: unprocessed (food is in its original form or close to its original form); no risk (minimal processing that poses no risk to health); low risk (processing has no or low impact on health); significant risk (processing may make it less healthy and may have a moderate impact on health); and highest risk (processing makes it less healthy and could have a high impact health).

To develop the scale, ZOE scientists considered multiple food processing factors and their potential impact on health.

The factors include energy density (calories per gram of food), energy intake rate (how quickly calories are consumed), hyperpalatability (foods engineered to trigger excessive consumption), and non-culinary additives (the addition of artificial colours, sweeteners, and preservatives).

Health risks are not always clear-cut

UPFs have been receiving increasing attention over the past five years, with growing research pointing to the link between high UPF consumption and increased health risks such as obesity, cancer, type 2 diabetes, and even all-cause mortality in specific populations.

As UPFs receive increased scrutiny, consumer interest in clean-label products grows. According to market research company Mintel, almost half of Italian consumers agree that “natural ingredients” are a top purchasing factor when shopping for food.

However, there is growing discourse around the idea that not all UPFs are bad or unhealthy.

For example, a study published in The Lancet found that higher consumption of UPFs, such as sugar-sweetened beverages, was associated with increased risk of multimorbidity of cancer and cardiometabolic diseases, while other UPFs, such as breads and cereals, were not associated with an increased risk.