Despite growing consumer concerns about ultraprocessed foods, there still isn't an agreed definition of the term. While a number of outside groups and regulators have floated their own definitions, the Non-GMO Project hopes its new label can set the gold-standard.
Earlier this year, the group known for its butterfly seal launched a Non-UPF Verified label for food and beverage companies to signal to consumers that products are free from the hallmarks of ultraprocessing. More than 300 products have since been verified, which is "incredibly encouraging, particularly for a program this new," according to Non-GMO Project CEO and Founder Megan Westgate.
The Non-UPF Verified label is unique in that it takes a holistic approach in determining whether a product is ultraprocessed by focusing on both ingredient integrity and the degree of processing. Westgate hopes that Non-UPF Verified can be more than just a label and become a framework for the industry in reformulation and the development of healthier foods.
Food Dive spoke with Westgate about the development of the Non-UPF Verified label, the challenges in creating an ultraprocessed framework, and whether the seal can become as widespread as the Non-GMO label.
Editor’s note: This conversation has been edited for brevity and clarity.
FOOD DIVE: Why do you think the Non-GMO Project is best positioned to create a label for non-ultraprocessed foods?
MEGAN WESTGATE: Our work has revealed a clear throughline. Our mission’s core values of food integrity, transparency and informed choice connect both Non-GMO Project and Non-UPF Verified.
When we created the Non-GMO Project nearly 20 years ago, there were plenty of people who questioned whether consumers would care enough about genetic engineering to change the marketplace. What we learned was much bigger than GMOs.
Over time, that led us to look further along the journey from farm to fork. The value created on the farm doesn't necessarily survive every step along the way. Ingredients continue through sourcing, processing and formulation before they reach the shelf, and integrity can be protected, changed or lost along that journey.
About three years before ultraprocessed food became the mainstream conversation it is today, we had already begun exploring minimal processing and additives through our systems-based work with the Food Integrity Collective.
Those threads eventually came together in Non-UPF Verified. The certification strives to identify and protect three things that matter deeply to us: structural integrity, nourishment and transparency.
People don't need to become experts in food science. They need trustworthy information about things they otherwise cannot see. When you make the invisible visible, people can make informed choices.
The label itself was in development for quite a while and included a pilot phase. What were some of the challenges that you faced during this process and what lessons did you learn from the pilot?
One of the biggest challenges in creating the Non-UPF Verified Standard was recognizing that determining whether a food is ultraprocessed is far more complex than creating a list of ingredients that are allowed or prohibited, or assigning value to particular nutrients.
Added sugar was one example. We began with very strict requirements, but through the pilot we learned that even relatively minimally processed products may use a combination of sweeteners for reasons including flavor, functionality and cost. We refined the requirements to account for meaningful differences among product categories, including how much added sugar is appropriate for products that consumers expect to be sweet. This allowed us to maintain rigorous limits while applying them in a way that makes sense across different types of food.
Baking mixes offered another useful lesson. A dry cake or baking mix isn’t consumed as it comes out of the package. The consumer adds other ingredients before eating it. One of our pilot participants helped us recognize that applying added-sugar requirements only to the dry mix could create a misleading picture of the food as it is actually prepared and consumed. We added provisions to account for products that require further preparation. That may sound like a small distinction, but those are exactly the kinds of real-world nuances a meaningful standard needs to address.
We also learned how quickly this landscape is changing. New ingredients and processing technologies continue to emerge, while the science around ultraprocessed food is still developing.
That was one of the most important lessons of the pilot: a strong certification standard has to be both rigorous and grounded in how food is actually made, sold and consumed. You cannot understand ultraprocessing by looking at a single characteristic of a product.
Why was it important to focus on both processing and ingredient composition in your definition?
Ingredients matter. Nutritional composition matters. Processing matters.
Our standard deliberately considers both ingredient integrity and processing because we don't think either one tells the whole story on its own.
What concerns us is that processing is the part consumers can’t see. You can turn a package around and read the grams of sugar, fat and sodium. You can read every ingredient that is required to appear on the label. What you generally cannot determine is what happened to those ingredients before they reached that package.
And there is growing research suggesting that matters. Controlled feeding studies have found different outcomes in food intake and weight gain when people consume diets with different levels of processing, even when researchers have attempted to match important nutritional characteristics. Processing can affect food structure, eating rate, satiety and the way nutrients are delivered.
So we’re not saying nutrients don't matter. We’re saying processing should not be invisible simply because it’s difficult to detail it on a Nutrition Facts panel.
That is a core food integrity issue for us. If we want people to have informed choices, we have to give them access to information they cannot reasonably uncover for themselves.
How have food and beverage brands responded to this label? Do you see this growing to become as large as the Non-GMO label, which has more than 5,700 brands verified?
We are already working with brands across many different product categories. We are also seeing companies use the Standard as more than a label. It is becoming a framework for conversations about sourcing, formulation and how products are actually made.
That aligns with what consumers are telling us. In our latest consumer market research, 72% of shoppers said they are actively trying to avoid ultraprocessed foods, even though many do not feel confident identifying them.
People are asking for transparency and agency. They want to understand the food they are buying, but there’s still a tremendous amount they simply can’t see.
Could Non-UPF Verified someday reach the scale of the Butterfly? Absolutely.
We certainly think the need is there. It’s worth remembering that our Non-GMO Project Verification didn’t scale to 5,700 brands overnight — we’ll be celebrating our 20th anniversary next year. We're intentionally building Non-UPF Verified the same way through a meaningful certification, a rigorous standard that evolves with the science and public input as well as the care our third-party Technical Administrators take when verifying each product.
We are at a critical moment that is very similar to the one we saw at the beginning of the non-GMO movement. Consumers are asking a question that the existing food system does not make easy to answer. Brands are beginning to respond. Retailers are paying attention. And independent verification can help connect all of those pieces.
Are you concerned about the rise of multiple labels and definitions for non-ultraprocessed? Would you be in favor of a national definition?
There is always a risk that too many competing definitions and labels create more confusion rather than less. Sometimes when packages become crowded with claims and certifications, consumers are left trying to figure out what each one actually means.
So yes, I think greater clarity and consistency would be valuable.
At the same time, we would want any national definition to reflect the complexity of the issue. If we reduce ultraprocessing to a handful of additives or numbers on the Nutrition Facts panel, we risk creating a definition that is easy to administer but leaves out the very thing the term is supposed to help us understand: how food is actually processed.
The conversation is still evolving as the science advances. Policymakers are asking questions. Brands are reformulating. But most of all, consumers are paying attention.
Our hope is that Non-UPF Verified can contribute what we have learned from actually reviewing products, ingredients and manufacturing processes.
Whatever framework ultimately emerges, it should increase transparency and help people make informed choices.
