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Brazil pushes forward on restricting ultra-processed foods

The Brazilian government is pushing ahead with its proposal calling on the World Health Organization (WHO) to restrict the marketing of ultra-processed foods – a move causing a mixed response.

In May, last year, Brazil shared a proposal at the World Health Organization's 79^th World Health Assembly in Switzerland calling for restrictions on the marketing and sale of ultra-processed foods (UPFs) globally. The proposal received backing from France, Mexico and Uruguay at the time and a few months later WHO established a Guideline Development Group for ultra-processed foods (UPFs).

At a glance:

• Brazil has several ongoing proposals to restrict ultra-processed foods, including one calling on the World Health Organization (WHO) to restrict the products globally.
• Concerns have been raised about the lack of a globally harmonised definition for ultra-processed foods, which critics argue creates difficulties when translating restrictions into law.
• Many support the move to restrict ultra-processed foods, many are against attempts and call for consensus on a global definition and understanding of the term.

Made up of various global experts in the field of public health, food safety, technology, nutrition, social research and economics, the aim of the group is to develop guidelines on the consumption of ultra-processed foods, providing “much-needed, evidence-based global guidance on this important topic”, it said.

In November, WHO took the subject to the Codex Alimentarius aiming to get a definition of ultra-processed foods, though this year the Codex Committee on Food Labelling removed the subject from its list of possible future work. Despite this, WHO said that it would present a profiling model for regulatory measures on ultra-processed foods by the end of 2026 and guidelines on consumption by 2028.

‘No single Brazilian proposal’

Dr Marcia Terra, secretary-general of the Brazilian Society for Food and Nutrition (SBAN), advisory board member at Brazil's International Diabetes Federation (ANAD) and independent regulatory and scientific affairs consultant for the food and beverage industry, said Brazil's WHO proposal is one of many that addresses the topic of ultra-processed foods.

“There is no single Brazilian proposal; there are dozens. In the National Congress alone, counting the Chamber of Deputies and the Federal Senate, there are at least 26 bills on so-called ultra-processed foods,” Terra told Ingredients Network. The bills range from calls to ban the sale of UPFs, restrict marketing of them, add carcinogenic warning labels, and even stop the Brazilian government from buying these products. “The oldest is from 2018 and the newest is from this year. More than half were filed from 2025 onward, showing how quickly the topic became fashionable in Congress,” she said.

So far, none of the proposals have reached the end point of regulatory processes.

Crucially, Terra said each of the proposals brings its own definition of ultra-processed, which is one of the most concerning aspects in the wider debate. “In law, this is very bad because it creates legal uncertainty: the inspector, the company, and the judge will read the same rule in different ways.”

No globally harmonised definition

The lack of a common, globally harmonised definition of UPFs is a problem that cannot be ignored, she said.

Under most definitions, Terra said an ultra-processed food is “any food with an additive or an ingredient not used in a home kitchen”. Taking this definition means that for school canteens, products with sweeteners suited to children with diabetes, gluten-free foods for children with coeliac disease, and products for those with food allergies would be banned.

“It worries me a lot to see activists taking this agenda to politicians who know little about food technology,” she said. “The activists picture crisps, soft drinks, and sweets; they don't think of the child who needs these products to eat safely at school.”

For hospitals, the impact is “even more serious”, she said, with the potential banning of manufactured food and cartons of juices, which ensure safe nutrition for patients, along with restrictions on supplements, gels, and special formulas.

Asked if it is possible to reach a consensual, harmonised global definition of UPFs, Terra said it would be unlikely. “The problem is that there is nothing to define. As I always say, this word was invented, and its definition has been changed several times by its own creators since the first version in 2009.”

Brazilian epidemiologist Carlos Monteiro and his team from the University of São Paulo coined the term “ultra-processed food” as a scientific concept in 2009; they later integrated it into the widely known and established NOVA food classification system.

NOVA and Nutri-Score

Today, NOVA informs a number of dietary guidelines across Latin American countries, classifying foods into four groups based on the level of processing: unprocessed/minimally processed, processed culinary ingredients, processed foods, and ultra-processed foods. More recently, Europe's front-of-pack nutrition logo, Nutri-Score, updated its algorithm to better align with NOVA. Whilst each system remains distinct, both are now considered inter-related and complementary in terms of the health dimensions they measure in foods.

Speaking to Ingredients Network, Professor Serge Hercberg, part of the team behind the Nutri-Score, said that any effort aimed at reducing the consumption and promotion of UPFs “is beneficial from a public health perspective”.

“We are fighting in France, alongside many colleagues, to inform both about the nutritional composition of foods, with the Nutri-Score, and about whether a food is ultra-processed, with a black banner around the Nutri-Score marked UPF for ultra-processed foods,” Hercberg said.

He said numerous scientific studies demonstrate the link between the consumption of ultra-processed foods and many health conditions.

Terra contests this point – especially attempts in one of Brazil's bills to link ultra-processed food consumption to cancer and add warning labels. “The idea is so absurd it is hard even to argue against it. Cancer, like other non-communicable chronic diseases, has many causes: genetics, age, smoking, alcohol, lack of exercise, excess weight, environment. Diet is one part of this, and within diet, so-called ultra-processed foods are a small fraction.”

Terra said Brazilian lawmakers are currently using any WHO document as a stamp of legitimacy to integrate “ultra-processed” into law but she said laws need to have an “objective criterion”, ie an inspector needs to be able to look at a product and know whether it falls under the rule or not. This, she said, is not the case with ultra-processed products.

Outside of Brazil, the US is expected to propose a first definition and create front-of-pack labelling for ultra-processed foods soon and the European Commission has asked its advisory groups for a scientific and ethical assessment, with an opinion due in the first quarter of 2027.

“When everyone is trying to define the same thing at the same time, it is because it has not been defined,” Terra said. “Someone created a new idea; it was tested, and it did not work because no-one could reach a shared conclusion. In science, this is normal. Nothing lasts forever, and ideas that seemed good can be set aside or replaced by better ones.”

Writing in the independent sustainability news publication Impakter, José Graziano da Silva, previous director-general at the Food and Agriculture Organization (FAO) (2012-2019), founder and director of Brazil's Zero Hunger Institute (Instituto Fome Zero) and professor emeritus at the University of Campinas, said the move from Brazil to get WHO to restrict UPFs certainly requires a more nuanced approach than just banning a certain type of food.

Foods designed to be “cheap, long-lasting, hyperpalatable and widely marketed, frequently as substitutes for fresh foods”, for example, are not the same as products that have been through industrial processes such as pasteurization, canning, industrial refrigeration and controlled fermentation, Graziano da Silva said. Similarly, adding fibre, vitamins or minerals to an industrial formulation does not necessarily eliminate the effects associated with hyperpalatability, rapid consumption, the presence of additives, the loss of the original food matrix or the replacement of meals prepared with fresh food.

Looking forward, therefore, he said the overarching purpose of Brazil's new initiative should be to “transform the promotion of healthy and sustainable diets into a global commitment, supported by WHO and FAO, capable of bringing together regulation, production, access and food education. More than restricting products, this is about expanding possibilities – so that real food is accessible and valued, and becomes the easiest choice for everyone.”