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  • Why not just regulate ultraprocessed food (UPFs)?

Why not just regulate ultraprocessed food (UPFs)?

Because ‘ultra-processed food’ (UPF) is not a uniform biological category. Not all items are equally addictive or harmful, and a single regulatory category is easily gamed through industry reformulation. A serious policy approach requires definitions that track mechanism, such as hyper-palatable formulations, refined carbohydrate load, and additive architecture, rather than marketing categories alone. This could take years and result in court delays that entangle regulators and litigators.

As a descriptive category it is useful, but as a single regulatory unit it is vulnerable. The report notes that treating ultra-processed food as one category is poorly supported and easily exploited; a stronger approach is to anchor claims in ingredient architecture and biological response.

Restrictions on UPF advertising to children on digital platforms, including on websites and in computer games is a separate issue from the discussion relating to cumulative carbohydrate exposures - which can include spikes from UPF consumption, and the risk of chronically elevated and unstable blood sugar and insulin.


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