The Non-GMO Project Publishes its Non-Ultraprocessed Foods Standard

The Non-GMO Project this week made good on its promise to create a program to certify (or disqualify) foods as not ultraprocessed. And they’ve developed a seemingly comprehensive set of rules to that end.

The Non-Ultraprocessed Foods (Non-UPF) Verification Program officially launched this week by publishing its standard. We’ve carried a number of news stories about the effort and what its goals and thinking were, but this is the first time it published its specifics.

"The Non-UPF Verified Standard" attempts to “offer a clear, evidence based framework rooted in scientific findings and aligned with consumer expectations. It identifies products that avoid the core hallmarks of ultraprocessing, including both engineered additives and industrial processes that degrade food structure and function.”

Those were the two main components or culprits: processing and ingredients.

“While some emerging policies focus narrowly on specific ingredients, ultraprocessing by definition demands that we evaluate processing itself. This standard does exactly that—recognizing that how a food is made is just as important as what goes into it,” the announcement said.

The core, however, is a list of about 289 ingredients that would clearly make a food or beverage ultraprocessed. The A (acesulfame-potassium) to Z (zirconium compounds) list includes the usual suspects: the seven petroleum-based colors targeted by the FDA, all synthetic non-nutritive sweeteners and all gums, thickeners and texturizers. But also most refined or processed oils and sodium-based preservatives, flavor enhancers, leavening agents, chelators, emulsifiers and functional salts (but not naturally occurring sodium.

Also prohibited are steviol glycosides and monk fruit extract -- emphases on glycosides and extract; natural versions of those two plant-based sweeteners apparently are permitted. And the standard even sets limits for acceptable levels of added sugars (from a low of 2% in meats, chips and soups to 40% for candies).

“The use of natural flavors represents a complex and often opaque area of food formulation,” the group admitted. “Because of this variability, and to avoid creating unnecessary barriers to participation or innovation, compliance with this section is optional for Version 1 of the Non-UPF Standard. Participants are still required to provide information related to natural flavor use to support data collection and inform the development of more specific and mandatory requirements in a future version of the Non-UPF Standard.”

This is indeed Version 1 of the Non-UPF Standard. The group implied there might be revisions and refinements along the way.

This list was created from ingredients prohibited by a number of other quality standards and governmental regulations, including European Union regulations, PCC Community Markets, Whole Foods Market and applicable U.S. state legislation.

The processing component

Processing is just as important as ingredients. The standard considers as processing methods in biological, chemical, mechanical and thermal, and within each category sets up three levels of processing: permissible, conditional and prohibited.

For example, within biological, traditional fermentation is permitted, industrial fermentation (resulting in highly modified ingredients) is conditional but prohibited are precision fermentation, biomass fermentation and enzymatic interesterification.

There’s a long list of permissible mechanical processes: cutting, high moisture extrusion, forming, homogenization, even high-pressure processing, microfiltration and ultrafiltration and membrane and centrifugal separation. Only 3D printing is prohibited.

“Grounded in current research, consumer interest and real-world feasibility, it is designed to support innovation without compromising integrity, helping both manufacturers and consumers navigate a food system in urgent need of repair,” the group said.

The document does pay homage to the Nova Classification System, one of the first looks at ultraprocessing, developed by researchers at the University of São Paulo, Brazil, in 2009. It classified food into four groups:

1. Unprocessed or minimally processed foods
2. Processed culinary ingredients
3. Processed foods
4. Ultraprocessed products

And the Non-UPF Project notes a number of foundational contributions from that scheme, especially elevating the link between processing and public health.

“Nova named the problem. It wasn’t built to solve it at the product level,” the document said. Nova falls short, especially for brands and retailers, by classifying categories of food, not specific products or formulations, not differentiating processing intensity or structural modification, and treating all Group 4 products the same — from neon candy to fortified whole-grain cereal.”

The Non-UPF Project is a creation of the Non-GMO Project, which certifies products as not containing genetically engineered ingredients, and its Food Integrity Collective. And there is a fee structure for getting certified. Then you get to use the stamp.

The standard was developed with the help of a number of natural foods processors: Amy's Kitchen, Bear, Califia Farms, Caulipower, Heray Spice, Levelle Nutrition, Olyra, One Mighty Mill, Simple Mills, Spindrift and Yes Bar.

Also see their consumer research on ultraprocessed foods, from October.

See the whole standard in a 28-page PDF here.

Or start your search at www.nonultraprocessed.org/standard.