• The Non-GMO Project released its “Non-UPF Verified” Standard earlier this month. The release follows the launch of the new certification standard earlier this year.
  • The Standard, which attempts to define so-called “ultra-processed foods” (UPF), prohibits the use of any ingredient contained in “Annex B – Harmonized Prohibited Ingredients List,” which it indicates reflects a “selected collection of prohibited ingredients from quality standards and governmental regulations.” The Standard also divides food processing methods into prohibited, conditional, and permissible categories, which are in turn divided based on alleged differences in degree of processing (the permissible bucket consists of methods deemed to be “minimal” or “moderate”). A non-exhaustive (and very short) table (A.1) groups certain processing methods into these categories.
  • Notably, the processing criteria only apply to “ingredients declared on the product’s ingredient panel” and not to “sub-ingredients or processing aids that are not required to appear on-pack under applicable labeling regulations.”
  • The Standard ostensibly doesn’t apply to processing methods that are “demonstrably essential for food safety,” but it permits conditionally processed foods only up to 30% of the finished product, “regardless of food safety justification.” The Standard also contains limits on added sugars.
  • There is no consensus on how to meaningfully classify foods based on processing, and the science regarding the effects of so-called “ultra-processed food” remains unsettled. Indeed, the Standard incorporates ingredient bans and added sugar limits, neither of which directly relate to the term “processing.”