Ultra-processed foods: diverging regulatory approaches create new challenges for industry

UPF definitions and labelling requirements gain momentum in Latin America

Colombia is leading the way. A draft proposal published in April 2026 – for which the consultation closed in May 2026 – would introduce specific definitions for UPFs and require an additional rectangular “Advertencia Ultra Procesado” label alongside existing nutrient warnings. If adopted, compliance would extend beyond nutrient thresholds to include processing and ingredient-related criteria.

Furthermore, Chile is moving in a similar direction. Proposed legislation seeks to introduce mandatory UPF labelling and tighter advertising restrictions for children.

US focuses on building a regulatory definition for UPFs

The United States remains focused on definition-building. FDA and USDA are developing a common definition that could underpin future policy and labelling requirements, although the timescale remains unknown.

At state level, however, California has already begun restricting certain UPFs in school meals through AB 1264, demonstrating how policy measures may emerge even before a nationally recognised definition is established.

UK continues a nutrient-based regulatory approach

The UK is taking a different approach. Proposed updates to school food standards, for which the consultation closed in June 2026, would restrict foods commonly associated with UPFs, including HFSS products, sweet baked goods and deep-fried foods, without formally regulating UPFs as a category.

WHO guidance and the potential for global regulatory divergence

Internationally, the World Health Organization (WHO) is developing its first guideline on ultra-processed food consumption, with recommendations expected in late 2026 or 2027.

At the same time, several countries are advancing national definitions, labelling schemes and policy measures. This raises the possibility of increasingly divergent regulatory frameworks, making it more difficult for multinational food businesses to adopt a single global approach to compliance.

How should food manufacturers prepare for evolving UPF regulation?

• Monitor emerging UPF definitions, labelling requirements, implementation timelines and enforcement approaches across key markets
• Assess products against processing-related criteria, including ingredient types, additive use and functional roles, not just nutrient profiles
• Avoid assuming a single harmonised UPF definition will apply across markets and prepare for country-specific requirements

Want to know more?

Leatherhead Food Research members can access our 2025 Regulatory Insight Report on Ultra-Processed Foods, which explores how regulators around the world are defining, classifying and addressing ultra-processed foods. In addition to member reports, our regulatory and scientific experts provide tailored horizon scanning, market-specific assessments and portfolio impact evaluations to help businesses understand how emerging UPF policies may affect labelling, reformulation and product positioning.

For more information on accessing the report, please contact [email protected]