Unfortunately, we’ll have to wait quite a while before California can fulfill that promise — if at all.
The state’s new “Non-Ultraprocessed Certified” program currently relies on information found on a product label, including ingredients, additives and nutrient levels. The law does not specifically require anyone to review how the ingredients or finished products were actually processed. But consumers are increasingly asking not just what’s in their food, but how that food was made.
That question is urgent, but the law gives the state until June 1, 2029—nearly three years from now—to accredit certifiers. The details of its certification process have yet to be developed.
Brands and shoppers looking for meaningful answers today should not have to wait. Furthermore, a certification should tell shoppers something they cannot learn from the package alone. If a seal says a food is “non-ultraprocessed,” the certification should actually examine how the food was made.
For years, nutrition debates have revolved around major nutrients and energy: sugar, fat, protein, sodium and calories. We’ve been taught to compare foods by the numbers on the back of the package and assume that if two products look nutritionally similar, they must be biologically similar too.
In reality, emerging research raises questions about what those numbers miss, including the ways industrial processing can change a food’s physical structure and how we digest it.
To be clear, the issue is not whether to process food at all. Humans have always processed food. Grinding grain, fermenting vegetables, baking bread, making cheese, nixtamalizing corn, drying fruit — these are ancient food traditions that helped nourish civilizations for generations. Many of these methods actually improve nutrient availability, digestibility, safety and preservation.
But there is a big difference between transforming food through these familiar methods and using intensive industrial processes to break ingredients apart, alter their structure — what scientists call the “food matrix” — and reconstruct them. A package can name the ingredients, but it doesn’t tell consumers which processing methods were used.
When foods are industrially fractionated, pulverized, extruded, chemically modified, recombined, flavored, stabilized and engineered for shelf life, that matrix can change. Sometimes dramatically.
The question is whether the methods used to make a particular product support a claim that it’s not ultraprocessed.
Answering that question takes more than reading ingredient lists and nutrition panels. It takes examining information from manufacturers and suppliers about how ingredients were made and how the finished food was produced. That’s the value an independent certification can offer shoppers.
And shoppers need answers now.
Consider rice flour. To most consumers, “rice flour” sounds straightforward. But rice flour can be produced through very different processing methods with very different biological effects, and consumers cannot tell which one was used by looking at the package alone.
Stone-ground, whole rice flour retains much of the grain’s original fiber and structure. In contrast, rice flour that has been processed through industrial methods — such as extrusion, heat, pressure and pre-gelatinization — fragments the starches. This processing significantly increases the flour’s digestibility and reduces feelings of fullness.
These differences matter metabolically. The more the original food structure is disrupted, the faster digestion tends to occur, the more rapidly glucose becomes available and the less work the body must do to process the food. Texture, particle size and structural integrity all influence satiety and metabolic response in ways a standard nutrition label cannot fully capture.
In other words, two products may both list “rice flour” on the label while representing entirely different levels of industrial processing. This is why it’s so critical that non-UPF claims examine not just what is in the food, but what has been done to the food.
This is the kind of nuance that is missing from California’s new certification program. And the danger is that if policymakers have their way, these errors will spread as other states look to California’s flawed framework as a model for creating their own non-UPF claims.
But ultraprocessing is, by definition, about processing.
It’s time to stop pretending that the industrial transformation of food is biologically insignificant simply because a nutrition panel or ingredient list looks acceptable.
A non-UPF claim is a specific promise to consumers. To keep it, we must reveal what the label cannot: how our food was actually made.
Megan Westgate is the founder and CEO of the Non-GMO Project and Non-UPF Verified, with nearly two decades of experience in independent food certification and food system transformation. See nonultraprocessed.org.
Dining and Cooking