Consumer reading food label in supermarket

What are the differences between nutrient profiling models and ultra-processed food classifications?

30 July 2024 | Lewis Wallis, Regulatory Affairs Advisor and Ed Allen, Regulatory and Scientific Affairs – Nutrition and Sustainability Lead

1. Introduction

The UK House of Lords Select Committee on Food Diet and Obesity was appointed on 24 January 2024 and is considering the role of foods, such as ‘ultra-processed foods’ (UPFs) and foods high in fat, sugar and salt (HFSS) in a healthy diet, including how they influence health outcomes. As part of the inquiry, the Committee has been inviting speakers from across the food system to participate in oral evidence sessions, alongside providing the opportunity for the submission of written evidence.

Although there is an expected overlap between some products that are categorised as both UPF and HFSS, the different approaches used to classify products mean that some products may be considered UPF but not HFSS and vice versa.

Here we provide an overview of each classification system and the differences between them.

2. Nutrient Profiling Models

In recent years, concerns regarding the nutritional composition of products and those that may contribute to non-communicable diseases, such as obesity, diabetes, cancer and heart disease, has extended beyond analysis for meeting nutrition labelling requirements, to evaluation of whether individual products are considered ‘healthy’.

There are a number of reasons why businesses are evaluating the nutritional composition of product portfolios, including for:

Marketing restrictions (e.g. UK High Fat Sugar Salt (HFSS) restrictions)
Reformulation (e.g. voluntary salt/sugar reduction targets)
Nutrition claims (e.g. “low fat”, “high protein”, “source of fibre”)
Front-of-pack nutrition labels (e.g. voluntary UK Multiple Traffic Lights scheme, Nutri-Score (used in some EU Member States))
Public place food criteria (e.g. school food standards)
Taxes (e.g. UK Soft Drinks Industry Levy (SDIL))
Consumer preferences and expectations (e.g. demand for products perceived as ‘healthier’)

The concept of ‘nutrient profiling’ seeks to address product-level evaluation and has been defined as “the science of classifying or ranking foods according to their nutritional composition for reasons related to preventing disease and promoting health”¹. Applying the concept includes the use of ‘Nutrient Profiling Models’ (NPMs) that assess the nutritional composition of products to determine product ‘healthfulness’. In effect, a NPM takes the nutrition data commonly found on product labels and uses it to calculate a ‘score’ or categorise products based on set thresholds for nutrients of concern (e.g. saturated fat, sugar, salt).

Although there is yet no widespread consensus on what considerations a NPM should take into account (e.g. using values per 100g vs per serving, single thresholds for food and drink vs category-specific thresholds, nutrients to include/exclude), there is a project underway by the Access to Nutrition Initiative that is seeking alignment with various stakeholders on the principles that should form the basis of an NPM². The Food Data Transparency Partnership (FDTP) health working group is also considering metrics that should be used to evaluate portfolios for voluntary reporting.

In the UK, there are two policy-relevant NPMs that are used for different purposes: The UK Nutrient Profiling Model (UK NPM) , also known as the Ofcom model, used for categorising products as high in fat, sugar and/or salt (HFSS) for marketing and advertising restrictions, and the voluntary Front-of-Pack Nutrition Labelling scheme that assigns colour coding based on nutrient thresholds (e.g. red for high fat, high saturated fat, high sugar and high salt)³.

3. HFSS

In GB (England, Scotland and Wales), current and future legislation is being implemented that restricts the promotion and placement of products high in fat, sugar and/or salt (HFSS).

To determine products that are categorised as HFSS, an NPM is applied that considers the balance of ‘positive’ and ‘negative’ nutrients of a product. It assigns points to each component in the model (i.e. energy, saturated fat, sugar, sodium, protein, fibre, fruit, vegetables and nuts) and uses the output ‘score’ to determine whether products within in-scope categories are restricted from product promotion and placement both in-store and online.

4. Front-of-Pack Nutrition Labelling

Nutrient profiling models can be used to determine Front-of-Pack Nutrition Labelling (FOPNL). There is no single internationally recognised model used and instead different countries have developed their own based on their policy preferences and market context. For example, the UK developed a voluntary scheme published in 2013 that assigns red, amber or green colours to nutrient values based on pre-determined thresholds, which equate to high, medium and low proportions respectively (also know as the Multiple Traffic Light scheme).

Examples from other countries include the Health Star Rating (Australia and New Zealand) that displays a rating between 0.5 and 5 stars, and warning labels used in some Latin American countries to highlight where products contain excess amounts of nutrients of concern (e.g. saturated fat, sugar, salt).

The diversity in models not only confuses consumers who travel between countries but also challenges food manufacturers who must adapt to varying nutrient thresholds and labelling requirements when marketing their products internationally.

5. Level of Processing

Another way that products can be categorised is by their level of processing. However, there is yet no universally agreed or legal definition for these categorisations (e.g. ‘ultra-processed’), and there are multiple models for categorising them.

The NOVA classification system is widely used within the literature to categorise products based on processing and, in 2023, the UK Scientific Advisory Committee on Nutrition (SACN) reviewed the available evidence and suggested that it was the only model potentially relevant to the UK population⁴. However, it has not been applied to UK legislation or formally recognised by UK regulatory authorities as a dietary analysis tool for evaluating product healthfulness.

NOVA classification system

The NOVA system categorises products into 1 of 4 categories⁵:

1 = unprocessed, e.g. raw materials from plants (e.g. fruits, grains) or animals (e.g. eggs, milk), or minimally processed foods such as those having undergone limited processes e.g. drying, chilling, freezing to extend shelf-life
2 = processed culinary ingredients, e.g. oils, sugar, salt
3 = processed foods produced by combining two or more products from groups 1 and 2 and apply further processing, e.g. cooking, baking
4 = ultra-processed foods, i.e. products including ‘formulations of ingredients, mostly of exclusively industrial use, typically created by series of industrial techniques and processes’

Comparing the UK NPM and the NOVA classification system

Purpose

UK NPM: It was developed by the Food Standards Agency (FSA) 2004-5 and categorises foods/drinks based on their nutritional composition.
NOVA: It was developed by researchers in Brazil and classifies foods based on the level of processing.

Focus

UK NPM: Nutritional composition of foods.
NOVA: Level of processing that foods, and their ingredients, undergo during production.

Classification criteria

UK NPM: Uses a scoring system based on the nutrient content of foods, including both ‘negative’ nutrients (such as energy, saturated fat, sugar and sodium) and ‘positive’ nutrients (such as protein, fibre, and percentages of fruits, vegetables and nuts). Foods and drinks are scored, and those with a score above a certain threshold are considered ‘less healthy’.
NOVA: Foods are categorised into four groups: 1) unprocessed or minimally processed foods 2) processed culinary ingredients 3) processed foods 4) ultra-processed food and drink products.

Applications

UK NPM: Used to prevent ‘less healthy’ products from featuring in children’s TV advertising, volume promotions and prominent locations both in-store and online.
NOVA: Used in nutritional epidemiology and public health to assess dietary patterns and their relationship with health outcomes and has been used in dietary guidelines (e.g. Brazil).

6. What does the future hold for classification models/systems?

As the level of processing is evaluated irrespective of a product’s nutritional composition, such categorisations (e.g. NOVA, which does not distinguish between foods with very different nutritional value which may be subject to similar degrees of processing) are not classified as NPMs. Nonetheless, there is ongoing research investigating how markers of processing can be incorporated into NPMs, for example, by including the presence of flavourings, colours, sweeteners, and other additives⁶.

An alternative NPM that integrates the concept of UPFs is the Pan American Health Organisation (PAHO) NPM developed in 2015. The model sets criteria for identifying processed and ultra-processed (NOVA 3 and 4) products that are excessive in ‘negative’ nutrients/components. The PAHO model targets the general population and has been used as the basis for front-of-pack warning labels and taxation policies in some countries (e.g. Mexico, Chile and Colombia). Although the model applies to all NOVA 3 and 4 products, the thresholds for warning labels and taxation policies are based on the nutritional composition of products and not the level of processing.

A perspective published in 2022⁷ proposed the concept of ‘ultra-formulated foods’ as a way of further sub-categorising UPFs based on formulation vs processing (with a focus more on product formulation, rather than only its level of processing, for determining how ‘healthy’ a product is), and further attempts to sub-categorise may take place in the future.

It is likely that efforts will continue to try and integrate the concepts of UPF and HFSS and untangle the potential health impacts of affected products. However, there is currently no legislation in place targeting UPF products as categorised by the NOVA classification system.

The current restrictions in GB apply to those products categorised as high in fat, sugar and salt (HFSS) using the UK NPM.

How we can help

Need advice on how HFSS restrictions could impact your business or help with calculating Nutrient Profiling Model scores for your products? Contact our Regulatory Affairs team, who can help with any HFSS and NPM regulatory requirements and ultra-processed food classifications.

Our experienced team of regulatory experts can help you ensure that your products are compliant with the legislative requirements of your target market. We offer a valuable, extensive and authoritative information and advisory service to help clients stay compliant with food regulations in more than 80 countries.

We also have a training course specifically on nutrient profiling models; Nutrient profiling models: high fat sugar salt (HFSS) restrictions, front-of-pack nutrition labelling (FOPNL) and nutrition claims – This half day course provides an overview of HFSS policy and divergence in the devolved nations; the latest restrictions and applying the UK Nutrient Profiling Model (NPM) to products; and insight into international developments and divergences in front-of-pack labelling schemes.

About Lewis Wallis

Lewis is a Regulatory Affairs Advisor in the UK/EU team at Campden BRI and has previous industry experience from working for a large multi-national company. He has contributed to and written material for a variety of outputs including research publications, technical reports, food law updates, blog articles, white papers, book chapters, eBooks and guidance documents. Lewis presents on Campden BRI courses and has provided guest lectures for new product development and food policy students covering a variety of Regulatory Affairs topics.

He is a member of the IFST Food Regulatory Special Interest Group that work to host thought-provoking discussion workshops which feature experts presenting on the latest regulatory hot topics.

Alongside his current role, Lewis is a Postgraduate Researcher at University of Leeds and draws upon his regulatory expertise to conduct research at the intersection of food legislation and consumer behaviour, particularly focusing on measures designed to promote healthier and more sustainable food choices within digital food environments (e.g. online retail, meal delivery apps, social media). He has conducted research on the implementation of High Fat Sugar Salt (HFSS) restrictions within online retail and his work involves the application of nutrient profiling models to products promoted and sold in digital settings.

About Ed Allen

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Need advice?

Need advice on how ultra-processed food classifications or HFSS restrictions could impact your business, or help with calculating Nutrient Profiling Model scores for your products?

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