This policy brief was written for INRL20160 Introduction to EU Politics at University College Dublin during the 2024/25 academic year. The module asks students to identify a live problem on the EU agenda, weigh the options open to the Union, and set out concrete recommendations. The brief is reproduced here as submitted, and the views expressed are the author’s own.
Executive Summary
The consumption of ultra processed foods (UPFs) is on the rise and directly harming Europeans’ health. This harm takes the form of obesity, and obesity related diseases such as heart disease, diabetes, and live cancer in Europeans. The reduction of these diseases would reduce the amount of health care spending required by EU member states. In order for European Union (EU) citizens to become healthy, they need accurate information and children need protection from predatory marketing. Creating and implementing policies to require accurate labelling and restricting the marketing of UPFs to children is how the EU Commission can accomplish this goal.
Background
Many Europeans are unknowingly consuming UPFs and while simultaneously professing their disapproval of them. A study from the EIT Food Consumer Observatory found “67% of European consumers state that they do not like it when their foods contain ingredients they do not recognise” (2024, pg.14). In addition, four in ten Europeans do not believe that the European Union is doing enough to regulate UPFs (EIT Food Consumer Observatory, 2024). It was assumed that if Europeans were cognisant of what UPFs looked like they would avoid them. However, the study discovered the exact opposite. According to the EIT Food Consumer Observatory, “Plant-based substitutes […] are seen as UPF by about a third (36% and 34%) of European consumers” (2024, pg. 37). This displays a lack of understanding about UPFs and a need for a change.
UPFs were first defined by a team of scientists in Brazil that developed the NOVA food system to classify the levels of processing in foods. The NOVA food system classifies food in four different groups.
- 1. Unprocessed foods. Food that has not undergone any changes. This would include foods like apples, carrots, and eggs. (Monteiro et al., 2019)
- 2. Processed culinary ingredients. Food products that use semi industrial processes to change the form of a single food. This would include olive oil, spices, and flour. (Monteiro et al., 2019)
- 3. Processed foods. Foods that are made by adding ingredients to create a new food product. This would include baked bread, smoked fish, and cheese. (Monteiro et al., 2019)
- 4. Ultra processed foods. Food products created using industrial processes to process, fraction, and chemically modify whole foods into a product that can not be replicated outside of an industrial setting (Monteiro et al., 2019). UPFs commonly have artificial flavours and colouring as well as extra hydrogenated fats and modified starch (Khandpur et al., 2020). Examples of UPFs include carbonated soft drinks, flavoured yoghurts, and chicken nuggets.
A recent study from across nine European countries found a “15% higher risk of becoming overweight or obese for normal weight participants at baseline in the highest quintile of UPF consumption compared to the lowest” (Cordova et al., 2021, Discussion Section). This shows that UPFs pose a threat to the health of Europeans by putting them at the risk of obesity. Secondly, the threat of UPFs is not distributed equally among all citizens, with children from migrant backgrounds, low socio-economic standings, and single-parent houselands being significantly more likely to consume UPFs (Khandpur et al., 2020). The consumption of the UPFs are negatively affecting European’s health and the European Union must take decisive action to curb the rise of ultra processed food.
Current Policy
The core of EU food regulations come from General Food Law Regulation (Regulation (EC) No 178/2002) which created the European Food Safety Authority which provides risk assessments on foodstuffs and scientific opinions to the Council of Ministers, European Commission, and European Parliament (European Commission, 2024). This has resulted in several laws such as the Health Claims Regulation, the Food Information to Consumers Regulation, and the Novel Food Regulation. These regulations work to protect consumers from potentially misleading information and harmful ingredients. However, food labelling and advertising schemes are voluntary and unevenly implemented in the EU (United European Gastroenterology, 2023).
In 2020, the “farm to fork” policy was introduced with the intention of making food systems in the EU more sustainable (European Commission, 2024). This may affect the production of UPFs, which are unhealthy, and rely on large scale industrial processes that harm the environment (Leite et al., 2022). However, this policy does not address the consumption rate of UPFs. As of now there are some regulations that affect certain aspects of UPFs but there is no current European Union legislation directly addressing UPFs which leaves a loophole that companies can exploit.
Policy Recommendations
The proposed solution is to enact an EU-wide “Front of Pack” (FOP) labelling policy on food and drink products as well as a marketing regulation to prevent misinformation and promote healthy eating. These policies would be based on the Chilean Law of Food Labelling and Advertising which required green labels on healthy foods and black labels on UPFs (Taillie et al., 2020). It also banned advertisement of UPFs in children’s media programs and banned UPF companies from using child-targeted marketing in social media (Taillie et al., 2020). The EU needs to set standards to ensure that its citizens have both access to healthy food and the information necessary to make informed decisions. Additionally, United European Gastroenterology (2024) suggests this also would persuade food manufacturers to change the nutritional ingredients of their products in order to become more healthy and therefore more marketable. It would limit the impact of predatory marketing of low nutrient additive food products towards children. Once implemented these regulations would become legally binding in the EU (European Commision, 2024).
The short term expected outcome would be a decrease in consumer purchasing of ultra processed foods. Chile’s Law of Food Labelling and Advertising law resulted in a steady decline in purchases of sugary beverages over a two year period (Taillie et al., 2020). The long term expected outcome would be lower rates of obesity, and obesity related diseases such as heart disease, diabetes, and live cancer in Europeans. The reduction of eating related illnesses would reduce the amount of health care spending required by EU member states.
Bibliography
Cordova, R., Kliemann, N., Huybrechts, I., Rauber, F., Vamos, E. P., Levy, R. B., Wagner, K.-H., Viallon, V., Casagrande, C., Nicolas, G., Dahm, C. C., Zhang, J., Halkjær, J., Tjønneland, A., Boutron-Ruault, M.-C., Mancini, F. R., Laouali, N., Katzke, V., Srour, B., … Freisling, H. (2021). Consumption of ultra-processed foods associated with weight gain and obesity in adults: A multi-national cohort study. Clinical Nutrition, 40(9), 5079–5088. https://doi.org/10.1016/j.clnu.2021.08.009
Food EIT Consumer Observatory. (2024). Consumer perceptions unwrapped: Ultra-processed foods (UPF). EIT Consumer Observatory. https://www.eitfood.eu/files/Consumer-Perceptions-Unwrapped_Consumer-Observatory-Report-1.pdf
European Commission. (2024). Retrieved November 8, 2024, from https://food.ec.europa.eu/horizontal-topics/general-food-law_en
Khandpur, N., Neri, D. A., Monteiro, C., Mazur, A., Frelut, M.-L., Boyland, E., Weghuber, D., & Thivel, D. (2020). Ultra-processed food consumption among the paediatric population: An overview and call to action from the european childhood obesity group. Annals of Nutrition & Metabolism, 76(2), 109–113. https://www.jstor.org/stable/48620374
Leite, F. H. M., Khandpur, N., Andrade, G. C., Anastasiou, K., Baker, P., Lawrence, M., & Monteiro, C. A. (2022). Ultra-processed foods should be central to global food systems dialogue and action on biodiversity. BMJ Global Health, 7(3), e008269. https://doi.org/10.1136/bmjgh-2021-008269
Monteiro, C., Cannon, G., Lawrence , M., Da Costa Louzada, M., & Machado, P. (2019). Ultra-processed foods, diet quality, and health using the NOVA classification system. Food and Agriculture Organization of the United Nations. https://openknowledge.fao.org/server/api/core/bitstreams/5277b379-0acb-4d97-a6a3-602774104629/content
Taillie, L. S., Reyes, M., Colchero, M. A., Popkin, B., & Corvalán, C. (2020). An evaluation of Chile’s Law of Food Labeling and Advertising on sugar-sweetened beverage purchases from 2015 to 2017: A before-and-after study. PLoS Medicine, 17(2), e1003015. https://doi.org/10.1371/journal.pmed.1003015
United European Gastroenterology. (2023). Ultra-processed foods: An EU health crisis. United European Gastroenterology. https://ueg.eu/files/1288/0e9fa1f3e9e66792401a6972d477dcc3.pdf
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