Consumer

Ultra-processed foods: the ANSES opinion

April 7, 2025

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Addressing the growing public health concern surrounding ultra-processed foods (UTPs), this document unveils the expert opinion of the French National Agency for Food, Environmental and Occupational Health Safety (ANSES, 2024).

In a field often focused on nutritional profiles, this report offers a novel and comprehensive assessment by specifically characterizing ultra-processed foods through the lens of hazardous processing methods and their potential to generate neoformed substances with significant health impacts.

This original approach provides a scientifically robust foundation to orient future investigations into the intricate relationship between food processing and health outcomes.

Context: food consumption trends

The impetus for this extensive evaluation arises from observed trends in food consumption. Studies such as INCA 3 (2014–2015) — ANSES’s third survey on the food consumption and eating habits of the French population — have documented an increasing reliance on processed products, particularly among younger consumers.

This shift has contributed to a growing disconnection between individuals and their awareness of the nutritional quality and composition of the foods they consume, as the increasing prevalence of processed and ultra-processed products often obscures the origin, content, and health implications of dietary choices.

International health agencies and public health authorities increasingly recommend limiting the consumption of ultra-processed foods, in light of growing evidence associating their intake with the development of non-communicable diseases (NCDs).

ANSES opinion on ultra-processed foods, objectives

To address the complexities of ultra-processed food consumption and its health impacts, the ANSES investigation pursued a set of interrelated objectives:

identifying hazardous processing methods, by assessing which food processing techniques may lead to the formation of neoformed substances;
reviewing classification systems, through a critical comparison of existing models — such as the NOVA classification — to evaluate their strengths and limitations in capturing the true impact of food processing;
evaluating epidemiological data, to investigate the associations between ultra-processed food consumption and adverse health outcomes, including increased risks of chronic non-communicable diseases (NCDs);
determining the factors contributing to the harmfulness of ultra-processed foods, with the aim of identifying actionable levers to reduce the risks linked to their consumption;
proposing future research directions, by underscoring the need for more robust methodologies to quantify risk and inform consumer guidance.

The core of the ANSES opinion lies in its comprehensive analysis of processing techniques, chemical hazards, and the resultant classification of foods based on their propensity to generate neoformed substances.

Processing methods and biochemical risks

Industrial food processing employs modular technology, diverse food matrices, and tailored unit operations to meet societal and environmental demands. Processes involve transfers (movement, energy, matter), reactions (chemical, biochemical, microbiological), and considerations of scale, such as time and space (Bimbenet et al., 2007). Processing tends to reduce variability in biological raw materials while influencing health, sensory, and nutritional properties. Some examples to follow:

heat treatments can be applied indirectly (via heat exchangers or autoclaves) or directly (through radiation, steam injection, or ohmic heating). High temperatures (Augustin, 2011; Espinosa et al., 2020) and high pressures (EFSA, 2022) enhance food safety but may introduce chemical risks or reduce vitamins (Anses, 2022);
food composition may also be altered by over 300 food additives, which are currently authorized in the EU (EFSA, 2025), and around 750 processing aids that are being used in various sectors. However, while food additives must be declared on labels, processing aids are transient and unlisted.

Food processing can lead to the formation of neoformed substances — compounds such as acrylamide, polycyclic aromatic hydrocarbons (PAHs), furan compounds, nitrosamines, and oxidized triglycerides — which pose potential toxicity risks. Despite this, many alterations in natural biochemical compounds remain insufficiently studied (Barabási, Menichetti, & Loscalzo, 2020). The ANSES risk analysis focuses on 130 identified food-related hazards, with particular attention to neoformed substances; however, risks related to food contact materials (FCMs) are not included within the scope of this assessment (Anses, 2020).

Prioritization method

Due to the complexity of chemical reactions during food processing, defining neoformed substances can be challenging. The 2018 ANSES report proposed a prioritization method based on identifying processes and raw materials most likely to generate these substances without directly predicting toxicity. The approach ranks unit operations first, then classifies foods based on processing methods and raw material properties using multi-criteria decision-making.

This report follows the 2018 ANSES report recommendations, focusing on the likelihood of neoformed substance formation rather than general chemical hazards. Note that additives were excluded (their risks are already assessed at the EU level), and microbiological risks were not considered. We must say that omitting additives from this targeted analysis may therefore limit the comprehensiveness of the risk assessment and overlook emerging evidence from recent food safety research.

The ELECTRE III method for food processing risk assessment

To evaluate the potential formation of neoformed substances in processed foods, the ELECTRE III method — a multi-criteria decision-making (MCDM) approach — was applied. This method, part of the ELECTRE family of outranking techniques developed by Bernard Roy in the 1960s, enables the ranking and prioritization of alternatives based on multiple, often conflicting, criteria:

application in food processing analysis. The ANSES study included a representative selection of foods undergoing various technological and agro-industrial processes. These processes were categorized by unit operations — such as heat treatments, chemical and biological processes, high hydrostatic pressure, mechanical or shearing actions, electrical and radiation treatments, extractive and refining steps, and specialized operations like freeze-drying — and by the intrinsic properties of raw materials. Key raw material attributes included unsaturated lipids, proteins, reducing sugars, antioxidants, water activity, and pH deviation;
multi-criteria evaluation and weighting scenarios. Six core criteria were used to assess unit operations: temperature, duration, pressure, chemical reactivity, ionizing radiation, and UV exposure. These were weighted based on expert judgment across several scenarios — from equal weighting to models that emphasized specific factors such as high temperature, prolonged duration, and chemical reactivity. One scenario specifically excluded ionizing radiation to evaluate its influence on overall prioritization.

For food prioritization, the criteria were structured into two categories:

the number and nature of processing steps likely to generate neoformed substances, and
the susceptibility of raw materials to chemical changes. Various weighting configurations were tested to determine how each factor influenced the likelihood of neoformed substance formation, offering a comprehensive framework for risk-based food process ranking.

Classification of unit operations and foods regarding neoformed substances

This section of ANSES opinion details how unit operations and foods were classified according to their capacity to generate neoformed substances:

data for 52-unit operations were ranked using the Electre III method, and the operations were grouped into three categories: most likely, moderately likely, and least likely to form neoformed substances;
a sensitivity analysis confirmed the stability of this ranking across different weighting scenarios.

Discussion and additional considerations

Experts noted that temperature and duration are primary factors in neoformed substance formation, especially in processes such as roasting and grilling. These factors, along with pressure and UV exposure, reflect the overall energy applied to food, suggesting the possibility of using a single energy-based criterion.

Moreover, certain unit operations can help reduce or eliminate neoformed substances. Examples include:

enzymatic treatment with asparaginase prior to heat processing can lower acrylamide levels, and supercritical CO₂ extraction can reduce acrylamide in roasted coffee;
separation and refining processes (as used in the sugar industry) help remove unwanted compounds;
heat treatments may also inactivate enzymes that facilitate the formation of neoformed substances (quinones or polyquinones, synthesized from phenolic compounds by polyphenol oxidase, PPO), and bleaching treatments (at 70–90°C) help prevent undesirable reactions that affect color and texture (formation of pheophytins by the oxidation of chlorophylls).

Existing classifications of foods based on processing and their relevance

Several frameworks categorize foods based on processing level and technological transformation. The main classifications include:

NIPH (2007, Mexico) – categorizes foods by production scale and tradition
IARC-EPIC (2009, Europe) – classifies based on processing intensity and preparation
NOVA (2010-2019, Brazil) – groups foods by ingredient complexity and formulation
IFPRI (2011, Guatemala) – differentiates by processing stages and convenience
IFIC (2012-2015, USA) – defines categories by processing purpose and usage
USP (2015, Brazil) – focuses on ingredient types, processing, and additives
FSANZ (2014, Australia/New Zealand) – assesses processing impact on food structure
UNC (2015, USA) – classifies by physical, chemical, and biological transformations
SIGA (2018, France) – evaluates industrial ingredients, additives, and nutrition

Analysis of the relevance of classifications for identifying neoformed substances

Current food classification systems primarily assess processing intensity, food composition, and nutritional impact. However, they do not directly account for the chemical transformations (i.e., the formation of neoformed substances).

For instance, while NOVA and IFO classify foods based on processing levels, they do not address the chemical reactions that occur during processing.

Technological classifications such as IFPRI provide indirect insight but still fall short of systematically evaluating the relationship between processing methods and neoformed substances.

Description and analysis of the NOVA classification

The NOVA system categorizes foods into four groups (Classes) based on their industrial processing level:

unprocessed or minimally processed foods: foods with little to no transformation, including fresh, frozen, or dried fruits, vegetables, meats, and milk;
processed culinary ingredients: ingredients derived from natural sources and used in cooking, such as oils, sugar, salt, and starches;
processed foods: foods altered by the addition of salt, sugar, or oils (e.g., canned vegetables, cheese, and fresh bread);
ultra-processed foods (UPFs): foods formulated with industrial ingredients and additives, such as packaged snacks, soft drinks, and instant noodles.

While NOVA is widely accepted for public health research and dietary guidelines, its suitability for assessing neoformed substances is limited. It recognizes processing impacts on food structure and nutrient content, yet its lack of specificity means it does not assess compositional changes due to processing.

Consequently, some minimally processed foods may still contain harmful neoformed substances (e.g., fried potatoes can contain acrylamide), indicating a need for refinement that considers processing intensity factors such as heat treatments and pressure.

UPFs and chronic disease risk

A systematic review of the literature assessing the weight of evidence was carried out to evaluate the epidemiological association between the consumption of ultra-processed foods and the risk of chronic diseases. ANSES followed a structured and transparent methodology:

developed a protocol including PECO criteria (Population, Exposure, Comparator, Outcome) – a framework used to structure research questions, to clearly define the population, the exposure being studied, the comparator group, and the desired outcomes;
focused on prospective cohort studies to assess long-term effects;
prioritized studies published in peer-reviewed journals, with clear definition of food processing categories (especially NOVA 4).

Data extraction

Data selection from the included articles, along with risk of bias analysis and weight of evidence assessment, covered 12 prospective cohort studies — primarily from Europe and North America — involving large adult populations. These studies evaluated high consumption of ultra-processed foods (UPFs) using food frequency questionnaires and dietary records, and monitored disease incidence over multiple years.

Results

Most studies reported a positive association between high ultra-processes foods (UPF) consumption and increased risk of:

obesity and weight gain
type 2 diabetes
cardiovascular diseases
overall mortality
certain cancers (e.g., breast cancer).

The associations were often dose-dependent, with stronger risks at higher levels of ultra-processed foods (UPF) intake.

Summary and conclusion of the review

The objective of this analysis was to explore potential links between the consumption of ultra-processed foods (UPFs) and chronic non-communicable diseases (CNCDs) through a systematic literature review with a weight of evidence assessment. Ten studies published up to June 2023 met the inclusion criteria set by ANSES Human Nutrition. Although no specific food classification system was required, all studies used the Nova classification, focusing on Nova class 4 foods.

The studies analysed four cohorts, with dietary intake assessed through either 24-hour recalls or food frequency questionnaires (FFQs), the latter being less precise. None of the studies focused on vulnerable groups such as children, the elderly, or pregnant women.

All studies adjusted for total energy intake (TEI), allowing assessment of Nova 4 food effects independent of calorie intake. Further adjustments for Body Mass Index (BMI) and dietary composition showed minimal impact on results, suggesting the associations are not solely due to weight or nutrient differences.

The review found preliminary evidence linking higher Nova 4 food consumption with increased risks of type 2 diabetes, overweight/obesity, cardiovascular diseases, all-cause mortality, and some cancers (breast cancer in women, colorectal cancer in men). No association was found with prostate cancer, and evidence was inconclusive for hepatocellular and head and neck cancers. Due to the limited number of studies and low overall evidence, further research is needed.

Analysis and conclusion of the ANSES expert groups

The analysis emphasizes the link between food processing and the formation of neoformed substances (e.g. acrylamide, polycyclic aromatic hydrocarbons), which may pose health risks. A prioritization of food processing operations revealed that not only the number but also the type of processes and characteristics of the food matrix influence the formation of these substances, though scientific evidence on matrix-related effects remains limited. The method’s main limitation is its inclusion of all neoformed substances without assessing their health impact.

When compared with the Nova classification system — widely used in epidemiology — it appears that Nova focuses more on food formulation (e.g. presence of additives) than on processing techniques. The classification is based on vague, non-exhaustive lists, often supported by subjective examples that may not apply across countries. Despite this, studies using Nova classification have shown preliminary evidence associations between high consumption of class 4 (ultra-processed) foods and increased risks of obesity, diabetes, cardiovascular diseases, several cancers, and mortality. These associations persisted even after adjustments for total energy intake and diet composition, suggesting other factors at play.

To strengthen the evidence, further studies are needed — particularly in specific populations (e.g. children, elderly) — and should control for energy intake and diet quality. The mechanisms proposed for these associations include the presence of harmful neoformed substances, contact material contamination, additives and processing aids (especially cosmetic ones), and the synergistic ′cocktail effect′ of these compounds. The hyperpalatability of ultra-processed foods may also drive excessive intake. Research should continue to identify hazardous processes and substances, especially those unique to industrial processing, and prioritize them for toxicological evaluation.

ANSES conclusions and recommendations

The growing public health burden of non-communicable diseases (NCDs) in developed countries, often linked to nutritional factors like high blood pressure and cholesterol, underscores the need to strengthen diet and physical activity measures in public policy. In France, actions have included food safety controls, regulation of additives and processing methods, and initiatives like PNNS and PNAN promoting better nutrition and physical activity.

Despite these efforts, recent findings show limited improvement, prompting questions about gaps in public health strategies. One emerging hypothesis is the role of ultra-processed foods (UPFs), which may be contributing to NCDs but remain insufficiently explored in current policies.

To evaluate this, ANSES reviewed the scientific basis of UPF classifications, focusing on the widely used NOVA system. This classification links high consumption of ‘NOVA 4’ foods (UPFs) with increased risks for seven out of ten health indicators, including all-cause mortality. However, the weight of evidence is weak, as most findings rely on one or two studies and show inconsistencies.

ANSES points out a few areas where the NOVA classification system could benefit from further refinement, including:

the inclusion of a broad range of criteria — such as additives, packaging, and marketing – that are not exclusively tied to processing;
a lack of clarity and consistency, which may lead to varied interpretations among researchers;
an opportunity to better address potential risks associated with harmful substances formed during food processing.

Given these considerations, ANSES recommends that existing classifications, such as NOVA, undergo further scientific evaluation to enhance their suitability for informing public health recommendations and policy frameworks. It recommends exploring:

the impact of energy-dense food products on energy balance;
formulations that encourage overeating;
broader consumption-related risks (e.g. fast eating, disrupted eating patterns, social context).

ANSES therefore calls for new studies to assess causal links and better understand how food composition and energy intake contribute to health outcomes. It also stresses the need to identify specific food processes that may pose health risks.

Future directions

The analyzed ANSES opinion opens the door to refining how UPFs are considered in public health. Its future research priorities are the health effects of UPFs, providing clear definitions and improve the classification methods as well as a contribution to public debate and regulatory frameworks related to UPFs. It also continues its work on front-of-pack nutrition labelling such as Nutri-Score, including its development, validation and the monitoring of its impact.

One possible direction ANSES could follow – (not yet confirmed) – is one suggested by Serge Hercberg: adding a black banner with the warning “ultra-processed food” around the NutriScore logo. It is conceivable that this label could eventually be limited only to UPFs identified as critical, based on ANSES’s more nuanced scientific approach, rather than a blanket application to all NOVA 4 foods.

Current debate and controversaries

The debate around ultra-processed foods (UPFs) is intensifying, especially with growing public interest in metabolic health and the rise of weight-loss drugs like Ozempic and Wegovy from Novo Nordisk. In this context, a belated critique of the NOVA system risks undermining the positive effects it has already produced — namely, greater awareness among citizens, industry actors, and policymakers about the health risks linked to UPFs.

At the same time, a scientific debate grounded in NOVA — one that acknowledges its merit — could open the door to a more nuanced evaluation of UPFs. By applying a risk-benefit analysis, it might be possible to reclassify certain products not just based on processing level, but on their actual impact on health.

Striking this balance — between the communicative power of NOVA and improved scientific precision — could be crucial for shaping the next phase of nutrition policy, both in France and beyond.

Interim conclusions

ANSES’s assessment highlights the significance of hazardous processing of ultra-processed foods and the formation of neoformed substances as key contributors to potential health risks. Its analysis prioritized processing methods that are more likely to generate these substances, while recognizing that food classifications, such as NOVA, offer valuable insights but may benefit from further refinement in capturing these chemical transformations.

While preliminary epidemiological evidence links high UPF consumption to increased NCD risk, more research is needed to confirm causality and the role of neoformed substances.

Future efforts should focus on identifying specific processing-induced hazards, refining food classification to include chemical risks, and conducting robust epidemiological studies controlling for various factors. ANSES recommends strengthening public health strategies and exploring enhanced front-of-pack food labeling to address the potential risks associated with ultra-processed foods based on a deeper understanding of their processing.

Dario Dongo, Iudita Sampalean

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