Non-UPF Verified Sets a New Standard for Ultra-Processed Foods
This article first appeared in the December 2025 issue of Presence Marketing’s newsletter.
By Steven Hoffman
In mid-November, an international team of 43 scientists released a landmark series of papers in The Lancet concluding that ultra-processed foods (UPFs) now pose a “clear global threat” to public health. Drawing on more than 100 long-term studies, Reuters reported that the series links higher UPF intake to increased risk of obesity, Type 2 diabetes, cardiovascular disease, cancer, depression, and all-cause mortality.
Coverage in outlets from The Guardian and ABC News to NPR underscores the gravity of the findings. One analysis noted that UPFs are associated with harm to every major organ system in the body, and that these products are rapidly displacing fresh and minimally processed foods worldwide. University of North Carolina nutrition researcher and Lancet series coauthor Barry Popkin told NPR, “We can say now that truly ultra-processed food represents a clear global threat to our health—not only our physical health but also mental health in terms of its impacts on depression.”
At the same time, a growing body of consumer and market research points to a widening trust gap. Many shoppers want to avoid UPFs but say they can’t easily tell what qualifies. A recent New York Times Well column explored why ultra-processed products are so hard to resist and so ubiquitous in modern diets, and highlighted the way industrial formulations can override normal satiety signals and blur the line between “food” and “edible product.”
Against this backdrop, the Non-GMO Project’s new Non-UPF Verified Standard lands at a pivotal moment for CPG brands, retailers, and the entire natural and organic products ecosystem.
From GMOs to UPFs: The Non-GMO Project widens its lens
On Nov. 12, the Non-GMO Project formally announced Version 1.0 of its Non-UPF Verified Standard, described as “the nation’s first comprehensive framework” for defining and verifying foods that are not ultra-processed, and called it the “first Non-UPF Verified standard to address the ultra-processed foods crisis.”
The new certification builds on the Non-GMO Project’s 18-year record of third-party verification and its iconic butterfly seal, now found on more than 63,000 products that represent an estimated $50 billion in annual sales.
“Around the world, more people are waking up to the realization that much of what fills our grocery carts is no longer truly food,” said Megan Westgate, founder and CEO of the Non-GMO Project and Non-UPF Verified, at a recent webinar unveiling the new standard. “Doctors and researchers increasingly describe these products as ‘processed edible substances’—industrial formulations engineered for palatability and shelf life rather than nutrition.”
Westgate is careful to say this is not an attack on processing per se. As she told Food Business News: “Processing itself isn’t the enemy. It’s how and why it’s done that matters. The Non-UPF Standard defines a middle ground where convenience and nourishment can genuinely coexist.”
In practice, that “middle ground” is defined by a rigorous ingredient and processing criteria, which are detailed in the Non-UPF Verified Standard v1.0.
Why ultra-processed foods are under fire
The Lancet series and surrounding news coverage sharpen a distinction many in the natural channel have understood for decades: It’s not just what’s in food, but also how it’s made.
The Guardian’s coverage of the Lancet research noted that more than half of the average diet in the U.S. and U.K. now consists of UPFs, with some low-income and younger populations getting up to 80% of their calories from these products. Citing CDC data, ABC News reported that Americans on average consume over half of their daily calories from UPFs.
The Lancet authors point to several mechanisms by which UPFs drive harm:
Disrupted food structure and “hyper-palatability” that encourage overeating and rapid absorption of refined starches and sugars.
High levels of added sugar, sodium, and unhealthy fats.
Widespread use of cosmetic additives and ultra-refined ingredients, some of which may alter gut microbiota or expose consumers to contaminants such as phthalates.
Aggressive marketing and product design that exploit biological reward pathways, particularly in children (MAHA Commission).
In the NPR report, Lancet series coauthor Marion Nestle, professor emerita of nutrition and food studies at NYU and author of “Food Politics,” drew a direct line between the science and the need for policy and marketplace action. She noted that some countries, including Chile, have already shown that warning labels, marketing restrictions, and school food reforms can curb UPF intake. “It’s time to take on the industry,” Nestle said. “They’ve got to stop.”
The Lancet series and recent media reporting all make the point: Ultra-processed foods are not just one more dietary risk factor. They are a structural driver of global chronic disease—and the food system will not change without clear definitions, strong incentives, and credible labels.
‘Disconnected’: What consumers are telling us
In October, the Non-GMO Project released a consumer research report titled “Disconnected,” which summarized the attitudes of U.S. shoppers toward UPFs and the modern food system. Some of the topline numbers from “Disconnected” and related research are striking:
A 2024 Non-GMO Project survey found that 85% of Americans want to avoid ultra-processed foods, but most say they feel overwhelmed and unsupported in trying to do so.
Internal research from the Non-GMO Project’s Food Integrity Collective showed that 68% of shoppers actively try to avoid UPFs, and 70% say they need clearer labeling or third-party verification.
New Hope Network reported that 72% of Americans say they are trying to avoid ultra-processed foods, signaling a powerful demand across mainstream and natural retail.
“Disconnected” emphasized that consumers feel the food system is “out of their hands” — dominated by large corporations using engineered ingredients that are disconnected from natural food sources.
In other words, shoppers are ahead of policy. They are already looking for ways to opt out of UPFs, but they lack tools they can trust. That, more than anything, is the market gap the Non-UPF Verified Standard aims to fill.
The architecture of the Non-UPF Verified Standard
The Non-UPF Verified Standard approaches ultra-processing through two essential frameworks: ingredient integrity and formulation, and processing limits.
1. Ingredient integrity and formulation
The standard targets ingredients that are either emblematic of ultra-processed formulations or under scientific scrutiny for metabolic, neurological, or gut impacts. Collectively, these criteria are designed to protect what the standard calls structural integrity, nourishment, and transparency, steering innovation away from “cosmetic” ingredients and toward minimally processed building blocks:
Non-nutritive and bio-transformed sweeteners (such as aspartame, sucralose, stevia extracts, erythritol, and other sugar alcohols) are prohibited as sugar substitutes. Minimally processed stevia leaf preparations may be allowed only at flavor-level use, not as a core sweetener.
Added sugars are capped by category, typically ranging from low single-digit percentages (by dry weight) for soups, sauces, snack foods, and proteins, to stricter limits for beverages and breakfast foods, and up to roughly 20% for desserts and 40% for some confectionery categories.
Gums, thickeners, hydrocolloids, and texturizers produced via industrial degradation or fermentation—such as carrageenan, microcrystalline cellulose, polysorbates, polydextrose, xanthan gum, and maltodextrin— are largely prohibited.
Artificial colors and certain processed oils are excluded.
Natural flavors are confined to use cases where the corresponding “real” ingredient is present and may not be used to mask the absence of whole foods.
2. Processing limits and food structure
Not all processing is equal. The Non-UPF Verified Standard distinguishes among permissible, conditional, and prohibited methods and requires that:
At least 70% of a product’s weight (or dry weight, for certain categories) must be minimally or moderately processed using permissible methods that preserve the food matrix.
Up to 30% may be “conditionally processed”—for example, certain protein isolates or powders—if they meet specific criteria.
High-impact chemical, structural, thermal, or biological modifications are not allowed, including synthetic biology and 3D-printed ingredients.
The intent is to address the very features UPF critics highlight: extensive fractionation and recombination of ingredients, aggressive “engineering” of texture and flavor, and techniques that break down food structure to the point where the body no longer recognizes the substance as food.
As the standard notes, UPF is as much about the degree and purpose of processing as about individual ingredients. The Non-UPF framework is one of the first to operationalize that insight in a way that is auditable at the product level.
The full standard is publicly posted at NonUltraProcessed.org. The Project has signaled that it will update its prohibited ingredient list annually based on emerging science and pilot feedback.
Pilot brands, early adopters and the reformulation challenge
If Non-UPF Verified is to matter, it has to show up on shelves. The early signs are promising.
A pilot cohort of 16 brands—including both mission-driven emerging companies and established names—has been working with the Non-GMO Project and independent technical administrators to test the Non-UPF verification model across nearly every aisle. In addition, New Hope Network reported that 200 brands are already on the wait list, and that the Non-UPF Verified seal is expected to begin appearing on packages in 2026.
In Douglas Brown’s New Hope Network feature, “Non-UPF Verified: Must-Knows for Natural Brands,” Westgate characterized the program as “a movement, not just a mark,” and noted that reformulation will be essential in categories dependent on gums, stabilizers, and added sugars. “We have some cleaning up to do in this industry,” she said. “Reformulations are needed. We need less sugars and gums. It’s going to be a process. But it does seem like brands are really paying attention.”
For many natural and organic manufacturers, the reformulation challenge may feel familiar. Non-GMO and organic standards forced reevaluation of supply chains and ingredient decks; Non-UPF now pushes deeper into how those ingredients are combined and processed.
For mission-driven brands backed by retailers that cater to ingredient-savvy shoppers, the upside could be substantial:
Differentiation in crowded categories such as ready-to-eat meals, plant-based meats, beverages, and snacks, where formulations can drift toward UPF territory even in “natural” sets.
Alignment with policy trends, as HHS, USDA, and FDA explore definitions and potential regulatory approaches to UPFs.
Deeper consumer trust, particularly among shoppers who already use Non-GMO Project and organic seals as navigational tools in the aisle.
For contract manufacturers and ingredient suppliers, however, this is more than a marketing play—it’s a roadmap for where formulation business is likely headed.
Industry response: Caution, criticism, and opportunity
The Non-UPF standard does not exist in a vacuum. Trade groups and conventional food manufacturers are watching closely and some are pushing back.
Food Business News noted that while states such as California have begun to legislate around certain additives and ultra-processed foods, groups like the Grain Foods Foundation argue that some UPFs can fit into healthy dietary patterns, especially when fortified or reformulated.
More broadly, many industry stakeholders have urged federal agencies to avoid definitions that hinge on processing intensity, arguing that frameworks like the NOVA classification system paint with too broad a brush and risk demonizing shelf-stable, affordable foods.
Westgate and her team acknowledge these debates. In FoodNavigator-USA’s report on the standard, she described the NOVA system as foundational but “not built to solve at the product level,” and emphasized that Non-UPF Verified is designed to be auditable, enforceable, and feasible within current food system realities.
At the same time, the Lancet series and global media coverage are shifting the terms of the debate. ABC News quoted experts who warn that global UPF proliferation is a major public health threat and that voluntary, incremental steps are unlikely to be enough.
In that context, voluntary third-party standards such as Non-UPF Verified may serve a dual role as a pre-regulatory signal to policymakers that industry is capable of responding to the science, and as a competitive differentiator for brands and retailers.
What it means for natural & organic CPG leadership
For marketers in the natural and organic products community, the Non-UPF Verified Standard is not just another badge on the front of the pack. It is a concrete response to three converging forces:
Escalating science: The Lancet series, joined by years of epidemiology, clinical research, and meta-analyses, makes a compelling case that UPFs are a unique risk category and that their impact is global.
Consumer anxiety and demand for coherence: Shoppers are hungry for standards that make sense of conflicting information and give them real agency.
Regulatory and reputational risk: As HHS and USDA gather input on UPF definitions, and as advocacy groups press for action, companies that stay tethered to hyper-processed formulations may find themselves on the wrong side of both policy and public opinion.
For natural and organic brands—many of which built their identity on getting ahead of GMO, pesticide, and synthetic additive concerns—Non-UPF Verified is an invitation to lead again. That leadership could take several forms:
Portfolio mapping: Assess where current SKUs fall on the processing spectrum, and identify quick wins for reformulation versus long-term R&D projects.
Supplier engagement: Challenge ingredient partners to develop minimally processed alternatives to emulsifiers, texturizers, and refined oils that violate the Non-UPF criteria.
Retailer collaboration: Work with retailers to pilot Non-UPF assortments, shelf tags, and consumer education in key categories.
Storytelling and transparency: Use packaging, digital channels, PR, and in-store activations to explain how Non-UPF Verified complements existing organic, non-GMO, regenerative and other claims.
A call to action
The publication of the Non-UPF Verified Standard is not the final word on ultra-processed foods; however, it is the opening of a new chapter. Science will continue to evolve. Policymakers will debate definitions and regulatory levers. Industry groups will push back, negotiate, and in some cases innovate.
But the direction is clear. When The Lancet, The New York Times, The Guardian, NPR, ABC News, and the natural products trade press all make the same point—that ultra-processed foods are undermining global health and consumer trust—the question for our industry is not whether to respond, but how quickly.
For brands that built their business on “better for you,” Non-UPF Verified offers a unique opportunity to help redefine what “better” means at the level of processing itself, and to align product portfolios with a future in which real food—and the integrity of how it’s made—once again takes center stage.
For more information on the standard, please refer to the full Non-UPF Verified Standard v1.0, the Non-GMO Project’s launch announcement, and the Disconnected research report, available via the Non-UPF team’s Google Drive link.
Steven Hoffman is Managing Director of Compass Natural Marketing, a strategic communications and brand development agency serving the natural and organic products industry. Learn more at www.compassnatural.com.