Last week, I posted information and links to documents sent to me anonymously suggesting that the new Nordic Nutrition Recommendations (NNR) had been influenced by the food industry to omit a statement in an earlier draft to reduce consumption of ultra-processed foods.

I have no first hand personal experience with these recommendations and do not want to get in the middle of a dispute over the development of these guidelines.

I do feel strongly that the concept of ultra-processed is an enormous step forward in understanding how to eat more healthfully, backed up as it is by hundreds of observational studies and one extraordinarily well controlled clinical trial (Kevin Hall’s at NIH).  I think enough evidence exists, and the concept is well enough defined, to advise the public to eat less of highly processed food products.

Shortly after my post went online, I received the following letter from Norwegian researchers involved in the NNR process asking me to correct and clarify what I had posted.  I reproduce the letter here with their permission, and with thanks for our correspondence over this issue.  Read what they say and last week’s post, and decide for yourself.

July 12^th 2023

Dear Marion Nestle,

This email is from the Norwegian researchers involved with the recently published Nordic Nutrition Recommendations (NNR2023), including the head of the working group.

We have read your books, followed your daily blogposts for years, and always appreciated your informative and thoughtful letters. However, your post Monday 10th July on NNR2023 and the chapter on ultra-processed foods (UPF) is misinformed, and we believe that your informant has misled you. We would appreciate the opportunity to answer the claims, one by one.

• You: “The backstory here is one of effective food industry lobbying”.
  • This is 100 % untrue. The committee has not been subject to any form of lobbying unless one considers responses to the public hearing as lobbying. In the public hearing, which you have a link to, you cite that we received 60 responses (or to be correct: 58 responses when subtracting the heading and an empty entry) to the UPF chapter, but as the same institution could have several entries, there were 39 unique responses. Of these, 27 represented industry or commercial interests in one way or the other, while 12 responses were from academia.
  • If you read the responses carefully, you will see that absolutely ALL the academic institutions argue that it is premature to give public advice on UPFs. The academic responses came from the following institutions: Lund University, Nofima (a food research institute), Natural Resources Institute of Finland, Norwegian University of Technology and Science (NTNU), Technical Research Centre of Finland, SINTEF Ocean (Norway), RISE Research Institute of Sweden, Norwegian University of Life Sciences, Chalmers Technical College, Sweden’s Agricultural University (SLU), Karolinska, University of Helsinki, University of Lund, Swedish Food Agency, University of Gothenburg, and University of Umeå. (There are more than 12 institutions because several of them merged their responses into one entry).
  • You do not mention that there were three independent peer-reviewers of the UPF review paper, none of which has ties to the food industry
  • It is first and foremost careful listening to the input from the peer-reviewers and the scientific inputs from the public consultation, combined with our own evaluation of the totality of the evidence, that made us land on not having a specific recommendation on UPFs.
    • The arguments against having a recommendation on UPF are nicely summed up in this input to the public hearing (jointly signed by a number of scientists from Sweden): “In summary, the chapter introduces an unspecific concept that is controversial without a detailed discussion about its benefits and limitations. It is questionable whether the concept UPF adds anything beyond existing measures of diet quality since it is merely a proxy that includes both diet (nutrient) quality aspects, additives and processes. It is of outermost importance that NNR is based on solid scientific data and avoids speculations based on model studies and poorly defined exposures to maintain trust and credibility among the public and the research community. As researchers, we consider UPFs as an unspecific and non-scientifically defined concept that will make it difficult to study mechanisms and unravel causality. Instead, we suggest using existing and more well-defined and studied measures of diet quality and make efforts to come up with better ways of measuring food processing per see to allow a scientific evaluation of its potential implications for human health. This could be reflected in a narrative chapter that introduces and discuss the concept of UPF and food processing and their benefits and limitations in a balanced way as well as identifies scientific gaps in our understanding of the role of different processing and additives for health”.
    • As an example, whole-grain bread does not become unhealthy just because it is placed in the UPF group.
• You: “These negative views of the UPF concept differ from the views of the background document (however politely stated) and clearly were influenced by the overwhelmingly negative views of food industry representatives”.
  • Yes, the food industry representatives were negative, but as explained in the previous comment, so were absolutely ALL the Nordic scientists who responded in the public hearing. The result would have been the same regardless of the comments from industry.
• You refer to a summary in English available on online: https://docs.google.com/document/d/10Kf4kuaD1wZNkQJyrdOHdQPvsDqY6O6pytizzBxfpRA/edit?lctg=102461686&pli=1 This is an anonymous summary, but likely written by the same person who is your informant
• You cite your informant who states the following: “I have come to realize that this is not at all about evidence. It’s about power, and who gets to define what’s important in nutrition science. “The establishment” refuses to accept that someone from Brazil, a country they regard as inferior, should be allowed to tell them they have been wrong in their nutritionism-approach. They claim NOVA is based on ideology, not science….And now this is getting in the way of public health”.

This is an outrageous claim and we wonder how anyone can accuse us of something like this. We have the deepest respect for Carlos Monteiro and have followed his research on UPF since he first published his hypothesis in 2009. Like him, we are deeply concerned about the rise of overweight and obesity worldwide and like him, we work on disentangling the causes. We find the UPF concept intriguing scientifically, but it’s premature to use the concept in public advice until it has been refined and better defined.

We are also surprised that you do not mention the large proportion of comments coming from the meat industry and farmer’s organizations regarding both health and sustainability aspects of meat consumption. They have of course been fervently opposed the science advice to reduce meat consumption to maximum 350 grams red meat/week, generating significant media attention and engaging with politicians to dismiss the report. This would itself certainly be an interesting case study. However, the committee again adhered to the science and did not succumb to lobbyism. The same goes for sugars, alcohol and other hot topics. This is contrary to the accusations that the recommendations were influenced by the food industry.

We regret to note that you have shared a letter containing misleading allegations regarding the NNR2023 results on UPFs. The unfounded accusations of NNR2023 seem to come mainly from persons who are also in opposition to the NNR2023 advice on reducing red meat intake, thus being in opposition to a more environmentally sustainable diet. Nonetheless, we do hope that you will look more closely into the final NNR2023 report (not the draft) and modify the damaging and untruthful assertions about the process.

Yours sincerely

Helle Margrete Meltzer, member of the NNR2023 committee, former research director at the Norwegian Institute of Public Health

Rune Blomhoff, head of the NNR2023 committee, professor at the University of Oslo

Jacob Juel Christensen, member of the NNR2023 committee, postdoc at the University of Oslo

Erik Kristoffer Arnesen, advisor to the NNR2023 committee, PhD student at the University of Oslo

The U.K.’s Scientific Advisory Committee on Nutrition (SACN) has released its statement on ultra-processed foods.

It dealt with the NOVA classification system (the one I used in yesterday’s post to define ultra-processed foods).  The committee does not like it much.

Assessment beyond the initial screen identified that the literature is currently dominated by NOVA, raising the risk that any limitations or biases present within the NOVA classification system may be replicated throughout the research literature.
While NOVA also met criterion 2 on a clear, usable definition and criterion 4 on the availability of data on inter-assessor agreement, assessment beyond the initial screen dentified less certainty on the clarity, reliability and feasibility of the system.

The SACN’s conclusions:

The SRs identified have consistently reported that increased consumption of (ultra-) processed foods was associated with increased risks of adverse health outcomes. However, there are uncertainties around the quality of evidence available. Studies are almost exclusively observational and confounding factors or key variables such as energy intake, body mass index, smoking and socioeconomic status may not be adequately accounted for.

…In particular, the classification of some foods is discordant with nutritional and other food-based classifications. Consumption of (ultra-) processed foods may be an indicator of other unhealthy dietary patterns and lifestyle behaviours. Diets high in (ultra-) processed foods are often energy dense, high in saturated fat, salt or free sugars, high in processed meat, and/or low in fruit and vegetables and fibre.

…The observed associations between higher consumption of (ultra-) processed foods and adverse health outcomes are concerning – however, the limitations in the NOVA classification system, the potential for confounding, and the possibility that the observed adverse associations with (ultra-) processed foods are covered by existing UK dietary recommendations mean that the evidence to date needs to be treated with caution.

Comment: Kevin Hall  et al’s well controlled clinical trial of ultra-processed versus merely processed diets is neither discussed nor cited in this statement.  Once again, I have no personal knowledge of how this statement was developed, but the U.K.s Soil Association has published a statement with the provocative title, Sticky fingers of food industry on government ultra-processed food review.

While we’re pleased that SACN has prioritised this review, and has acknowledged that ultra-processed foods are of “concern”, we’re disturbed that the committee’s conclusions may have been skewed by industry ties, conflicted financial interests, and a narrow framing of the science.

…But the committee is also guilty of losing the wood for the trees, failing even to raise concern about how ultra-processed foods have overtaken their own nutritional advice….Most people in the UK are failing to eat such a [healthy] diet, precisely because these foods have been displaced by ultra-processed products. The average child’s diet is more than 60% ultra-processed, and rates of obesity and ill health are rising sharply in turn. …SACN is oddly silent on case for re-balancing the diet and addressing the corporate capture of children’s food.

These omissions should prompt us to look more closely at the composition of the committee. SACN has sixteen members. One is a paid consultant working for Cargill, Tate & Lyle, and CBC Israel (a manufacturer and marketer of fizzy drinks such as Coca-Cola and Sprite); two are in receipt of funding from the meat and dairy industry; one is a shareholder in Sainsbury’s; and five are members of the American Society of Nutrition, which is funded by Mars, Nestlé, and Mondelez. Among SACN’s members is the Chair of International Life Sciences Institute (ILSI) Europe, a body that receives funding from some of the world’s largest food companies, such as Barilla, Cargill, Danone, General Mills, Mondelez, and PepsiCo; and two individuals with financial relationships with the British Nutrition Foundation, an organisation funded by British Sugar, Cargill, Coca Cola, Danone, Greggs, Kellogg, KP Snacks, Mars, McDonald’s, Mondelez, Nestlé, PepsiCo, Tate & Lyle, and Tesco. Two SACN members have been funded by Danone, one of the largest ultra-processed food companies in the world; one sits on the council of the Nestlé Foundation; and another is a former employee of Unilever, with current shares in the company worth “more than £5000”.

These declared interests do not imply corruption or bias on the part of SACN members, but they illustrate how pervasive are industry ties at the interface of science and policy.

I am devoting this week to the pushback against advice to reduce consumption of ultra-processed foods.  It is coming from the food industry, of course, government agencies with ties to the food industry, and nutritionists who focus on  the benefits of nutrients, without contextualizing the foods and diets they come from (“nutritionism”).

For the record, ultra-processed foods are :

• Industrially produced
• Bear little resemblance to the foods they were derived from
• Typically contain additives for color, flavor, and texture
• Cannot be made in home kitchens,
• Are formulated to be irresistable,
• Are associated with excessive calorie intake and poor health
• Are extremely profitable to their makers
• Cannot be made in home kitchens (a brief operating definition)

Ultra-processed food pushback #1: A study from the USDA and authors with conflicted interests

The USDA’s Agricultural Research Service is so proud of this study that it sent out a press release.

Scientists at the USDA Agricultural Research Service’s (ARS) Grand Forks Human Nutrition Research Center led a study that demonstrates it is possible to build a healthy diet with 91 percent of the calories coming from ultra-processed foods (as classified using the NOVA scale) while still following the recommendations from the 2020-2025 Dietary Guidelines for Americans (DGA). The study highlights the versatility of using DGA recommendations in constructing healthy menus.

The Study: Dietary Guidelines Meet NOVA: Developing a Menu for A Healthy Dietary Pattern Using Ultra-Processed Foods.  Julie M. Hess, Madeline E. Comeau, Shanon Casperson, Joanne L. Slavin, Guy H. Johnson, Mark Messina, Susan Raatz, Angela J. Scheett, Anne Bodensteiner, Daniel G. Palmer.  The Journal of Nutrition, 2023.  https://doi.org/10.1016/j.tjnut.2023.06.028.

Purpose: “The purpose of this proof-of-concept study was to determine the feasibility of building a menu that aligns with recommendations for a healthy dietary pattern from the 2020 DGA and includes ≥80% kcal from UPF as defined by NOVA.”

Method: “we first developed a list of foods that fit NOVA criteria for UPF, fit within dietary patterns in the 2020 DGA, and are commonly consumed by Americans. We then used these foods to develop a 7-d, 2000 kcal menu modeled on MyPyramid sample menus and assessed this menu for nutrient content as well as for diet quality using the Healthy Eating Index-2015 (HEI-2015).”

Results: “In the ultra-processed DGA menu that was created, 91% of kcal were from UPF, or NOVA category 4. The HEI-2015 score was 86 out of a possible 100 points.”

Conclusions: “Healthy dietary patterns can include most of their energy from UPF, still receive a high diet quality score, and contain adequate amounts of most macro- and micronutrients.”

 Conflicts of Interest: “MM serves as the Director of Nutrition Science and Research for the Soy Nutrition Institute (SNI) Global. The SNI Global receives funding from soybean farmers via the soybean national checkoff program and via membership dues from companies involved in manufacturing and/or selling soy ingredients and/or soyfoods. GHJ serves as Senior Advisor to the McCormick Science Institute. JLS serves on advisory/consultant boards for Simply Good Foods, Quality Carbohydrates Coalition, and the Sustainable Nutrition Scientific Board and has received funding from the National Institutes of Health, Taiyo, Barilla Foods, and the USDA in the past 12 mo. The other authors report no conflicts of interest.”

Funding: This work was supported by USDA Agricultural Research Service project grant #3062-51000-057-00D.

Comment:  I can think of only one reason for doing a study like this: to cast doubt on the concept of ultra-processed foods (UPF) and all the research showing that UPF diets induce people to eat more calories (see the study by Kevin Hall et al) and are strongly associated in hundreds of studies with poor health, evidence that by this time is overwhelming and incontrovertible.  Why now?  Because the 2025-2030 Dietary Guidelines Advisory Committee has been charged with examining the relationship of UPF to heart disease risk.

The first rule of the ‘Playbook” is to cast doubt on the research, which is what we are seeing here.  The message to reduce consumption of ultra-processed foods makes good sense for health reasons.  But such advice is very bad for the profits of food companies making junk foods.

The USDA’s Agricultural Research Service is a marketing arm of the food industry,.  It is heavily conflicted.

For one thing, the Healthy Eating Index is not useful for this purpose; it is strictly nutrient-based, which is not the issue here.  And the Dietary Guidelines are careful to leave plenty of room for eating junk foods and to say not one word about UPF.

I think the UPF concept is so solidly backed up by evidence that it is here to stay.  But it is so threatening to food companies making UPF products, and the USDA is so captured by the food industry (checkoff programs, anyone?) that it is understandable why they are so eager to cast doubt.

Thanks to the half dozen or so readers who sent this one to me, to Ted Kyle for calling it “oxymoronic healthy eating,” and  Kevin Hall for pointing out that the healthfulness of this diet is assumed, not tested:

The long-awaited report on aspartame from the International Agency for Research on Cancer and the WHO and FAO Joint Expert Committee on Food Additives (JECFA) are now out.  These agencies jointly issued two documents.

A press release

Citing “limited evidence” for carcinogenicity in humans, IARC classified aspartame as possibly carcinogenic to humans (IARC Group 2B) and JECFA reaffirmed the acceptable daily intake of 40 mg/kg body weight.

A summary of the findings

• The [IARC] working group classified aspartame as possibly carcinogenic to humans (Group 2B) based on limited evidence for cancer in humans (for hepatocellular carcinoma, a type of liver cancer)…There was also limited evidence for cancer in experimental animals…In addition, there was limited mechanistic evidence that aspartame exhibits key characteristics of carcinogens, based on consistent and coherent evidence that aspartame induces oxidative stress in experimental systems and suggestive evidence that aspartame induces chronic inflammation and alters cell proliferation, cell death and nutrient supply in experimental systems.
• The [JEFCA] Committee concluded that the data evaluated during the meeting indicated no reason to change the previously established acceptable daily intake (ADI) of 0–40 mg/kg body weight for aspartame. The Committee therefore reaffirmed the ADI of 0–40 mg/kg body weight for aspartame…Based on the results of the oral carcinogenicity studies of aspartame, the absence of evidence of genotoxicity, and a lack of evidence on a mechanism by which oral exposure to aspartame could induce cancer, the Committee concluded that it is not possible to establish a link between aspartame exposure in animals and the appearance of cancer.

If this feels crazy-making, I’m with you.

For starters, I’ve never seen a scientific report released this way—essentially by leakage and press release before the research is published where it can be reviewed independently.

To summarize the chronology:

• June 29: Reuters releases leaked information that aspartame is soon to be declared a carcinogen (I wrote about this in a post on July 6)
• June 29: American Beverage Association releases statement: “There is a broad consensus in the scientific and regulatory community that aspartame is safe.”
• July 1: Vox publishes a an article with the provocative title, “The WHO is about to declare aspartame can cause cancer. Here’s why you should listen.”
• July 12: Reporters tell me that they participated in a press conference with WHO and IARC to discuss what the reports will say when they are released at 12:30 a.m. ET on July 14.
• July 12: Anahad O’Connor writes in the Washington Post: “Does aspartame pose a health risk? Here’s what the science says” (I’m quoted in it).
• July 12 and 13: The agencies send reporters copies of press releases on embargo (see above), but not the published data.
• July 13: Reporters get copies of a statement from the FDA disagreeing with IARC.
• July 14:  Everything comes off embargo, including these four pieces:

1. Research article in Lancet Oncology:  Carcinogenicity of aspartame, isoeugenol, and methyleugenol 
2. Infographic
3. Q & A
4. Featured News page on the evaluation of aspartame

Here’s what I think of all this: if aspartame is a carcinogen, it’s a weak one.

But it is artificial and off my dietary radar.  It’s not essential in human diets.  I don’t like its taste and I don’t like all the iffy questions about how it is metabolized.  I avoid it.

You don’t want to avoid it?  JEFCA says you can have 9 to 14 cans of diet soda a day without exceeding tolerable limits.  If you want one once in a while, it is highly unlikely to hurt you.

But a much better idea is getting out of the sweetened-drinks habit.  If you must have something sweet to drink, try adding fruit juice to water.

The World Health Organization has just come out with a new report on protecting children from the harms of marketing unhealthy food to kids.

Some conclusions from research on the effects of marketing unhealthy foods to kids:

• Across studies, the most frequently marketed food categories were fast food, sugar-sweetened beverages, chocolate and confectionery, salty and savoury snacks, sweet bakery items and snacks, breakfast cereals, and desserts.
• Reductions in children’s exposure to food marketing were more often found with: mandatory policies; policies designed to restrict food marketing to children, including those older than 12 years; and policies that used a government-led nutrient profile model to determine the foods for which marketing was to be restricted.
• Reductions in the power of food marketing were more often found with: mandatory policies; and policies designed to restrict food marketing to children, including those older than 12 years.
• Policies to protect children from the harmful impacts of food marketing would be highly cost-effective or cost-saving.
• Policies to protect children from the harmful impacts of food marketing can be expected to reduce health inequities.
• In HICs [high-income countries], policies to protect children from the harmful impact of food marketing are largely acceptable to
  the public, but industry has generally opposed government-led restrictions.
• Some countries have successfully implemented policies, demonstrating that policies are acceptable to government and policy-makers and feasible to implement.

Therefore, WHO recommends that policies:

• Be mandatory
• Protect children of all ages
• Use a government-led nutrient profile model to classify foods to be restricted from marketing;
• Be sufficiently comprehensive to minimize the risk of migration of marketing to other media, to other spaces within the same medium or to other age groups
• Restrict the power of food marketing to persuade.

Yes!

WHO has just given governments a mandate to take action.  Go for it!

My distant (but dearly loved) cousin, the food package designer Michael Kravit, thought I would enjoy seeing this example of first-rate food marketing—and of a healthy product yet.

First, open the box.

Cut. Scoop. Enjoy!

You aren’t sure how?  The company even supplies a video.

I’d like to see more like this.

Well here’s a big surprise.  The USDA is taking a look at concentration in agribusiness.

TODAY: Webinar at 1:00 p.m. ET.  Register here.

Here’s what this is about:

This report details issues surrounding market concentration in agribusiness, particularly in three agribusiness sectors where concentration has increased over time: seeds, meatpacking, and food retail. Market concentration and its impact on competition have attracted growing public scrutiny. Critics argue that many industries have grown too concentrated, with fewer firms competing with one another and a consequent weakening of competition. The report covers the consolidation in each of these industries, explains the driving forces behind increased concentration, and examines public policies aimed at encouraging competition, focusing on the implementation of merger policy.

This report has lots of interesting tidbits about those three industries.

• Two firms, DuPont Pioneer and Monsanto, control 71.6% of U.S. corn and 65.9% of U.S. soybeans.
• Four U.S. meat firms (not necessarily the same ones) control 85% of steers and heifers, 67% of hogs, 55% of turkeys, and 53% of chickens.

But what is shocking to me about this report is what it does not say.

It does not refer to or even cite Phil Howard’s book: Concentration and Power in the Food System: Who Controls What We Eat?

I wrote about Howard’s book when it came out in a new edition.

How could the USDA’s economists fail to mention Howard’s analysis of the global seed industry (since updated).

It’s great the USDA is taking this on.  But if you really want to know what’s going on in industry concentration, read Phil Howard’s book first.

A reader who wishes to remain anonymous sent me an account of the development of the new Nordic Nutrition Recommendations, pointing out what they do not contain: a recommendation to reduce ultra-processed foods [Note: this is an updated and slightly corrected version of what was first posted on July 9].

Indeed, on pages 253-255 (this is a long report), you will find this statement:

The backstory here is one of effective food industry lobbying.

The Nordic Nutrition Recommendations do not say:  reduce consumption of ultra-processed foods.

The story begins with two authors who were asked to sum up the health effects of ultra-processed foods, and to advise the committee writing the recommendations.  They did so.  Their initial background paper concluded with these recommendations:

(1) Limit the consumption of ultra-processed foods.

(2) Choose less processed form of foods within each food group when possible.

(3) Cook at home and choose freshly prepared foods when eating out.

The committee revised the background paper.  It omitted the three recommendations but concluded:

Recommendations to limit ultra-processed foods, and choose foods of lower processing level, when possible, may enhance and support several of the existing FBDGs [food-based dietary guidelines] and help individuals select more healthful foods that align with the overall NNR2022 [last years Nordic Nutrition Recommendations] guidelines within each food category. For example, such advice would support choosing plain, unsweetened yoghurt instead of flavored, sweet yoghurt; choosing oatmeal or muesli based on grains, nuts, and dried fruits over sweetened, refined breakfast cereals; and choosing chicken breast/thighs over chicken nuggets.

The revised document was opened for public comment and a hearing.  A great many representatives of food companies objected to saying anything negative about ultra-processed foods.  This Excel spreadsheet lists the 60 people who commented and their main objections.

After the hearing, the committee preparing the recommendations wrote a draft report based on the comments.  The section on ultra-processed foods is on pages 152-153.  It begins:

There is currently no consensus on classification of processing of foods, including UPFs. The dominating UPF classification (NOVA classification group 4) contains a variety of unhealthy foods, but also a number of foods with beneficial health effects.

It also says:

Health effects. Regular intake of UPF encourages over-eating and intake of foods in the UPF category of the NOVA classification has been suggested associated with increased risk of obesity, cardiovascular disease, type 2 diabetes, cancer, depression, and premature mortality …However, no qSRs [qualified systematic reviews] support these suggestions.

These negative views of the UPF concept differ from the views of the background document (however politely stated) and clearly were influenced by the overwhelmingly negative views of food industry representatives.

The draft report also was opened for public comment.  These comments also are listed in an Excel document. Some favor the changes benefiting the food industry; others—but many fewer—object to them (these last are summarized in yet another document).

The final Nordic Nutrition Recommendations are somewhat of a compromise between public health and food industry views, but generally favor the food industry position.  The new Nordic Nutrition Recommendations are less critical of the UPF concept, but do not say “reduce consumption of ultra-processed foods.”

The NOVA food classification system, which first defined ultra-processed foods, was published by Carlos Monteiro, a professor of public health at the University of São Paulo, and his colleagues in 2009.*  About the Nordic recommendations, my informant writes:

I have come to realize that this is not at all about evidence. It’s about power, and who gets to define what’s important in nutrition science. “The establishment” refuses to accept that someone from Brazil, a country they regard as inferior, should be allowed to tell them they have been wrong in their nutritionism-approach. They claim NOVA is based on ideology, not science….And now this is getting in the way of public health.

My take-home lesson:  The food industry came out in force on this issue and greatly overwhelmed the few comments of public health advocates.  The message here seems clear: public support for reduction of ultra-processed food needs to be widespread, clear, and forceful.

*Definition of ultra-processed foods

• Industrially produced
• Bearing no evident relationship to the foods from which they were derived
• Formulated to be irresistably delicious (if not addictive)
• Usually containing color, flavor, and texture additives
• Often high in salt, sugar, and fat (but these are culinary ingredients that do not in themselves make foods ultra-processed)
• Cannot be made in home kitchens (because they are industrially produced and contain ingredients unavailable to home cooks)

Addition

An additional document was sent to me after this post and the response from nutritionists involved in the NNR, which I posted the following week.  It is from the authors of the background document expressing their concerns about the changes made.