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What counts as ultra-processed food? How to check a recipe

On 9 October, Ocado opened a "Simple Ingredients" aisle with more than 350 products, none containing artificial colours, emulsifiers, stabilisers or flavours. Even so, Ocado was careful to say the aisle isn't free of ultra-processed food (UPF), because the UK has no agreed definition of UPF. Most food teams are in the same spot: buyers, shoppers and journalists all ask the question, and there's no official test to answer it with.

The short answer is that a food counts as ultra-processed under NOVA, the classification most UPF research uses, if its recipe contains at least one ingredient or additive you wouldn't use in a home kitchen, such as maltodextrin, soya protein isolate, a flavouring or an emulsifier. Retailers like Tesco, Waitrose and Ocado then add their own rules on top. Here's how both work, and how to check your recipes against them.

Why the UK still has no official test for UPF

As of October 2026, ultra-processed food isn't defined anywhere in UK food law.

The Scientific Advisory Committee on Nutrition (SACN), which advises the four UK governments, published a rapid evidence update on processed foods in April 2025. It called the link between eating more UPF and poorer health "concerning", but the evidence is almost entirely observational, so it can't show that processing itself causes harm. SACN didn't adopt a definition. At its June 2026 horizon-scanning session it kept processed food and health on monitoring, rather than starting a full review.

The government has followed SACN's lead. When the House of Lords Food, Diet and Obesity Committee asked for an operational definition of UPF, the government's January 2025 response said a full SACN assessment would be needed first, once there was enough evidence.

It's the same gap we've seen with "healthy", which also has no agreed definition in UK food law. So when someone asks whether your product is UPF, they're almost always using one of two things: NOVA, or a retailer's own rules. You need to know both.

What is NOVA?

NOVA is the classification behind nearly every UPF study and headline. Researchers led by Carlos Monteiro at the University of São Paulo developed it, and it sorts food by how much and why it has been processed, not by nutrients. When SACN screened eight classification systems for UK use, NOVA was the only one that met its criteria, though SACN has reservations about it.

NOVA has four groups:

  1. Unprocessed or minimally processed foods. Fresh fruit and veg, eggs, milk, plain meat and fish, dried pulses, plain oats, plain yoghurt. Drying, freezing, pasteurising or grinding doesn't move a food out of this group.
  2. Processed culinary ingredients. Oils, butter, sugar, salt and flour, the things you cook with rather than eat on their own.
  3. Processed foods. Group 1 foods with group 2 ingredients added, like most cheeses, simple bread, tinned vegetables in brine, salted nuts and cured meats. They usually have two or three ingredients and are still recognisable as a version of the original food.
  4. Ultra-processed foods. Industrial formulations made mostly or entirely from substances you wouldn't find in a home kitchen. Monteiro's examples include soft drinks, packaged snacks, mass-produced packaged bread, margarines and spreads, flavoured breakfast cereals, nuggets, sausages and other reconstituted meat products.

Group 4 is a big share of what the UK eats. Analyses of National Diet and Nutrition Survey data put UPF at about 51% of adults' energy intake and up to 68% for 12 to 18 year olds, according to a 2026 review in the British Journal of Nutrition.

What pushes a product into NOVA group 4?

It isn't the length of the ingredient list, and it isn't processing on its own. NOVA looks for marker ingredients, set out by Monteiro and colleagues in Public Health Nutrition in 2019, and they fall into two groups.

The first is food substances rarely or never used in home cooking. These include sugars such as fructose, high-fructose corn syrup, fruit juice concentrates, invert sugar, maltodextrin, dextrose and lactose; modified oils (hydrogenated or interesterified); protein sources such as hydrolysed proteins, soya protein isolate, gluten, casein, whey protein and mechanically separated meat; and soluble or insoluble fibre. The paper adds a catch-all for any other source of protein, carbohydrate or fat that isn't a whole food, a processed food or a culinary ingredient, which is how other isolates, like pea protein, end up counted too.

The fibre point catches a lot of better-for-you NPD. Adding inulin or another isolated fibre to hit a "source of fibre" claim makes a product NOVA 4, even when it improves the NPM score (we looked at the formulation side in fibre in functional drinks).

The second is what NOVA calls cosmetic additives, the ones that change how a food looks, tastes or feels. That covers flavourings, flavour enhancers, colours, emulsifiers, emulsifying salts, non-sugar sweeteners and thickeners, plus anti-foaming, bulking, carbonating, foaming, gelling and glazing agents.

One marker is enough to put a product in group 4, so a short ingredient list that reads clean can still be NOVA 4 if it includes a "natural flavouring" or whey protein. Additives that only keep a food safe, such as preservatives and antioxidants, don't move it to group 4 by themselves, because NOVA allows them in group 3.

Is cheese ultra-processed?

Usually not. A cheddar made from milk, salt, starter cultures and rennet is NOVA group 3, a processed food. Processed cheese is different. Slices, triangles and spreads made with emulsifying salts (sodium citrates or phosphates) are group 4, because emulsifying salts are one of NOVA's markers. Flavoured cream cheeses can end up there too if they contain thickeners or flavourings.

So the same food, made to a different recipe, lands in a different group. You see the same split in other everyday categories:

  • Bread. Flour, water, yeast and salt is group 3. Add an emulsifier such as E471 or E472e, which many sliced loaves use to keep the crumb soft, and it becomes group 4.
  • Breakfast cereals. Monteiro's own example: plain oats, plain corn flakes and shredded wheat are group 1, the same foods with added sugar are group 3, and with flavours or colours they're group 4.
  • Plant drinks. An oat drink made from oats, water, oil and salt sits in group 3. Many barista versions add gellan gum, emulsifiers or flavouring, which takes them to group 4.
  • Protein shakes and bars. Whey protein and soya protein isolate are markers in their own right, so most of these are group 4, however good the nutrition panel looks.

Why NOVA and HFSS can give opposite answers

NOVA ignores nutrients completely. The nutrient profiling model (NPM), which decides whether a product is HFSS, only looks at nutrients (our HFSS scoring walkthrough shows how it works). So the two tests often disagree.

A flavoured protein shake with no added sugar can sail through the NPM and still be NOVA 4. A block of cheddar is NOVA 3, yet it carries red traffic lights for fat, saturated fat and salt. SACN made the same point in its 2025 update: the UPF category only partly overlaps with foods high in saturated fat, salt or sugar.

For a food team, this means passing one test tells you nothing about the other. Some retailer briefs now ask for both. Waitrose's Good Health label, for example, wants minimal additives and non-HFSS status at the same time (we covered that in Tesco and Waitrose additive bans: what it means for your recipe).

Every retailer is writing its own UPF definition

Without a legal definition, retailers have each drawn their own line:

  • Ocado's Simple Ingredients aisle (launched 9 October 2026) takes products with recognisable ingredients and no artificial colours, emulsifiers, stabilisers or flavours. Fortified flour and live cultures are allowed.
  • M&S's Only range, which features on the Ocado aisle, has eight ingredients or fewer and no artificial colours or preservatives.
  • Tesco has banned or restricted 114 additives across its own-label range.
  • Waitrose Good Health combines an ingredient test with a nutrition test.

None of these is NOVA. Ocado's rules overlap with NOVA on emulsifiers and flavourings, but a rule written around additives won't flag things like maltodextrin or whey protein, which NOVA counts as markers. A product could get onto the Simple Ingredients aisle and still be NOVA 4.

Shoppers are pushing all of this along. Ocado says searches for "unprocessed" are up 178% year on year, and Clariti research cited at the launch found 48% of shoppers have changed what they buy based on ingredient information.

How to check if your recipe is ultra-processed

You can run a rough NOVA check on any recipe in about ten minutes:

  1. List every ingredient, including sub-ingredients. A seasoning blend, a chocolate chip or a stock cube can bring in its own emulsifier or flavouring, and that's where most surprises come from.
  2. Flag anything on either marker list. One flag means the product is NOVA 4.
  3. Write down what each flagged ingredient does. Texture, shelf life, sweetness and a protein claim are the usual reasons. You need to know the job before you can replace it.
  4. Model the swap before you trial it. Taking out an emulsifier usually costs shelf life, swapping a sweetener for sugar moves your NPM score, and yeast extract in place of a flavour enhancer adds salt. Recalculate the nutrition panel and NPM score from the new recipe. If sugar is in the brief too, see our guide to clean label sugar reduction.
  5. Note which definition you're answering to. NOVA, Tesco, Waitrose and Ocado can give four different answers for the same product, so be clear with each buyer about which one you've checked.

What this means for a food team

If you're a founder-led brand selling on a "simple ingredients" story, check that it holds up under NOVA. That's the version journalists use, and Open Food Facts shows a NOVA group on product pages.

If you're a manufacturer or co-manufacturer, you'll increasingly get briefs that just say "make this not UPF". Ask which definition the client means before anyone touches the recipe, because removing Tesco's additives and removing NOVA markers are different jobs with different costs.

If you supply catering or food service, expect the question in menu reviews and tenders. Having your recipes already sorted by NOVA group puts you ahead of most suppliers.

Every swap costs something, in shelf life, salt, sugar, NPM score or the claim on pack. It's much cheaper to find that out on paper than after a failed shelf-life trial.

Frequently asked questions

What counts as ultra-processed food?

Under the NOVA classification, a food is ultra-processed if it's an industrial formulation containing at least one ingredient rarely used in home cooking, such as maltodextrin or soya protein isolate, or a cosmetic additive such as a flavouring, emulsifier, colour or sweetener. As of October 2026, the UK has no legal definition, so retailers including Tesco, Waitrose and Ocado use their own rules.

What is the NOVA classification?

NOVA is a food classification system developed by researchers at the University of São Paulo. It sorts foods into four groups by how much they've been processed: unprocessed or minimally processed foods, processed culinary ingredients, processed foods and ultra-processed foods. Most UPF research uses it, but it isn't part of UK law.

Is cheese an ultra-processed food?

Most natural cheese, such as cheddar made from milk, salt, cultures and rennet, is NOVA group 3 (processed), not ultra-processed. Processed cheese slices and spreads made with emulsifying salts are NOVA group 4, as are cheeses with added flavourings or thickeners.

Is bread ultra-processed?

It depends on the recipe. Bread made from flour, water, yeast and salt is NOVA group 3. Bread containing emulsifiers such as E471 or E472e, flavourings or other marker ingredients is NOVA group 4, and many sliced supermarket loaves fall into that group.

Do preservatives make a food ultra-processed?

Not on their own. Under NOVA, processed foods in group 3 can contain additives that preserve them. Cosmetic additives such as flavourings, colours, emulsifiers and sweeteners, or ingredients like maltodextrin and whey protein, are what put a food in group 4.

Is ultra-processed food the same as HFSS?

No. HFSS status comes from the nutrient profiling model, which scores nutrients only. NOVA looks only at processing. A product can be non-HFSS and ultra-processed, or HFSS and not ultra-processed.


SACN is still monitoring UPF, and its expert roundtables pointed towards refining NOVA rather than replacing it. Until there's a UK definition, the practical answer to "is this UPF?" is to ask whose definition the person means, and know how your product scores on each.

Canoli shows what happens to your nutrition panel and NPM score as you swap ingredients, so you can test a cleaner recipe before you trial it. Get started free.