A recent OECD- and GLP-compliant safety assessment of a fully characterised root-and-leaf ashwagandha extract demonstrated no genotoxicity, no treatment-related adverse effects in a 90-day study, normal liver findings and no adverse endocrine effects, even at exposure levels substantially above typical consumer use¹.

These findings are consistent with published clinical studies showing standardised ashwagandha extracts to be generally well tolerated and provide an important evidence base for future regulatory evaluations.

Standardised ashwagandha extracts have been evaluated for safety and tolerability in a range of human clinical studies, some of which are summarised in Table 1.  Over the past decade, however, ashwagandha has come under increasing regulatory pressure across Europe.

Table 1. Safety and Tolerability Evaluations of Standardised Ashwagandha Extracts

In recent years, several EU member states have introduced or proposed measures affecting its use in food supplements, ranging from limits on daily intake to reclassification and, in some cases, national restrictions; others continue to keep it under review.

These differing national positions reflect an evolving and, in places, contested regulatory picture rather than a settled EU-wide consensus.

In June 2024, the EU Heads of Food Safety Agencies recommended initiating a formal review procedure that could result in no regulatory action, an EU-wide restriction or prohibition¹².

A central and recurring issue throughout this regulatory debate has been the limited availability of publicly accessible toxicology datasets generated to internationally recognised testing standards, contributing to differing interpretations across jurisdictions.

In 2026, Summan et al.¹ addressed that gap by providing a comprehensive safety evaluation of a standardised ashwagandha root-and-leaf extract, conducted in accordance with Organisation for Economic Co-operation and Development (OECD) Test Guidelines and Good Laboratory Practice (GLP), and published in peer-reviewed literature.

Why do OECD and GLP Matter?

Not all safety studies are conducted to the same standard.

OECD Test Guidelines provide internationally recognised methods that allow safety data to be evaluated consistently by regulators around the world.  GLP ensures that studies are planned, conducted, recorded and audited according to strict quality standards.

OECD Test Guidelines  — a standardised method

• OECD Test Guidelines are internationally recognised study designs. Because every laboratory follows the same protocol, results generated in one country can be evaluated consistently by regulators anywhere in the world.

GLP-certified conduct  — audited quality control

• GLP (Good Laboratory Practice) means the study was planned, conducted, recorded and audited according to strict quality standards. It is a check on the integrity of the process itself, not only the result.

Regulator-ready data  — fit for independent review

• Combined, these frameworks produce a standardised, auditable and reproducible dataset. That is what allows a regulator to evaluate the findings independently.

Together, these frameworks help ensure that safety findings are reliable, reproducible and suitable for regulatory review.  So, these frameworks establish how a study is conducted and the next question is what the test conditions are.

Why Test at such High Doses?

Safety studies are intentionally designed to challenge an ingredient at levels far above commercial use.  The objective is not to replicate consumer intake, but to determine whether adverse effects emerge under conditions of substantial exposure.

For example, in the recent Summan et al.¹ 90-day study, an Ashwagandha root-and-leaf extract was administered daily at doses up to 4,000 mg/kg body weight, providing a safety margin 19 times the standard dose of 125mg.  No treatment-related adverse effects were observed at any dose tested, establishing the highest tested dose as the No Observed Adverse Effect Level (NOAEL).

Understanding Safety Assessments

In the food and dietary supplement industry, understanding how risks to health are identified, evaluated and managed protects consumers and ensures regulatory compliance.

Risk assessment is a stepwise process used to identify potential hazards and adverse health effects.  By completion of a safety assessment, an evidence-based risk analysis of an ingredient can be provided.

Rather than relying on a single study, regulators expect evidence accumulated from several research studies.  Each study is designed to answer a different safety question such as would a single large exposure cause harm?  would it damage DNA?  would daily use affect organs or physiological systems over time?

A battery of genotoxicity tests examined whether a standardised ashwagandha root-and-leaf extract could cause mutations, chromosome damage or other genetic changes to identify potential for long-term health concerns¹.  The authors concluded there was no evidence of toxicity or genotoxicity observed under the test conditions¹ (Table 2).

Table 2.  OECD-Compliant Toxicology Assessment for an Ashwagandha Root-and-Leaf Extract¹

Regulatory Relevance

The publication of a comprehensive OECD-compliant safety package provides regulators with a standardised toxicological dataset to support the independent assessment of ashwagandha root-and-leaf extract.

In addition to the studies summarised in Table 1, the recent Summan et al.¹ contributes evidence in several areas that have been central to current regulatory evaluations, including liver safety, endocrine-related effects, and genotoxicity.

While regulatory decisions are informed by multiple lines of evidence, the availability of these data helps address a longstanding gap in the safety dossier for root-and-leaf ashwagandha preparations and strengthens the overall evidence base available for regulatory review.

Addressing Liver-Safety

Recent regulatory scrutiny of ashwagandha has been driven in part by case reports of liver injury associated with a range of ashwagandha-containing products.

While case reports can help identify potential safety signals, they do not establish causality or isolate the contribution of a specific ingredient or extract to the health concern.

Summan et al.¹ who conducted an oral toxicity study under controlled conditions found no evidence of treatment-related liver pathology following administration of an ashwagandha root-and-leaf extract, including at the highest dose evaluated (4,000 mg/kg/day) ¹.

In addition, liver histology remained normal and key liver biomarkers (ALT, AST and ALP) showed no evidence of hepatotoxicity¹.  These findings provide a controlled toxicological dataset that can be considered alongside clinical and real-world evidence when evaluating liver safety.

The US National Institutes of Health has noted that causality in reported cases remains uncertain, citing product adulteration, mislabelling and co-ingestion of other supplements as plausible contributing factors¹³.  These findings, taken together, underscore the importance of using fully characterised, standardised extracts evaluated under controlled conditions when assessing ingredient-level liver safety.

In Summary

As regulatory scrutiny of ashwagandha continues to evolve, the availability of high-quality safety data is increasingly important.

The recent OECD- and GLP-compliant safety assessment of a fully characterised root-and-leaf ashwagandha extract¹ provides a robust toxicological dataset, demonstrating no genotoxicity, no treatment-related adverse effects in a 90-day study, normal liver findings and no adverse endocrine effects under the conditions tested.

Importantly, these findings are consistent with the broader clinical evidence showing that standardised ashwagandha extracts are generally well tolerated.

Together, the data highlight the importance of evaluating fully characterised extracts using internationally recognised methodologies to support evidence-based regulatory assessment and informed safety conclusions.

An estimated 4.3% of the global population are affected by food allergies with reactions ranging from mild symptoms to life-threatening anaphylaxis¹.

While the labelling of intentionally added allergen ingredients is mandated in regulations, the procedure for “may contains” statements covering the unintentional presence of allergens varies widely and remains unregulated in many parts of the world.

As a result, it can be difficult for consumers to judge the actual level of risk and some may unnecessarily avoid foods that are safe or lose confidence in the warnings and simply ignore them.

The unintended presence of food allergens or cross-contamination can occur during food production, even when the allergen is not an ingredient.  For example, a cereal bar without nuts produced on the same line as nut-containing products may still contain traces of nuts despite cleaning procedures.

Allergens may also be transferred during ingredient handling and storage and therefore precautionary allergen labelling (PAL), including statements such as “may contain”, is often used to alert consumers to potential residual risks.

However, guidance is needed to prevent unnecessary PAL by ensuring warnings are only used when the risk has been scientifically assessed and cannot be adequately controlled through good allergen management practices.

The new Codex guidance recommends a qualitative risk assessment which can be supplemented with a quantitative risk assessment of unintended food allergen presence.

Reference doses for individual allergens are also included in the guidance and serve as the basis for establishing action levels.

The intention is that PAL shall only be used when, following the application of appropriate measures, the unintended presence of a food allergen(s) is above the action level for the allergenic food based on the reference doses for IgE-mediated food allergy and for coeliac disease.

PAL should not be used when the unintended presence of a food allergen(s) is at or below the action level.

The guidance also includes other points of clarification as for example, how to label in the case where the unintentional source of the gluten cannot be verified by risk assessment and how and where the PAL should appear on label.

The guidelines were adopted as part of the 49th Session of the Codex Alimentarius Commission², held in Geneva, Switzerland, from 6 to 10 July 2026 and will be included as an annex to CCFL’s General Standard for the Labelling of Pre-packaged Foods (CXS 1-1985)³.

The guidance complements existing Codex standards on allergen declaration and food allergen management, including the Code of Practice on Food Allergen Management for Food Business Operators (CXC 80-2020)⁴.

While Codex guidance is voluntary, it often serves as an internationally recognised benchmark that supports national legislation and assists international trade.

Currently the European Commission⁵ is considering the adoption of harmonised requirements for the use of voluntary PAL statements and the UK are also exploring options⁶.

Notes: Established by FAO and WHO, the Codex Alimentarius Commission develops international food standards, guidelines and codes of practice to protect consumer health and promote fair practices in the food trade.

From Broad Concepts to Operational Definitions

The debate around “ultra-processed foods” (“UPFs”) is entering a new phase.  At the end of 2025, The Lancet published a 3-paper series on “UPFs”, covering health associations and policy recommendations¹.

Much of the evidence underpinning this classification comes from observational studies that rely on dietary assessment methods not originally designed to assess food processing².

While these studies identify associations between dietary patterns and health outcomes, they do not establish cause and effect or determine the independent contribution of specific ingredients to the observed associations.

One of the most significant developments from the Lancet paper series was the proposal of moving beyond the broad descriptive Nova classification by Monteiro et al.³ toward a more operational definition based on “markers of ultra-processing” (MUPs).

These MUPs tend to include ingredients and additives not generally used in home cooking.  In practice, however, they also represent a subtle but important shift in how “UPF” is being conceptualised.

The discussion implicitly moves away from processing towards ingredients and formulation-level classification systems capable of being applied at product level and at scale.

This distinction matters because it means there are more questions to be answered such as which classification system is being applied, how is it operationalised, and what happens when it is used across real-world datasets.

These questions reflect a broader transition taking place across nutrition policy, where the conversation is increasingly focussed on data infrastructure, challenges, opportunities and implementation of health metrics.

The Lancet UPFs series¹ expands upon the related literature by moving from a classification widely used in observational studies to a definition that can be applied in practice for policy purposes.

Yet, at the time of writing this article, these ingredient-level approaches have not been empirically tested against health outcomes.

Existing Policy Landscape Remains Primarily Nutrient-Based

Despite growing policy and scientific attention on food processing levels, most regulatory approaches for enabling healthier food choices (e.g. taxation, marketing restrictions, labelling) still operate primarily through nutrient-based thresholds.

© Copyright 2026 Global Food Research Program at UNC-Chapel Hill.  Base map copyright © FreeVectorMaps.com

Front-of-pack warning labels in countries such as Chile and Mexico focus on nutrients of concern and, in some cases, sweeteners.  Restrictions in the UK on products high in fat, salt, and/or sugar (HFSS) rely on a nutrient profiling model.

Similarly, the Nutri-Score in certain European countries evaluates products through nutrient composition for labelling.  China requires sugar and saturated fat labelling and health warnings for children for mandatory implementation in 2027.

Although these systems do not classify foods according to their level of processing, food processing and ingredient-level definitions are now being considered in discussions around dietary guidance, marketing restrictions, taxation and/or front-of-pack labelling.

As these policy approaches use different underlying criteria, this raises an important question: what additional value does classifying foods by their level of processing provide beyond existing nutrient-based systems?

The Rise of Ingredient-level Classification

The proposed MUPs approach attempts to create a more scalable and standardised way of identifying “UPFs” using ingredient list data.  In theory, this allows classification to be applied consistently across large manufacturer and retailer datasets, but it also raises unresolved questions within the food processing debate.

One question is whether regulation is ultimately targeting specific ingredients or foods as a broader category.  Discussions often move interchangeably between emulsifiers, stabilisers, sweeteners, flavourings, industrial formulations and processed foods themselves, despite these not necessarily representing equivalent policy targets.

Another challenge relates to evidence translation based on the available science to date.  As a result, it leaves a gap between the descriptive categories used in dietary surveys and ingredient-level systems proposed for regulatory implementation.

The growing shift toward ingredient-level operationalisation therefore changes the nature of the debate.  At the same time, implementation remains inherently difficult.

Currently, there is no globally harmonised MUP framework, raising practical questions around who determines the official list of markers, how lists are updated and how disagreements are resolved as (re)formulation practices evolve.

Emerging Attempts to Bridge the Implementation Gap

In May 2026, Healthy Eating Research (HER) convened an expert panel to evaluate existing UPF definitions and approaches for guiding policy development⁴.  The report acknowledged that processing alone is not sufficient to determine the overall healthfulness of foods and instead is as an additional lens that may complement existing dietary assessment approaches.

In addition, inclusion of specific markers is not necessarily because those ingredients are individually harmful, but because they are viewed as indicators of foods categorised as “ultra-processed”.

However, while broader dietary patterns classified as “UPFs” may have been associated with adverse health outcomes in observational studies, it remains unclear whether the proposed ingredient-level markers used for policy capture those same associations.

The HER panel brought practical implementation challenges into sharper focus. These included maintaining and updating ingredient databases within rapidly evolving food supply chains, ensuring sufficient transparency around formulation practices, and managing the reality that static marker lists may quickly become outdated.

At the same time, the project reflects expansion of the field by applying proposed metrics to more than 90,000 products, highlighting how food classification systems need to consider real-world data to understand policy implications.

Reformulation and Shifting Incentive Structures

One of the most important implications of ingredient-level approaches relates to reformulation incentives.  The Lancet series critiques nutrient reformulation by arguing that reductions in fat, salt and/or sugar may increase the use of additives or industrial ingredients.

Yet ingredient-level operationalisation could itself create a different set of reformulation incentives, which may take the form of optimisation away from “less sugar” towards “less emulsifier”, expanding previous trends on “clean(er) label” or “natural” ingredient substitution strategies.

If ingredient-level criteria become the primary regulatory gatekeeper, reformulation may lead to prioritisation of additive substitution and formulation optics over measurable nutritional improvements.

This creates a broader policy question: what exactly is regulation trying to incentivise – nutritional composition, degree of processing, category restrictions, ingredient familiarity, formulation simplicity, eating behaviour, or some combination of these factors?

California as an Emerging Real-World Test Case

A number of these tensions are now beginning to materialise in regulatory approaches.

California has become one of the clearest examples of attempts to operationalise the level of food processing within legislation.  In 2025, the state introduced a formal “UPFs” definition for school food restrictions through AB 1264.  More recently, AB 2244 proposed applying this classification through a certification scheme for non-“UPFs” and preferential retail placement for certified products.

Rather than relying solely on Nova categorisation, California’s approach combines ingredient-level markers with nutrient thresholds.  Products may be classified as “UPFs” if they contain one or more listed additives while also exceeding thresholds for saturated fat, added sugar or sodium.  However, products containing non-nutritive sweeteners or polyols may still fall within the definition even where nutrient thresholds are not exceeded.

The result is a system where HFSS does not always equal “UPFs”, and vice versa, which creates potential divergence.  Nutritionally poor products may avoid “UPF” classification through “natural” substitutions, while products that have improved nutritionally may remain within restricted categories because of ingredient composition.

Alongside policy-led approaches, a growing number of third-party certification schemes have also been developed, particularly in the US, to certify foods as non-“UPF”.  These schemes often apply different criteria and thresholds, further illustrating the fragmentation currently emerging within operational definitions.

Product-Level Data is Becoming Central

One of the clearest changes emerging is that the debate is moving beyond a single classification and increasingly overlapping with wider discussions on data infrastructure.

Policy impact ultimately depends not on whether a classification system appears coherent theoretically, but on what happens when it is applied across real-world products, retail environments, purchasing and consumption datasets.

A framework may appear conceptually robust yet generate unexpected divergence, inconsistencies or implementation challenges once operationalised at scale.

Questions around ingredient transparency, data access, and successful implementation are therefore becoming central to the future of food and nutrition policy.

Final Reflections

A key challenge for “UPFs” moving forward is considering where the concept genuinely adds value beyond existing policy approaches.  Most stakeholders working in this space ultimately share similar goals: supporting healthier and more sustainable diets.

However, before “UPF” becomes embedded within regulatory frameworks, there needs to be greater clarity around what the concept is intended to achieve and whether current operational approaches remain coherent when applied consistently across real-world food systems and datasets.

Whatever direction the conversation takes, the future of “UPFs” feels likely to become more data-led, not only “definition-led”.  As such, the next chapter may depend less on continuing debates around classification itself, and more on understanding what happens when these approaches are applied in practice.

Without this, there is a risk that unintended consequences and potential divergence beyond existing nutrient-based approaches remain poorly understood, particularly as regulatory development in this area continues to accelerate.

These guidelines are published jointly by the department of Health and Human Services (HHS) and the US Department of Agriculture (USDA) and are long considered an authoritative source on health and nutrition guidance in the US.

These guidelines have several roles:

• • To help Americans choose a healthful diet.
  • To advise nutrition standards for a wide variety of federal feeding programmes like the school lunch programme, the Child and Adult Care Food Programme and the Supplemental Nutrition Programme for Women, Infants and Children (WIC).
  • To support federal and other public health nutrition education programmes.
  • To support food fortification and reformulation efforts by the food industry.

So why have these latest guidelines, published in January 2026, received so much attention?

The New Dietary Guidelines – a Significant Reset?

These 2025-2030 Dietary Guidelines for Americans (DGA’s)¹ are promoted as the “most significant reset of federal nutrition policy” and highlight the placing of  “real food at the centre of the American diet.”

However, much of the guidance has remained the same with a focus on eating nutrient dense foods, limiting added sugar and keeping saturated fat intakes below 10% of calorie intakes.

What is different is the emphasis on certain foods and nutrients, the new inverted food pyramid and how the process was undertaken this time around.

These guidelines are posted on a website including supplemental materials and Grok AI to answer consumers’ questions².

Key differences in messaging in the 2025-2030 Guidelines:

Here is a quick look at some of the differences in the new guidelines compared to the previous version:

Increased Protein:  Americans have long consumed more protein than earlier dietary recommendations advised.  However, the new dietary guidelines declare an end to the “war on protein”² and to prioritise protein at every meal.

They substantially increase the suggested intake to 1.2–1.6 g/kg/day for all Americans, rather than recommending increased intakes for specific subpopulations as in the past.

Meat and other animal-based forms of protein are highlighted in the guidance, with an acknowledgement that one can also find protein in other foods like beans, lentils, tofu and nuts.

Previous editions of the DGA’s and other substantial dietary guidance from around the world highlight the importance of using plant-based protein sources for sustainability and health reasons⁴.

Additionally, meat and animal-based protein tend to be more expensive than plant-based proteins and the costs associated with these changes are a limitation for many Americans.

Saturated Fat-Containing Foods:  These dietary guidelines maintain the previous recommendations to limit saturated fat to less than 10% of calories.

However, these guidelines suggest consuming butter, full-fat dairy products, beef tallow and eating more meat.

Based on the recommended number of servings for these foods, remaining within the 10% saturated fat limit will be a challenge⁵.

Define Real Food:  One of the main messages of the 2025-2030 guidelines is to “Eat Real Food”.  These guidelines steer Americans to consume foods like meat, full fat dairy products, fruits, vegetables and whole grains as the real foods, with a strong focus on the meat and dairy product categories.

While there have always been recommendations to consume nutrient-dense foods, these guidelines suggest limiting highly processed foods, implying these do not count as real foods.

Highly processed foods (often referred to as ultra-processed foods (UPF)) are under scrutiny around the world to determine definitions and health effects, but the science is far from settled.

In the guidelines, little guidance is provided on how to make such a substantial change – how to remove highly processed foods from American’s diets and to shift to lower processed foods.

Added Sugars:  The new recommendations are stricter, limiting added sugars to no more than 10g per meal for adults and no added sugars before the age of 11 years.  They also suggest limiting non-nutritive sweeteners.

The guidelines do include detailed information on identifying added sugar and limits on how much added sugar should be included in snacks.

Sustainability and Equity:  Throughout the world, countries and the Food and Agriculture Organisation of the United Nations (FAO) are focused on integrating the issues of sustainability and equity into their dietary guidance and food policies.

The later scientific committee behind the new DGA’s rejected these priorities in their substantiation documentation and they are not considered in these new guidelines⁶.

Reduce Alcohol But How Much?:  As with the previous version of the guidelines, there is a recommendation that drinking less alcohol is better for health.

The difference is that the new DGA’s do not include any specific limits on how many drinks per day should be consumed.

Picture This Pyramid

One of the most visible changes of these dietary guidelines is the launch of a new image of the guidelines – an inverted food pyramid.

The US has not used a food pyramid since 2011 when the USDA switched to MyPlate to make it clearer how much of the plate should be filled with different categories of foods.

This new pyramid (Figure 1) showcases a wide top highlighting meat, cheese, milk and vegetables; with other proteins, some dairy foods, fats and fruit in the middle section; and whole grains at the bottom tip.

Figure 1. Dietary Guidelines for Americans 2025-2030¹

The number of servings for foods are not listed, nor are the food images shown to scale.  Having whole grains displayed at the bottom tip may lead to consumer confusion as it suggests that very little grains should be eaten.  However, the new guidelines still recommend 2-4 servings of whole grains per day.

Scientific Bodies Weigh In

Several expert public health organisations have responded to the new guidance.  While they are positive about the elements of the DGA’s that align closely with the longstanding dietary guidance, they have also flagged concerns about some of the changes.

These concerns will likely impact on how the guidelines are adopted across the board by healthcare professionals, the public and the food industry alike.

The American Society for Nutrition’s (ASN) statement expressed concern over the change in the established scientific review process.

In 2023, a 20-scientist Dietary Guidelines Advisory Committee (DGAC) was selected, vetted for conflicts of interest and held public meetings before releasing a comprehensive scientific report in December 2024 with a public comment period⁷.  Normally, this report would inform the final DGA’s.

However, a new group of nine scientists was contracted to produce The Scientific Foundation for the Dietary Guidelines.  They rejected the results of the DGAC’s report and wrote this new document which was released along with the 2025–2030 Dietary Guidelines in January this year.

ASN believes the change from a rigorous and open process may undermine confidence in the DGAs and nutrition science and contribute to confusion⁸.

The Academy for Nutrition & Dietetics challenged the guidelines’ emphasis on animal sources of saturated fat, the lack of consideration of diets for people who cannot include dairy and the call for moderation in low calorie non-nutritive sweetener intake in the face of evidence that they are generally considered safe within acceptable intake limits⁹.

The American Heart Association says it will continue to “encourage consumers to prioritize plant-based proteins, seafood and lean meats and to limit high-fat animal products including red meat, butter, lard and tallow, which are linked to increased cardiovascular risk”  pending any future research¹⁰.

The World Cancer Research Fund are concerned that the increased emphasis on red meat does not reflect the scientific evidence linking higher intakes of red and processed meat to increased cancer risk¹¹.

Considerations for Food Industry and Healthcare Professionals

While the new DGAs are still in their early stages, it is possible to begin considering their potential impact.  We know that dietary habits are notoriously resistant to change.

For two decades, the International Food Information Council (IFIC) Food & Health Survey ¹² (an annual survey of 3,000 Americans) has consistently shown that taste dominates food and beverage purchase decisions, followed by price.   These same factors will continue to play a crucial role in shaping the adoption of any new dietary guidance.

It is likely that consumers will encounter more mixed messages from both healthcare professionals and through social media.

The 2025 IFIC Food & Health Survey, showed that 8 in 10 Americans were confused over what nutrition information to believe in because they felt it changed frequently.

For this reason, it will be important to reassure the public that many elements of the new DGAs remain the same.

This is a key message that can be emphasised by both healthcare professionals and the food industry alike.

Food Industry

• • Food companies will need to decide if they want to make changes to their portfolio based on the new guidance. Some change is already happening – one restaurant chain switched to cooking their fries in beef tallow¹³.  However, it is early days and having spent years reformulating, food manufacturers may pause before making changes to their products’ recipes considering some of the conflicting evidence.
  • The ambiguity around what defines a ‘highly processed food’ is difficult for product developers who are attempting to innovate or renovate but the DGA’s negative stance on “chemical additives”, added sugars and non-nutritive sweeteners, may accelerate the clean label trend and lead to shorter ingredient lists.  While this trend creates opportunities for the food industry,  food additives play an important role in food safety, preservation and in reducing food waste which remain priorities.  Fortification with key nutrients often lacking in the US diet should not be abandoned for the sake of a shorter “clean label.”  Companies that successfully balance these competing concerns may gain a competitive advantage.
  • A recent poll found that 1 in 8 U.S. adults are taking GLP-1 medications for weight loss, diabetes or other conditions¹⁴.  In response, the food industry is focusing on protein-rich, high-fibre, nutrient-dense foods.  Notably, these priorities closely mirror the DGA’s; however, GLP-1 use often requires a more targeted individualised approach to manage appetite suppression, preserve muscle and prevent potential nutrient inadequacies that may not be wholly delivered through a focus on real foods alone.

Healthcare Professionals

• • In the social media age, nutrition and dietetic professionals are well used to addressing conflicting advice but should expect growing confusion and challenge from both patients and other healthcare professionals.
  • US federal food programme changes have traditionally followed lengthy rule-making processes, but healthcare professionals engaged in these programs should be ready for faster shifts under the current administration—for example, a recent law allowing whole and 2% milk in schools alongside skim and low-fat options was introduced¹⁵.

Conclusion

Ultimately, guidance alone does not result in positive dietary changes.  Telling people to eat real foods does not work if they are unaffordable or unavailable.

The real question is whether these DGA’s will be followed by substantive federal action that enables Americans to make these changes in their daily lives.

Funding for educational programs to support healthy eating, reduction of food deserts in communities, cooking classes, reduced prices on food, support for improved food systems, funding for research and support for farmers to grow the diversity of crops needed are just a few of the actions required to support Americans to change their diets in such a large and profound way.

In 2022, approximately 1 in 8 individuals worldwide were living with obesity (including 1 in 3 in the EU and in North America), with adult obesity rates more than doubling since 1990 and adolescent obesity quadrupling during the same period.

This is particularly pertinent because obesity is a risk factor for many serious diseases and disorders such as cardiovascular diseases and type 2 diabetes which are major contributors to premature deaths.

The WHO acceleration plan to stop obesity has outlined strategies for governments to address this issue, including introducing nutrition labelling schemes that support consumers to make healthier choices, as well as monitoring the food environment for nutritional quality, prices and marketing practices.

Front-of-Pack Nutrition Labelling: A Decade of  Global Transformation

Many governments globally have introduced front of pack (FOP) nutrition labelling and regulations around sugar, fat, and salt as a key lever to combat obesity and associated non-communicable diseases.

FOP nutrition labelling can empower consumers to make healthier food choices by simplifying the nutritional information into clear visual cues, using colour, ratings or symbols, making it easier to compare products.

Figure 1 shows the countries who were early adopters of FOP nutritional labelling.  As early as 1989, Sweden added the voluntary ‘Keyhole symbol’ to their food labels, which was then added by Norway & Demark in 2009, followed by Iceland & Lithuania in 2013, and Macedonia in 2015.

Other European countries included a voluntary nutrition traffic light label in 2013 (UK & Ireland), while a similar mandatory label was implemented in Ecuador in 2014.  Australia and New Zealand also implemented a voluntary label known as the “Health Star” system in 2014.

Figure 1: Front-of-Pack Nutrition Labelling prior to 2015

Since 2015, various countries have implemented or proposed even more FOP nutrition labelling systems to provide accessible, at-a-glance nutritional information.  Figure 2, highlights the evolution of FOP nutrition labelling globally as of 2025.

Figure 2: Front-of-Pack Nutrition Labelling 2025

Notable Changes in FOP Nutrition Labelling since 2015:

• • European Union: Several EU countries have adopted the Nutri-Score system, a voluntary FOP nutrition labelling scheme that rates the nutritional quality of food products using a color-coded scale from A (healthiest) to E (least healthy).  France implemented Nutri-Score in 2017, followed by Belgium, Spain, Germany, and others.
  • Latin America: In 2016, Chile implemented black octagonal warning labels on foods high in calories, sugar, sodium, or saturated fat.  This measure led to a significant reduction in the purchase of unhealthy items and prompted food manufacturers to reformulate products to avoid the warning labels.  Since this implementation, several Latin American countries have also adopted similar labelling (Peru in 2019; Mexico in 2020; Uruguay in 2021; Argentina, Brazil and Colombia in 2022; and Venezuela in 2024), with some differences between countries, but all of them mandatory.
  • Canada: Health Canada introduced mandatory FOP nutrition label in 2022, with full implementation required by January 1, 2026.  The label highlights products high in saturated fat, sugars, and sodium, aiming to assist consumers in making informed choices.
  • South East Asia: Many countries in South East Asia have introduced healthier choice logo’s.  In 2022 Singapore introduced the mandatory Nutri-Grade label and advertising restrictions for all pre-packaged beverages, and out of home beverages from fountain dispensers, automated coffee machines and cafe’s / food service premises.  The Nutri-Grade system rates beverages according to their sugar and saturated fat levels, with a special sugar declaration mark for toppings added.
  • United Kingdom: In addition to the voluntary FOP traffic light label for pre-packaged foods, the UK has implemented mandatory regulations to reduce advertising of foods and drinks high in fat, salt, and sugar (HFSS) to combat childhood obesity.  These regulations, effective October 1, 2025, include a ban on HFSS ads on TV before 9 PM and a complete ban on paid-for online ads for these products.  The regulations, as outlined in the Advertising (Less Healthy Food Definitions and Exemptions) Regulations 2024, are designed to limit exposure of children to HFSS products through advertising.
  • Middle East: Colour coded traffic light labels have been introduced for pre-packaged foods in Iran (mandatory), the Kingdom of Saudi Arabia, and the United Arab Emirates (voluntary).
  • Sugar Taxes on sugar sweetened beverages: Globally over 100 countries have introduced levies on pre-packaged sugar sweetened beverages to promote healthier beverage choices by consumers.

Future Considerations for FOP Nutrition Labelling

• • Singapore: From mid-2027, the Nutri-Grade labelling requirements and advertising prohibitions will be extended to key contributors of sodium and saturated fat intake.  These measures will apply to 23 sub-categories of prepacked salt, sauces, seasonings, instant noodles, and cooking oils (SSSIO) sold in retail settings.
  • China has started to encourage companies to actively adopt the recommended standards of “Guidelines on graphic symbol of front-of-pack nutrition labelling in pre-packaged Food” , which introduced four front-of-pack nutrition labels simultaneously depending on products’ nutritional profile, including a black-and-white warning label, an A-D rating, and a “Smart Choice” message.
  • India: FSSAI engaged with the Indian Institute of Management (IIM) to seek expert advice on the most consumer-friendly front-of-pack labelling (FOPL) system used globally.  IIM conducted an in-depth survey to assess consumer preferences for various nutrition labels in India.  The results indicated that the Health Star Rating (HSR) system was the most preferred, owing to its ease of identification, understanding, reliability, and influence on consumer choices.  Based on these findings, in February 2022 FSSAI decided to adopt the Indian Nutrition Rating (INR), a modified version of Australia’s HSR, tailored to suit Indian consumer behaviour and dietary patterns.
  • USA: On January 14, 2025, the Food and Drug Administration (FDA) issued the long-awaited Proposed Rule on Front-of-Package (FOP) Nutrition Labelling.  The Nutrition Info box will categorize the levels of saturated fat, sodium, and added sugars as “Low,” “Med,” or “High,” making it easier for consumers to understand the nutritional content at a glance.  There are also plans to remove certain foods and beverages HFSS from SNAP (supplemental nutrition assistance program) US.

While these initiatives have shown promise in influencing consumer behaviour and encouraging product reformulation, their impact will be determined by regulatory frameworks, industry acceptance, and market restrictions.  For FOP nutrition labelling to be fully beneficial it must be paired with broader public health policies that address the needs of healthy and sustainable dietary habits, such as education, accessibility, and cultural needs.

Disclaimer: This article is based on information available as of June 12, 2025.

The decisions made by the USDA on Child Nutrition Programs focus on improving child health through nutritious school meals and addressing challenges such as added sugars, sodium levels, whole grains and procurement of American-grown foods.

Added Sugars and Sodium Limits

USDA has introduced a gradual, multi-year approach to limit added sugars in high-sugar products like grain-based desserts, breakfast cereals, yogurt and flavoured milk.

By School Year (SY) 2027-2028, the limit will ensure that no more than 10% of calories per meal come from added sugars.

Sodium limits will also be gradually reduced over several years, with a focus being packaged meats and meals.  By SY 2027-2028, schools will implement a 10% reduction for breakfast and a 15% reduction for lunch^1,2.

Whole Grains and Flavoured Milk

Schools are required to ensure that 80% of weekly grains are primarily whole grain, but they can occasionally offer non-whole, enriched grain foods.

Flavoured milk is allowed for all K-12 grades, with proposed changes that may limit it to certain grade levels.  USDA is seeking public input on this matter³.

Flexible Meal Planning and Traditional Foods

The proposed rule allows more flexibility at breakfast by including meats and meat alternates such as yogurt, eggs or tofu.  It also supports more culturally inclusive meals, including traditional Indigenous foods.

A significant financial investment in the Healthy Meals Incentives initiative, with $100 million dedicated to improving the nutritional quality of school meals, is also part of the changes^1,4.

Supporting Local Foods and Schools

The USDA is providing nearly $1 billion to support schools in purchasing American-grown foods for their meal programs, aiming to ease procurement challenges and encourage the use of locally grown products.

The Keep Kids Fed Act, which was signed into law, also provides extra resources to schools, summer meal sites and childcare food programs to address high food costs and supply chain disruptions⁴.

Why are these Changes Happening?

These updates to school nutrition standards aim to align with international practices by limiting added sugars and reducing sodium content.

For instance, the new regulations will cap added sugars at 10% of total caloric intake by 2027 and implement a 10% reduction in sodium for breakfast and 15% for lunch by the same year.

These standards resemble approaches in countries like the UK and Canada, where similar limits on sugars and sodium have been implemented to combat rising concerns about childhood obesity and health^1,4.

In the UK, the School Food Standards require that high-quality meat, poultry, or oily fish are provided and limits are set on the amount of sugar and fats available in school meals.

Meanwhile, Canada’s guidelines focus on providing meals rich in fruits, vegetables and whole grains while minimising processed sugars and sodium, aiming to foster healthier eating habits among children⁵.

These international approaches underline a common global trend towards enhancing children’s health through better nutrition standards in schools, emphasising reduced sugar and sodium while promoting whole grains and locally sourced foods.

This convergence suggests a growing recognition of the importance of healthy school meals as a foundation for lifelong healthy eating habits.

What does this Mean for the Industry?

For food manufacturers, these changes mean investing in research and development to reduce the sugar and sodium content of their products without compromising taste or texture.

For example, the new rules set limits on added sugars in flavoured milks, a popular item in school cafeterias, which will push dairy processors to innovate lower-sugar formulations that still appeal to children¹.

Similarly, with sodium reduction targets set for the coming years, manufacturers of processed foods products such as bread rolls, meats, packaged products, etc. typically used in school meals will need to find ways to maintain flavour while reducing salt content.

Additionally, the emphasis on locally sourced and unprocessed agricultural products opens new markets for local farmers and producers but poses challenges for larger, national manufacturers who may need to adjust their supply chains to meet local sourcing requirements.

This could mean forming new partnerships with local farmers or investing in local production facilities^1,4.

These changes not only reflect an increased focus on health and nutrition in school meals but also represent a growing consumer demand for healthier, locally sourced foods across the market.

Food manufacturers who successfully adapt to these standards can not only continue to serve the school meals market but also leverage their innovations to cater to broader consumer trends towards healthier eating.

As the world focuses more on sustainable diets, we can expect dietary sodium intake targets to become more important and prevalent in the coming years.  In this article, we review:

• • Sodium’s role in health
  • Tax and legislation initiatives on sodium reduction being enacted globally, and their impact
  • Voluntary initiatives from food industry and impact on sodium intake
  • What to expect in the future

What are the Effects of Excess Sodium Intake on Health?

Cardiovascular diseases (CVD) account for most non-communicable deaths (NCDs) globally¹, which equates to 17.9 million people annually².

Of these deaths, an estimated 1.89 million each year is associated with excessive intake of sodium in Europe³, which is a major driver of high blood pressure in many countries⁴, which is the leading risk factor for CVD^5,6.

Salt is the main source of sodium in foods⁷, therefore reducing salt intake can naturally translate into a lower sodium intake, which is beneficial for health^4,8, and is associated with reduced cardiovascular events¹.

However, sodium isn’t all bad!  The human body requires a small amount of sodium for critical body function such as muscle contraction and relaxation, conduction of nerve impulses, and regulation of body fluids⁷.

Unfortunately, our intake far exceeds the amount required by the human body and, hence, has a negative impact on health³.

The global average dietary sodium intake in adults is 4,310mg per day (10.78g salt per day), which is more than double the recommendation advised by World Health Organisation (WHO) (2000mg sodium/day = 5g salt per day)^9,10.

In general, daily sodium intake targets range between 2,000mg and 2,400mg per day (5 – 6g) across the globe^9,11-13.  Alarmingly, reports from international organisations reveal that the Middle East has extremely high rates of salt consumption, with an average per capita consumption of more than 12g per day¹⁴.

According to the UK National Diet & Nutrition Survey (NDNS), the main contributors of dietary salt are bread, cheese, and processed meat products¹⁵.

This is similar for Europe, with a large proportion of salt intake coming from foods that don’t necessarily taste salty such as potato products and tinned produce¹⁶.

On the other hand, sources of dietary sodium have been shown to differ between high-income countries (HICs) and low- and middle-income countries (LMICs)¹⁷.  For instance, in Southeast Asia, manufactured and processed foods provide 80% of the dietary salt intake in HICs, whereas most of the consumed salt in LMICs is added during food preparation and cooking and/or discretionary table salt^17,18.

It is important to bear in mind that, in general, consumption of processed foods is still relatively low in South Asian countries.  A study conducted in South India identified key food sources of sodium were pulses (29.7%), rice-based dishes (27%), and vegetables (16.7%)¹⁹.

What Actions are Being Taken to Lower Sodium Intakes?

Implementing highly cost-effective sodium reduction initiatives could potentially save an estimated seven million lives globally by 2030²⁰.

Many countries have implemented salt reduction targets for commonly consumed foods as part of a strategy to reduce salt intakes.  In 2013, the WHO Member States adopted a voluntary global target of 30% reduction in mean population salt intake by 2025²¹.

Although there has been an increase in the number of salt reduction initiatives around the world since 2014²², efforts must be urgently accelerated and replicated in other countries, with more rigorous monitoring and evaluation of strategies needed to achieve salt reduction targets.

Table 1. National sodium/salt reduction initiatives by WHO region²²

South-East Asia:  To align with the WHO global sodium reduction target, in 2013, the WHO South-East Asia countries set an intermediate regional target of 10% reduction in mean salt intake over the next 5 years¹⁰.

Europe & UK:  Many countries in Europe either have mandatory and/or voluntary salt reduction initiatives such as maximum permitted salt levels in foods and reformulation programs.

Policies include strategies such as taxes on high-salt food (Hungary), mandatory high-salt content labels (Finland), and targets for reformulation and close monitoring of the food supply (UK)²³.

Eastern Mediterranean:  The Eastern Mediterranean Region, which includes 22 countries and a population of approximately 580 million people, is a region that has a high burden of CVD^17,24.

National sodium/salt reduction strategies have been identified in Bahrain, Egypt, Iran, Jordan, Saudi Arabia, Kuwait, Lebanon, Morocco, Oman, Palestine, Qatar, Tunisia, and the UAE¹⁷.

The least common initiative was taxation on foods and beverages, whereas the most common strategy was reformulation (100%), followed by consumer education (77%), initiatives in specific settings (54%), and front of pack labelling (46%).  However, only 27% of Eastern Mediterranean countries monitored activities, and impact evaluations are lacking²⁴.

Taxes and Legislation

Taxing high salt products – Case Study in Europe

In 2011, Hungary implemented a tax called Public Health Product Tax (PHPT) on packaged foods that contain high levels of salt such as salty snacks and condiments.

The aim of introducing taxes is to reduce the consumption of food products that are not beneficial to public health²⁵.  However, it is not easy to prove causality between the implementation of a nutrient tax and a reduction in consumption of that specific nutrient.

For Hungary, an evaluation was conducted after the introduction of the PHPT to monitor its impact on the population.

Unfortunately, the consumption of taxed products by the adult population did not decrease, thus the salt tax had a minimal impact on Hungarian consumers behaviours²⁶.

Establishing mandatory upper limits on salt content of foods

Americas: On December 6, 2023, the Ministry of Health of Colombia issued Resolution 2056 which amended their “sodium rule”.

This amendment allows US exporters to use self-declarations to certify compliance with Colombia’s maximum sodium levels in processed products, which will help facilitate the trade of processed products to Colombia²⁷.

Europe & UK: European countries, including Belgium, Bulgaria, France, Greece, Netherlands, and Portugal, have implemented mandatory maximum salt targets on products with a generally high salt content.

The main products of focus are those that significantly contribute to dietary sodium intakes.

The UK is often viewed by other countries as a good example for addressing an issue in public health²⁸.  It implemented a successful voluntary salt reduction initiative, and now the government legislated to restrict the promotion, location and advertising of products deemed high in fat, sugar, and/or salt (HFSS)²⁹.

Warning labels on high salt foods

Across the globe, many countries use front of pack nutrition labels or warning labels that highlight the content of energy and usually these four nutrients – fat, saturated fat, sugar, and salt in foods and beverages.

It is widely accepted that one of the most effective ways to reduce sodium intake at a population level is through lowering the sodium content of foods that are consumed frequently.

Engaging industry on a voluntary basis to reformulate products high in salt is a key strategy to achieve success²³.  Many countries have established voluntary industry-led initiatives with category-specific salt targets for a wide range of food products.

Europe & UK:  European food industry and retailers show Reference Intakes (RI) on the front of product packaging, where the content of the above mentioned are displayed along with the daily RI for energy and for the four nutrients per portion³⁰.  In addition, the energy value is also expressed per 100g/100ml.

In recent years many countries have adopted similar front-of-pack labels displaying information on sodium (or salt).  For instance, in mainland Europe, several countries have implemented the Nutri-Score labelling scheme which grades the nutritional value of foods from A to E³⁰.  From January 2026, companies using the Nutri-Score logo must adopt the latest, and more restrictive, Nutri-Score algorithms for food and beverages³¹.

In Finland, numerous activities have been undertaken to reduce salt, in particular voluntary initiatives, and compulsory front-of-pack warning labels.  Warning labels are required if a specific product contains sugar or salt above a defined threshold.  For example, foods that are high in salt are required to carry a “high salt content” warning³².  Interestingly, since their introduction, the average sodium content in food products in Finland has decreased by 20-25%³².

Americas and Canada:  Many countries in Latin America such as Chile, Mexico, Peru, Uruguay, and soon Brazil, have adopted front-of-pack black warning labels that indicate if a product is high in calories, fat, sugar, and salt^30,33 (Figure 1).

In October 2021, the US Food and Drug Administration published new voluntary sodium reduction goals for the food and beverage industry³⁴.  Due to pressures to reduce sodium intake, the targets are only for 2.5 years compared with those issued previously.

The strategy supports sodium reduction already achieved by industry, provides targets for defining and measuring progress, and provides companies with the flexibility and time to meet these targets.

In Canada, as of January 2026, a front-of-package nutrition symbol is mandatory for pre-packaged foods that meet or exceed set levels for saturated fat, sugars or sodium.

South-East Asia:  In most South Asian countries, salt reduction initiatives are still in the planning phase and are yet to be fully implemented, with outcomes not evaluated or reported¹⁰.

Scaling up community-wide salt reduction strategies in this region is imperative for reducing salt intakes.

From a public health perspective, voluntary industry initiatives can be more effective, as they may be more achievable than government measures which can be hampered by pressure from interest groups, political gridlock, and bureaucratic inertia.

They may also achieve public health objectives quicker, more efficiently and less intrusively than governmental regulation.

An Industry Perspective

There are many positives with engaging in nutritional improvement of products, such as public health responsibility, creating positive publicity for the brand, goodwill among stakeholders and preventing binding government regulation and fiscal measures.

Product reformulation has large potential effects on the quality of the diet and has the potential to improve population health¹⁶.

One primary hurdle is that reformulation can alter the sensory attributes of food products and influence consumer liking.

However, there is evidence that consumers do not detect gradual decreases in the salt content of foods when slowly reduced over time³⁵.

Examples of successful industry-government partnerships for salt reduction

Community-based salt reduction programs have been conducted in many parts of the world, resulting in reduced salt intake, increased awareness and lowering of BP¹⁰.

Of all the WHO 194 Member States, 79% (154) have committed a policy towards sodium reduction and these commitments are usually included in national nutrition plans (n = 82), non-communicable disease plans (n = 94) or health sector plans (n = 40)⁶.

Western Pacific:  A community-based Eat Less Salt intervention in Vietnam decreased community salt intake from 21.5 to 20.4 g per day together with reduction in both systolic and diastolic blood pressure between baseline and follow-up of 1-year intervention¹⁰.

A similar project in Australia demonstrated a mean salt intake reduction from 8.8 to 8 g per day over a 3-year period.

A study in Japan found significant reduction in community salt intake, and a corresponding reduction in BP¹⁰.

Europe & UK:  Similarly, a research study conducted in Portugal reported a significant reduction in community salt intake, and a corresponding reduction in BP¹⁰.

Many EU governments in countries including Austria, Belgium, Czech Republic, France, Greece, Italy, Netherlands, and Spain have proposed a collaborative approach with industries on setting voluntary salt targets.

In Ireland, a salt reduction program was run over ten years from 2003 to 2013 which led to a reduction in daily adult salt intake by 1.1g³⁶.  In 2021, the Irish Government published their ambitious ‘Reformulation Roadmap’ with 2025 targets for reducing calories (20%), saturated fat (10%), salt (10%) and sugar (20%) in products that contribute to the most intake of these nutrients³⁷.

The UK’s gradual salt reduction program has been successful in reducing population-level salt intake: it achieved an overall reduced salt intake of 1 g per day in the adult population, reducing adult average sodium intake from 3,752 mg per day (9.38 g per day) in 2000 to 3,352 (8.38 g per day) in 2018³⁸.  This is a great step forward for public health despite the intake still being considerably higher than the UK recommended intake of 2,400g per day.

Conclusion

Many countries have taken and will continue to take actions to reduce population sodium intake.

High sodium intake is associated with not only increased BP but also risk of CVD.  Global sodium consumption is too high, so reducing intake will significantly improve public health.

For this reason, the sodium levels in products will continue to be scrutinised and the pressure on industry to reformulate products will continually increase.

The role of salt is essential in the preservation, flavour, and structure of food products; therefore, it is essential that governments and food industry collaborate to educate consumers, invest in new technologies and develop innovative reformulation methods and practices.

This article was originally published on 13 October 2021. It is being currently updated January 2026.

Sugar, in the form of the carbohydrate glucose, is the primary energy of life.  It is the main source for the human body, as all carbohydrates are broken down into sugars by our body to perform.  For instance, the human brain needs around 50 grams of sugar per day to function.  

This is one of the reasons humans evolved to find the taste of sugar favourable.  This was especially important during human evolution when sources of sugar were not as easily accessible as they are now.  

However, there is a difference between naturally occurring / free sugars and added sugars. How do consumers tell the difference? 

The WHO definition of term free sugars refers to ‘monosaccharides (such as glucose, fructose) and disaccharides (such as sucrose or table sugar) added to foods and drinks by the manufacturer, cook or consumer, and sugars naturally present in honey, syrups, fruit juices and fruit juice concentrates’. 

By this definition, for example, fruit juice would contain free sugars but might not be considered an ‘added sugar’ unless it was added to another food or beverage for the purpose of sweetening. 

The EFSA and FDA go into further detail about definitions of what is and isn’t an added sugar.  Added sugars are considered empty calories (i.e. supplying energy but little else nutritionally) and therefore have been the focus of increasing attention in dietary guidelines in recent years. 

As per European Regulation (EU) No 1169/2011 on the provision of food information to consumers “sugars” are defined as “all monosaccharides and disaccharides present in food, but excludes polyols”.  To date, there is no similar clear-cut definition of the term ‘added sugars’ in the same piece of Regulation.

However, Regulation (EC) No 1924/2006 on nutrition and health claims made on foods does reference a “No Added Sugar” claim as “where the product does not contain any added mono- or disaccharides or any other food used for its sweetening properties.”

Within the food industry, this then prompts discussion on how to define “any other food used for its sweetening properties”.  

In the United States, the FDA definition of added sugars includes sugars that are either added during the processing of foods, or are packaged as such, and include sugars (free, mono- and disaccharides), sugars from syrups and honey, and sugars from concentrated fruit or vegetable juices that are in excess of what would be expected from the same volume of 100 percent fruit or vegetable juice of the same type. 

The definition excludes fruit or vegetable juice concentrated from 100 percent fruit juice that is sold to consumers (e.g. frozen 100 percent fruit juice concentrate) as well as some sugars found in fruit and vegetable juices, jellies, jams, preserves, and fruit spreads. 

It is the consumption of increased added sugars that is blamed for various health conditions such as increase of a person’s risk for heart disease, type two diabetes, and obesity.  Additionally, there is a strong link between sugar intake and dental caries, or more commonly known as tooth decay or cavities.   

It has been estimated that, globally in 2010, US$ 298 billion was spent on direct costs associated with dental caries. 

It’s no surprise the focus from the authorities around sugar reduction.  Reducing sugar consumption is a global focus as a health imperative, the WHO recommends reducing free sugar intake for both children and adults to under 10 percent of total daily calories, equivalent to around 50 grams of free/added sugar maximum for the average person per day.  

It is undeniable that overconsumption of sugars – added sugars – has been recognised as a worldwide problem by top public health agencies and consumers’ interest regarding reducing sugar consumption over time is maintained high.  

Environmental Impact of Sugar Production 

Sugar is a major industry with significant effects on the global environment resulting from growing, harvesting, refining, and distribution.  On average, sugarcane accounts for nearly 80% of global sugar production, with some 110 countries currently producing sugar from either cane or beets.

For the period October/ September 2019, the top 10 producing countries (India, Brazil, Thailand, China, the US, Mexico, Russia, Pakistan, France, and Australia) accounted for nearly 70% of global output, with more than 170 million tonnes consumed annually (International Sugar Organisation). 

The production of sugar is a highly water intensive operation, especially from sugar cane which has deep roots. 

According to a recent sugar life cycle analysis and report conducted by Kerry, manufacturing 1kg of cane sugar uses 1,110 litres of water and leads to 0.42kg of CO₂ emissions.  For the case of beet sugar, it would require 640 liters of water and emit 0.85kg of CO₂ emissions (LCA). 

The increase in global demand for sugar is resulting in high water consumption, air and water pollution, soil degradation, and change in natural habitat.  It is estimated that 10% of soil is lost during harvest of beet sugar and 3-5% of soil in sugar cane harvest. 

This has resulted in the clearing of natural habitats such as rain forests, coastal wetlands, and savannah (WWF Action for Sustainable Sugar). 

Global Sugar Reduction Initiatives   

Following the 2015 publication of the WHO’s “Global Action Plan for the Prevention and Control of Noncommunicable Diseases 2013–2020” (GAP), 20 governmental bodies introduced taxation intended to reduce obesity and rising levels of diabetes, most often by targeting sugar sweetened beverages (SSBs) as they have been determined to be a major source of added/ free sugars. 

By mid-2018, 39 countries, states and cities had introduced nutritional taxation with more working toward voluntary sugar reduction approaches to encourage optimised nutrition. 

Today, that number continues to grow, with more than 50 countries or jurisdictions having implemented taxes on sugary drinks as a way to discourage consumption.  Among the latest places to turn to taxation as a means of encouraging healthy habits and fighting obesity-related illness are Spain and Poland, which introduced new sugar taxes in January of 2021. 

In the same time, there are front-of-pack labelling initiatives that are implemented across the countries on a global level.  Those initiatives seem to attract even more consumer’s attention. 

They are easier to be interpreted by the consumer and have alerted manufacturers since they have an impact on the marketing of a products as they may restrict the advertisement of unhealthy foods.  

• Although sugar taxes have been a developed world reality, some of the earliest and most enthusiastic adopters are emerging markets.  According to the PLoSONE journal article “Regulatory initiatives to reduce sugar-sweetened beverages (SSBs) in Latin America”, 14 Latin American countries have adopted public and private SSB initiatives since 2006.  These include Mexico, which has one of the highest rates of diabetes globally, and Chile which coupled its tax with warning labels on foods high in sugar, fat or sodium. 
• Hungary was another early adopter, with the introduction of its broad “health tax” in 2011 which took aim at a range of products including those containing high fat and sodium. Today, around a dozen European countries have some form of sugar or health tax, including the UK, Ireland, France and Portugal. 
• Canada introduced a front-of-pack nutrition symbol in 2023 that is required on foods high in sugar, sodium and/or saturated fat.  The United States does not currently have a national strategy for SSB taxation, although city authorities such as those in Berkeley, California, and Boulder, Colorado, have introduced local measures. 
• Among nations in the Middle East and Africa, sugar taxes are in play in countries including Saudi Arabia, the United Arab Emirates, Oman, Morocco, Nigeria and South Africa.  In Asia Pacific, several long-standing sugar taxes are in effect and more recent legislation has been applied in Thailand, Philippines and Malaysia. 

The structure of the taxes often follows a similar pattern, usually with a tiered system that awards a higher tax for products with higher sugars.  In most cases the tax is passed on to the final consumer, though some manufacturers have managed to mask price increases through the introduction of smaller pack sizes.
  

In addition to applying pressure to cost-conscious consumers, sugar taxes incentivise manufacturers to rethink recipes and create nutritionally optimised food and beverages.  

For example, ahead of the introduction of the UK Soft Drink Industry Level (SDIL) sugar tax in April of 2018, manufacturers began reformulating products, shrinking the number of high- and mid-sugar soft drinks in their portfolio and increasing their low- and zero-sugar offerings. 

A study in BMC Medicine found that six of the top ten brands affected by the SDIL reformulated more than half of the products in their portfolios between 2015 and end of 2018. 

As these products hit the market, the total volume sales of high- and mid-sugar soft drinks was cut in half, while volume sales of low- and zero-sugar drinks rose by 40%.  A separate report on the SDIL found that around its implementation, sugar content in soft drinks was reduced by an average of 44%. 

A similar pattern can be seen across Latin America, where 15% of the carbonated soft drinks launched in 2023 had a reduced/low/no or free sugar claim, reflecting the current focus of both the industry and the consumer. 

In Brazil, the food and beverage industry agreed to voluntarily reduce sugar in over 1,100 products by 2022.  Some participating manufacturers have also made voluntary commitments to the reduction of sodium, suggesting that overall  nutrition optimisation is an increasingly popular goal. 

New labelling requirements, including in Mexico and Brazil, are also pressuring brands to create lower sugar products. 

Even in markets and categories without formal legislation, there is still considerable pressure on manufacturers.  In the United States, The National Salt and Sugar Reduction Initiative (NSSRI) is in the process of setting voluntary sugar reduction targets after having gotten widespread commercial support for its salt reduction infrastructure.

In the UK, some SSBs that fall outside of the SDIL purview, including unsweetened juices and sweetened milk-based beverages, have seen sugar reductions of around 10% following requests from Public Health England. 

In Germany, voluntary targets have been set and, although no official taxes have been introduced, a small consumer survey suggests such efforts would have popular approval. 

As low sugar, no added sugar, reduced and free sugar claims become more prominent in new product launches, reformulation efforts are improving and consumer perceptions about reduced sugar beverages—which have historically faced taste and texture challenges—are changing.  

Consumers Attitudes Toward Different Sweeteners

Striking the balance between taste and nutrition is now more crucial than ever before.  People are not demanding but expecting food and drink that provide them with accessible and nutritional solutions that also cater to their taste buds.   

The need for sugar reduction is undeniable – 79% of global consumers believe that reduced sugar food and drinks are healthier than full sugar versions. 

Consumer’s sweetness expectations are no longer nebulous.  They are voicing their sugar reduction desires and laying down rules.  The degree of ‘desired’ sugar reduction is complex.  

What sweetener? In what product? Natural or artificial? And how much?  

The type of sweetener used in food and drink is important to 77% of consumers globally.  There’s lots of variables in the reduced sugar conversation, and consumers’ preferences vary considerably depending on the food or drink in question. 

The figure below shows consumer familiarity when it comes to different types of sweeteners:

This understanding is important to consider when we look at which sweeteners consumers would prefer. 

In the table below, honey was the most preferred sweetener among all consumers, followed by sucrose.  Neotame, advantame were the least preferred (do not prefer).

Preference for Sweeteners (% – Global; Base = Total Respondents)

Although taste remains a primary driver of sugar consumption, consumers increasingly acknowledge and turn to reduced sugar products as healthier alternatives.  

81% of global consumers indicate diabetes and weight gain as significant drawbacks of sugar consumption, which are major deterrents. 

Hence, the need for sugar reduction is undeniable, with 79% of global consumers believe that reduced sugar food and drinks are healthier than full sugar versions. (© Kerry Proprietary Consumer Research | Sensibly Sweet 2023 | n=12.784) 

Where to Start for Successful Reduction? 

The responsibility and cost of helping consumers reduce their sugar intake is being pushed onto the food and beverage industry.  Why so many sugar-reduced products fail? 

Though consumers cite taste as the biggest driver of their intention to repurchase, what are the other key factors that may stop great-tasting products from getting off the shelf. 

Every product category has different challenges when reformulating or developing from a low/no sugar added base.  From beverages to dairy, from bakery to sauces the approach is different.  

Reducing sugar or developing from a low/no sugar base in beverages needs to address simultaneously various challenges; low overall sweetness, high sourness, appearance of bitterness and off-notes while product mouthfeel is low.  

Considering the bakery product category the challenges are different to beverages; sweetness and mouthfeel are low, however now parameters as texture, shelf life, colour and crumb porosity are also impacted. 

There is not one solution fits all.  The approach is usually a combination of various ingredients that work in synergy to address the various challenges. 

From the selection of the desired sweetening system, to texturants and preservation systems the choices are dependent to your formulation and target consumer.  However, as taste is the primary driver when it comes to consumer’s purchase behaviour, flavours have a significant role to play in the formulation of reduced and low/no sugar containing products. 

Flavours with modifying properties, mouthfeel, and masking are used to optimise the sweetness profile of the product, deliver clean sweet taste and offer full-bodied mouthfeel with no off notes while optimising the flavour profile when sugar is being reduced/ low or not present in the product formulation. 

They work in synergy with the rest of the ingredients present in food and beverages enabling great clean taste without off notes that consumers will crave for.  

The sugar market has been greatly challenged the last years, with global deficit in the 2021/22 season replaced by a global surplus in 2022/23 season.  This crop uncertainty has a high impact on the whole supply chain of sugar.  

Sugar is universally used across food and beverages industry.  Hence there is a major need for cost stabilisation and potentially savings in the various product offerings to address consumer need for affordable nutrition in the current volatile environment.  

Conclusion 

Although there has been significant progress in sugar reduction and sweetness optimisation technology, there is still some way to go.  The sugar consumption is increasing in the years. 

Diabetes, obesity and teeth decay are still high in the health agenda’s agendas globally. 

Therefore, there is still much to play for as manufacturers stride to offer great tasting products that meet lower sugar targets and do not impact taste, texture and shelf life. 

A sustainable diet as described by the Food and Agriculture Organisation of the United Nations – is a dietary pattern that promotes all dimensions of health and wellbeing; has a low environmental impact; is accessible, affordable, safe and equitable; and is culturally acceptable.

In essence, a sustainable diet is one that is nutritionally complete and that accounts for the environmental and cultural context of food consumption^1,2.

This definition of sustainable diets is in line with the United Nations Sustainable Development goals (SDGs).  The SDGs ensure that we promote prosperity whilst also protecting the planet.

As there is a move forward towards a more sustainable way of producing food, it is very important for food manufacturers and consumers to be mindful of the role that sustainable FBDGs play in the future of food production and consumption.

How to Make Diets More Sustainable?

Many countries have started to incorporate sustainability aspects in their FBDGs.  Some have more robust guidelines than others, however it is encouraging to see that year on year there are more countries taking ownership of sustainable diets by involving their national governments.

In the current FBDGs set out by several countries, there are many overlapping topics, such as: biodiversity, reduction of food waste and incorporating more plants into the diet^3,4.

At the 2024 Federation of European Nutrition Societies conference (FENS) in Serbia, several member countries presented how sustainability is incorporated into their FBDGs and how the messages were rolled out to the nationally.

They discussed their campaigns, how the projects were communicated to the public and some of the key themes.  For instance, Denmark and Flanders in Belgium highlighted key messages discussing the importance of eating plant rich foods, increasing vegetable consumption, decreasing meat consumption, choosing wholegrains, choosing plant oil, reducing sweet/salty and fatty foods, quenching thirst with water and choosing sustainably sourced foods⁵.

The Italian government has created a dedicated sustainability chapter in their FBDGs that discusses aspects such as packaging, socio-economic sustainability and myth busting of mis-interpreted statements related to sustainability⁶.

Several organisations have commented on how important it is that the principles of sustainability are led by experts in the field.

By correctly establishing these requirements in relation to public health, national governments can guarantee adherence to policy and feel confident that they can begin to transform their current food systems^7,8.

What Can Consumers Do?

In addition to FBDGs, consumers can adopt approaches to eat in a more sustainable way.

Variety in the diet is important to ensure adequate nutrient consumption and fuelling the body with enough energy.  Boosting variety can be accomplished by incorporating more fruit, vegetables, and plant-based sources.

Although it may be it is easier for the body to absorb nutrients from meats, there are ways that to improve nutrient absorption from plant-based foods.  For example, having a source of vitamin C (such as a glass of fresh orange juice with a meal) can assist with the absorption of iron.

In addition to increased diversity in the diet, another focus should be reducing the amounts of high fat, salt and/or sugar-containing foods in the diet.  This is effective to reduce carbon production as the production of these foods contribute to greenhouse gas emissions along with high water consumption^9,10.

Food waste also contributes a large component to climate change with approximately one third of food produced each year being wasted prior to consumption¹¹.  This is why it is important to minimise food waste where we can by only purchasing what we are going to consume, eating seasonally and understanding the difference between ‘use by’ and ‘best before’ dates^12,13.

Conclusion

As we move toward transforming how food is consumed and produced, achieving a sustainable food system must be considered.

Many countries are including sustainable nutrition recommendations as part of their FBDGs to encourage their population to reflect on the environmental impact as well as the health impact of their food choices.

Many governments globally have stressed the importance of consumer buy-in to ensure the effective implementation of these guidelines.

Sustainability is a key word for the public to be aware of and by strengthening their understanding of this, it will be easier to integrate environmental recommendations into public health legislation and policy.

The updated specification for E471 will be extended with additional contaminants commonly found in emulsifiers, i.e., Glycidyl Esters (GE) and 3-monochloropropanediol (3-MCPD).

Mono- and diglycerides are used across a range of F&B applications, e.g., bread, dairy, margarine, dressings, chocolate, ice cream and confectionery, to name the main ones.

In EFSA’s initial request for information, they called for more data regarding potential contaminants in E471 (such as trans fatty acids, heavy metals, erucic acid, butanetriols and acrolein).

Food emulsifier producers specify these analytical results and the lowest technically achievable levels of 3-MCPD and Glycidyl Esters in E471.  Up until now, these were not included in the specification for E 471.

After the EFSA’s call for data for E471, European emulsifier producers worked together to define maximum technical achievable levels of those contaminants and submitted their findings to EFSA in December 2020.

The European Commission included only the contaminants heavy metals, 3-MCPD and GE in the revised specification (the other earlier mentioned contaminants were not included).  The revised specification received a favourable opinion from the EU member states on the March 8, 2023.

As such, the proposed specification is expected to be adopted and the legislation to be enforced by mid-summer of this year. T he draft specification includes a six-month transition period for both E471 itself and food containing E471.

The upcoming legislation for the additional contaminants is specified as per below:

What You Need to Know as a Food and Beverage Manufacturer

The E471 emulsifier industry is responsible for meeting this new legislation and deliver compliant E471 into the market. It may be expected as responsible producers to ensure customers/F&B manufacturers are kept informed of current proceedings.

In addition, according to the new legislation, E471-containing food products produced outside Europe but exported into Europe must adhere to the updated E471 standard.

Background

The use of food additives (E-numbers) within the EU is governed by strict rules and regulations.  Each E-number has undergone a stringent safety evaluation by the European Food Safety Authority (EFSA), and when found safe for use has been authorised by the European Commission.

EFSA periodically revises specifications of E-numbers, at which point they are re-evaluated in risk assessments.

In November 2018, EFSA launched a public call for technical and toxicological data on food additive E471 (mono- and diglycerides of fatty acids).

EFSA recommended adapting the current specifications for mono- and diglycerides of fatty acids (E471), in particular by reducing the maximum allowable limits for toxic elements of safety concern and including two new contaminants.

All European food emulsifier producers are members of the non-profit industry organisation EFEMA (European Food Emulsifier Manufacturers Association), and worked together as responsible producers to prepare the required documentation to address this request from EFSA.

Click on each link o navigate to that part of the page.

• • Why are 3-MCPD and glycidol esters (GE) considered contaminants?
  • What are 3-MCPD and GE and how are they formed?
  • What is the source of 3-MCPD and GE in food emulsifiers, E 471?
  • Have E 471 manufacturers developed effective mitigation techniques?
  • Analytical method for 3-MCPD and GE
  • What are the new levels proposed as part of this legislation and when will it come into effect?

 Why are 3-MCPD and Glycidyl Esters (GE) Considered Contaminants?

3-MCPD is a Group 2B IARC “possible” human carcinogen and thus may cause cancer, and could also pose risks to kidney function and the male reproductive system [1][2].

Glycidyl esters are classified as genotoxic and are a Group 2A “probable” human carcinogen [3][4].

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What are 3-MCPD and GE and how are they formed?

3-MCPD esters and GE are predominantly formed during the refining process of vegetable oils in the deodorisation step that involves very high temperatures up to 230^oC.

The formation of these contaminates is also related to food with high fat content that have undergone thermal processing (e.g., frying and baking) [5][6][7].

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What is the source of 3-MCPD and GE in food emulsifiers, E 471?

Several studies have shown that mono- and diglycerides (E 471) are precursors for the formation of GE in oils and fats [5][6][7] and thus GE is an unavoidable by-product in the production process of E 471.

The formation of GE is increased with concentration of mono- and diglycerides, and with temperatures above 220°C [8].  Apart from mono- and diglyceride concentration and high temperatures, the formation of GE is also influenced by other parameters, such as the oil source and the fatty acid composition.

For example, mono- and diglyceride from unsaturated oils and fats can have higher levels of GE than fully hydrogenated fat-based products.  In addition, processing conditions (i.e., processing time, catalysts, steam, vacuum and mixing) can influence the final concentration.

3-MCPD is neither formed nor removed in the manufacturing process of E 71.  Formation of 3-MCPD requires chlorine, which is not present in the manufacturing process for E471.

As such, the 3-MCPD level in E 471 is introduced only via the raw materials sourced and used in the manufacturing process of E 471.

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Have E 471 manufacturers developed effective mitigation techniques?

Over the last several years, EFEMA members have carried out extensive research and development work to thoroughly understand the chemical pathways and conditions affecting the formation and degradation of GE.

GE is formed at high temperatures, but, at the same time, GE is also an unstable epoxide at high temperatures.  Mitigation involves a controlled heat treatment of the reaction mixture after formation of mono-and diglycerides and the associated, unwanted GE by-product.

The mitigation technique requires the installation of specialised equipment.

A significant part of the mitigation process has already been completed by European producers, and a large proportion of E471 efforts are focused on meeting the upcoming legislation of maximally allowed 10 ppm.

Mitigation implementation and further process optimisation are ongoing to be able to enable the tighter specification of max 5 ppm GE to be in place six months after the legislation comes into force.

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Analytical method for 3-MCPD and glycidyl esters

No accurate analytical method existed for E 471 when the initial EFSA call for data on GE and 3-MCPD was requested in 2018.  The available and published methods—the AOCS 29a-c methods—did not give reliable results for food emulsifiers.

EFEMA has worked for over two years with the SGS Germany laboratory on the development of an appropriate and reliable method for the measurement of 3-MCPD, 3-MCPD esters and GE in emulsifiers.

A method based on a modification of the AOCS Official Method Cd 29b-13 with gas chromatography–mass spectrometry (GC/MS) has been developed for E471.

The method has been validated by an internal ring test among EFEMA members and was released in summer 2020 by EFEMA.  Dr. Jan Kuhlmann of SGS published the method in October 2021 [9].

The analytical method is highly laborious, requires specific equipment and demands a significant investment. In addition, the method is not yet validated by the EU reference laboratory and is still in the process of achieving proper validation.

EFEMA is aware that the National Food Institute at Technical University of Denmark (DTU Food), which hosts the European Union Reference Laboratory (EURL) for processing contaminants, has worked on a validation study of the method. 

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What are the new levels proposed as part of this legislation and when will it come into effect?

To ensure a minimal impact on end customers, the European Commission has proposed transitional measures for dealing with products containing E 471, and for E 471 itself.

These transition periods permit producers to use E471 with GE above 10 ppm if the E471 was produced prior to the regulation coming into force.  The food that contains the E471 with GE above 10 ppm may be marketed until the use-by date.

Additionally, E471 with GE above 5 ppm and below 10 ppm that has been manufactured after the regulation has come into force may be used by producers until the exhaustion of stocks. Similar to the 10 ppm transition rules listed above, food containing this E471 may be marketed until the use-by date.

The proposed specifications and transitional measures are as follows:

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