Researchers Say Ultra-Processed Foods Should Be Regulated Like Tobacco

• Researchers at Harvard, Duke and the University of Michigan argue that ultra-processed foods should face regulation comparable with tobacco because they are engineered to encourage habitual overuse.
• Their paper draws comparisons between cigarettes and ultra-processed foods, citing additives, reward systems and marketing methods that influence biological and psychological responses.
• The authors contend that some ultra-processed foods resemble engineered consumables more than genuine food, and advocate policies that favour minimally processed choices and curb misleading health claims.

Much has already been reported about ultra-processed foods and the possible consequences for human health. Food & Wine has closely followed emerging research, which suggests that ultra-processed foods could be contributing to a global health crisis, raising the risk of heart disease and even changing the signals that govern hunger. In response to this evidence - along with numerous similar findings - researchers are proposing a potentially radical measure: regulating ultra-processed foods as tobacco is regulated.

In a new paper published in Milbank Quarterly, researchers from Harvard, Duke and the University of Michigan wrote: "Cigarettes and UPFs are not simply natural products but highly engineered delivery systems designed specifically to maximize biological and psychological reinforcementand habitual overuse," a team of researchers from Harvard, Duke, and the University of Michigan wrote in their new paper, published in the journal Milbank Quarterly. "Both industries have used similar strategies to increase product appeal, evade regulation, and shape public perception, including adding sensory additives, accelerating reward delivery, expanding contextual access, and deploying health-washing claims. These design features collectively hijack human biology, undermine individual agency, and contribute heavily to disease and health care costs."

The evidence behind the tobacco comparison

To arrive at their conclusion, the team brought together decades of evidence from addiction science, nutrition, epidemiology and public-health history. They assessed how cigarettes were designed to maximise nicotine delivery, then compared those methods with ultra-processed foods. Their analysis centred on five areas of considerable overlap: dose optimisation, delivery speed, “hedonic engineering” - in other words, making foods irresistibly appealing - environmental ubiquity and “health washing”, which presents products as beneficial.

The similarities identified in the review are striking. As with cigarettes, ultra-processed foods are calibrated to provide particular quantities of sugar - such as the rapid hit from a fizzy drink - or a carefully engineered fat-and-carbohydrate balance, as in crisps.

The researchers wrote: "Refined carbohydrates stimulate dopamine release via the vagus nerve, whereas fats do so through intestinal lipid sensing," they wrote. "... UPFs with high levels of refined carbohydrates and added fats are some of the most potently rewarding substances in the modern diet. Notably, this refined carbohydrate-fat combination is almost nonexistent in nature."

These foods may have addictive potential similar to cigarettes because they deliver feel-good chemicals to the brain so quickly. Cigarettes, the researchers note, are designed to supply nicotine within seconds; ultra-processed foods, meanwhile, are made for swift digestion and absorption. With little or no fibre, they allow the body to process sugar and fat faster.

The paper also briefly explains why stopping after a single tasty crisp can be so difficult. According to the authors, ultra-processed foods use deliberate sensory design, including intense flavours that quickly fade and melt-in-the-mouth textures. These features generate further dopamine release, prompting the thought: "ok fine, one more."

The near-constant availability of ultra-processed foods, combined with marketing that often “health-washes” them through labels such as “low-fat” and “sugar-free”, reinforces the comparison. It resembles the way cigarettes have been promoted as “light”.

Understanding the spectrum of ultra-processed foods

The authors stress that ultra-processed foods are not all alike: risk differs according to both their ingredients and the extent of their processing. They add that “minimally processed” foods present a lower risk. As Food & Wine has previously explained, “minimally processed” covers the “removal of inedible or unwanted parts, cutting, drying, crushing, grinding, fractioning, roasting, boiling, pasteurisation, refrigeration, freezing, placing in containers, vacuum packaging, and non-alcoholic fermentation.” The researchers compared this category with “nicotine replacement therapies, such as transdermal patches, often contain more nicotine than a single cigarette but have minimal addictive potential.”

Although food and tobacco are not the same - food is essential to life, the authors acknowledge - they argue that some ultra-processed products operate less like conventional foods and more like highly optimised consumables. They recommend that public-health policy should account for that distinction.

How to identify ultra-processed foods from a label

Ultra-processed foods rarely appear obviously extreme, and are frequently sold as convenient, fortified or even “better for you”. Packaging claims such as “low-fat”, “high-protein” and “sugar-free” can be misleading. The ingredients list is generally the best indicator of how industrially formulated a product is: the more engineered and unfamiliar the ingredients seem, the more likely it is to be ultra-processed.

Warning signs include:

• Lengthy ingredient lists, often containing more than 5–7 items
• Ingredients that would not typically be used in home cooking
• Emulsifiers, including soya lecithin or mono- and diglycerides
• Artificial flavours or colours
• Isolated starches or protein isolates
• Several forms of added sugar

What regulating ultra-processed foods could involve

The researchers wrote: "Tobacco provides a warning, and tobacco control provides a source of hope. It is easy to forget how deeply cigarettes were once woven into American life, marketed as symbols of modernity, embedded in social rituals, and celebrated as an economic boon," they wrote. Regulation, however, has caused US smoking rates to fall sharply and has "reshaped cultural views of tobacco and eroded trust in the industry."

Unlike tobacco, the researchers say, the solution is already known: "Minimally and traditionally processed foods that have sustained human health for millennia. Legal action against health damages and misleading health claims, restrictions on UPF advertising, taxation of nutrient-poor UPFs, markedly reducing UPFs in schools and hospitals, and clearer labeling of ultraprocessing could all serve as next steps," they wrote. They also argued that merely requesting companies to make changes will not suffice. "Policies that confront UPFs with the same seriousness that once applied to tobacco, while actively promoting real food, offer the most promising path out of the current crisis."