Is all chocolate a UPF?

By Natasha Jolliffe-Spencer

- Last updated on GMT

Rethinking UPFs: New perspectives on chocolate
Controversy around ultra-processed foods (UPFs) continues to grow, especially with mounting scientific research as well as media attention scrutinizing the food group.

Chocolate, with its broad appeal, is often central to this debate. But is all chocolate classified as a UPF, and if it is, what are the implications for manufacturers and consumers? Could this trigger a shift in how chocolate is made, or will it remain a permissible indulgence despite the potential label?

As consumers grow more aware of UPFs, they may begin avoiding products they see as overly processed, including chocolate. In response, manufacturers might explore new product development strategies, focusing on less processed alternatives. Some brands, like Ombar, The Raw Chocolate Company, and Cocoa Runners, already produce and market minimally processed chocolates to cater to health-conscious consumers. If the UPF label becomes a more significant concern, could we see an influx of more such brands?

Is chocolate always a UPF?

The classification of chocolate as a UPF isn’t straightforward. “The classification of chocolate as an ultra-processed food depends on its components and how it is made,” says a spokesperson for the World Health Organization (WHO). The NOVA classification system, which categorizes foods based on their level of processing, may consider some chocolates to be UPFs while others may not fall into this category. NOVA is widely used to divide foods into four groups: unprocessed or minimally processed foods, processed culinary ingredients, processed foods, and UPFs.

“It depends on the processing and final composition,” agrees professor Pete Wilde, Emeritus Fellow at Quadram Institute, Norwich Research Park, highlighting that it’s not a one-size-fits-all determination.

To make chocolate, producers undergo several processes, from mechanical separation of the beans from the pod to fermentation, drying, roasting, and grinding. The next steps involve adding ingredients like milk and sugar. Lecithin, an emulsifier that helps mix sugar and fat particles for a smooth texture, is also commonly added at this stage. “Lecithin has been used in chocolate-making since the 1930s and makes up less than 0.5% of the chocolate’s weight,” a spokesperson from the Food and Drink Federation (FDF) explains.

However, the use of additives and the extent of processing can push certain chocolate products into the UPF category. “Processing methods and the addition of industrial additives like flavourings, colourings, non-sugar sweeteners, and emulsifiers determine whether a chocolate product falls into the UPF category,” according to the WHO. “A chocolate containing these additives is more likely to be classified as ultra-processed.”

Conversely, a minimally processed chocolate made at home may not be considered a UPF, even if similar processes are involved. “A homemade product is not classified as a UPF, so a chocolate bar made at home may not fit into that category even if it follows the same steps as a supermarket-bought chocolate,” the FDF spokesperson adds.

The limits of what we know

One challenge in definitively answering whether chocolate is a UPF lies in the lack of a universally accepted definition of UPFs. “WHO does not yet have formal guidelines on UPFs,” their spokesperson clarifies. Still, the organization encourages people to limit their intake of highly processed foods and beverages, promoting a diet centered around minimally processed foods that are low in free sugars, salt, unhealthy fats, and free from non-sugar sweeteners.

“The definition of UPF is broad and subjective,” the FDF spokesperson says, indicating the ongoing debate within the food industry. This lack of clarity extends to the unknown health effects of various ingredients used in processed chocolate. “We know a lot about the health impacts of chocolate’s polyphenols, fat, and sugar, but we don’t yet fully understand the effects of the additives,” Professor Wilde adds.

The amount of chocolate consumed also matters. Wilde notes, “If eaten sparingly, as it’s designed to be—an indulgent product—chocolate can form part of a healthy diet with little or no health impact. In fact, for very high cocoa content products, the health benefits could even be positive. But if chocolate is consumed daily in excess, the health impacts are likely to be negative.”

Evolving understanding of UPFs and chocolate

The debate over UPFs is still developing, and the WHO is in the early stages of creating formal guidelines. “WHO is working on establishing a clear definition of UPFs based on the NOVA system, which will help objectively classify these foods,” says their spokesperson. Countries such as Brazil and Chile have already developed policies that recommend limiting UPF intake, emphasizing the growing awareness and regulatory focus on food processing.

The FDF spokesperson adds that while it’s essential to consider the risks associated with highly processed foods, food processing itself offers many benefits, including food safety, longer shelf life, and greater convenience for busy families. “Food processing also helps increase the availability of healthier options, such as products that are lower in fat, salt, or sugar, or fortified with vitamins and minerals,” the spokesperson states.

For chocolate companies, this growing concern around UPFs may represent an opportunity to innovate. A move towards minimally processed chocolate could strike a balance between indulgence and health-consciousness. Brands that can produce chocolate products with fewer additives and less industrial processing may find favor with consumers seeking to maintain a healthy lifestyle without giving up chocolate entirely.

Professor Wilde notes that the perception of UPFs as inherently harmful oversimplifies the issue. “The notion that all UPFs are bad for you is far too simplistic,” he says. The FDF spokesperson echoes this sentiment: “All foods, including processed ones, can be part of a healthy balanced diet.”

Looking ahead

In 2023, the UK’s Scientific Advisory Committee on Nutrition (SACN) concluded that there wasn’t enough evidence to support any concrete policy recommendations around food processing. However, consumer education continues. The Food Standards Agency (FSA) and Food Standards Scotland (FSS) have both published resources on processed foods and health, encouraging people to follow the Eatwell Guide, the UK Government’s official guide to healthy eating.

As chocolate remains a beloved treat, the key for manufacturers may lie in creating products that retain the indulgent appeal while aligning with consumer demands for less processed, healthier alternatives. Whether or not all chocolate is classified as a UPF, the evolving narrative around food processing could inspire a shift in how this sweet indulgence is made and consumed. 

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