Across ASEAN, food classification systems built around degree of processing are moving from academic discussion into regulatory consideration. The NOVA system, in particular, which sorts foods into four tiers and groups a broad range of items as "ultra-processed," is increasingly cited in policy debates on taxation, labelling, and dietary guidance.
The appeal is understandable as it is a single classification that offers regulators a new, seductive method. The problem is that the underlying evidence does not support the regulatory weight now being placed on it.
The evidence base linking processing level to health outcomes is not yet strong enough to justify legislative action. That does not mean diet-related disease in Asia is not real, or that nutritional quality should not drive policy. It means the specific tool now being proposed, classification by degree of processing, has not been demonstrated to identify what makes food harmful, and risks producing policy that misses the actual problem.
The body of evidence linking "ultra-processed" intake to chronic disease is predominantly observational. It cannot establish causality, and is highly vulnerable to confounding by overall diet quality, socioeconomic status, and lifestyle. The thresholds at which processed food intake is reportedly associated with increased mortality risk vary dramatically across populations, and some cohorts with very high consumption show no significant elevated risk at all.
More fundamentally, the NOVA framework does not categorize nutritional quality within its "ultra-processed" category. It groups products higher in sugar content with fortified wholegrain cereals. Treating those as a single regulatory target is not a scientific judgement; it is a categorical one.
This uncertainty is reflected in the cautious positions of the scientific bodies a precautionary regulator would normally cite. France's ANSES has concluded that the “ultra-processed” concept has not yet been scientifically substantiated, and that classification by degree of processing cannot be translated into health risks or used for nutritional education.
The Nordic Nutrition Council, given the opportunity to act, declined to include UPFs in its 2023 Nordic Nutrition Recommendations. These are not industry-aligned positions. They are the considered judgements of jurisdictions that take dietary public health seriously, and they tell Asia regulators something important about where the science currently stands.
Still, the operational consequence for food systems is direct. Fortification programmes across ASEAN and India that have attempted to reduce micronutrient deficiency fall on the wrong side of the NOVA line. Indonesia's mandatory wheat flour fortification, in place since 2002 and covering iron, zinc and B vitamins, alongside vitamin A fortification of cooking oil and salt iodisation, sits in the same regulatory bucket as products with no comparable nutritional rationale.
So do the shelf-stable fortified foods the World Food Programme moved at scale after the 2004 Indian Ocean Tsunami, when over 50,000 metric tonnes reached 1.75 million survivors. A classification framework that treats all these as equivalent risks creates conditions for policy that discourages the very interventions governments rely on to address undernutrition, support disaster response, and keep affordable nutrition within reach of lower-income households.
The position is not that food policy across Asia should stand still. Diet-related disease in the region is a real problem, and FIA's members are reformulating, fortifying, and innovating in response to it.
But the right regulatory tool for that work is nutrient profiling within a Codex-aligned framework, not a classification system whose own scientific home jurisdictions have declined to act on. Regulators considering NOVA-based measures should defer them, and direct effort instead toward classifications grounded in nutrient composition.
FIA's April 2026 white paper, Why Food Processing Is Important To Us, sets out the full evidence and policy case in detail, and is available to download [here].