• A new conceptual analysis argues that many ultra processed foods are designed to drive repeated consumption using strategies similar to those used by the tobacco industry.
  • The authors describe how product formulation, rapid delivery of reward, constant availability, and health themed marketing can combine to encourage habitual over eating, with observational studies linking high intake to higher risks of several chronic diseases.
  • They say regulation should focus on the most harmful products through measures such as marketing limits, clearer labelling, and taxation, rather than treating every processed product the same.

Ultra processed foods are everywhere – they are convenient, shelf stable, heavily marketed, and built to taste intensely rewarding.

A conceptual analysis published in The Milbank Quarterly argues that this is not accidental, and that the modern ultra processed food industry has adopted tactics and design principles that resemble the strategies once used to build the cigarette market.

The authors start from a public health problem: in many industrialised countries, ultra processed foods contribute a large share of daily calorie intake.

At the same time, higher consumption has been linked in observational research to increased risk of cardiometabolic disease, cancer, neurodegenerative disease, and premature death.

Observational links do not prove cause and effect, but the scale and consistency of these associations have fuelled calls for stronger policy action.

A key point in the paper is that the debate about whether ultra processed foods meet formal definitions of addiction may not be the deciding factor for regulation.

The authors argue that public health action can be justified even if scientists continue to disagree on the best label, especially when products are widely consumed and potential harms are population wide.

They describe the underlying behavioural science in plain terms.

Reward learning is heavily influenced by dopamine signalling. When a behaviour reliably produces a quick, predictable reward, the brain becomes more likely to repeat it.

Cigarettes deliver nicotine rapidly, paired with additives that make smoke easier to inhale and more pleasant, which helps reinforce use.

The authors argue that many ultra processed foods can produce a similar pattern of fast reinforcement.

Products engineered with refined starches, sugars, and fats can be digested quickly, delivering rapid rises in blood glucose and strong reward signals, followed by a drop that may encourage a return to eating.

They also point to the way texture and structure are engineered so foods are easy to chew and swallow quickly, reducing the natural friction that comes with whole foods.

The analysis outlines several product design and market strategies that may promote habitual over consumption:

  1. Dose optimisation, tuning sugar, salt, fat, and additives to maximise pleasure without tipping into aversion.
  2. Delivery speed, stripping away the natural food structure so rewarding ingredients reach the body quickly.
  3. Hedonic engineering, creating a sharp peak in enjoyment that fades quickly, which can increase craving for another serving.
  4. Environmental ubiquity, ensuring products are available everywhere and at any time, normalising frequent use.
  5. Deceptive reformulation and marketing, using claims such as low fat, added fibre, or sugar free to create a health halo while leaving the core consumption drivers intact.

The authors also draw parallels in public messaging and lobbying, arguing that both industries have used targeted marketing and selective framing to protect sales and limit scrutiny.

They compare health themed reformulations in food to historic tobacco tactics such as low tar branding, which did not remove the underlying health risks in a meaningful way.

What would regulation look like if policymakers treated the highest risk ultra processed foods more like tobacco products?

The authors suggest several options, including taxation of the most harmful categories, clearer front of pack labelling, restrictions on advertising, and limits on where and how some products are sold, especially around children.

They also argue against a simplistic approach that treats every ultra processed item as identical.

Some products that fall under broad definitions of processing may be relatively neutral in health impact, so policy should be targeted rather than blanket.

For people living with diabetes, the practical relevance is straightforward.

Many ultra processed foods are designed to be easy to over eat and can drive sharp glucose rises, making day to day time in range management harder.

The most useful individual level response is not perfectionism but pattern change: shift the balance towards minimally processed foods that keep you full for longer, keep ultra processed snacks as occasional items rather than default fuel, and be sceptical of packaging that markets a product as healthy while it remains highly refined and easy to consume quickly.

Get our free newsletters

Stay up to date with the latest news, research and breakthroughs.