A draft of the European Commission’s upcoming cardiovascular strategy, the “Safe Hearts Plan”, has begun to circulate in Brussels. The text is not final, but its direction is already clear enough to raise concerns.
Proposals targeting sugary drinks, alcohol, and potentially certain categories of ultra-processed foods suggest a move toward treating entire categories as the problem, rather than addressing specific products and consumption patterns. This points to a more interventionist approach to diet, one that prioritizes broad signals over more targeted measures.
The objective is difficult to contest. Cardiovascular disease remains the leading cause of death across the European Union, and policymakers are under pressure to demonstrate progress. Yet the framing matters as much as the ambition. Food is not tobacco, and approaches that treat broad categories of everyday products as inherently harmful are likely to risk overlooking how those products function within European societies, especially in a period shaped by economic pressure and geopolitical instability.
A strategy shaped by a different reality
The timing of this debate is inconsequential. Europe is operating in a context defined by war on its borders, persistent inflation, and continued fragility in global supply chains. Food systems have not been immune to these shocks. Input costs have risen, transport routes have been disrupted, and households across the Union have felt the return of food as a significant budget item.
In this environment, questions of affordability and access are no longer secondary considerations. They sit at the center of political stability. Policy choices that affect the price, availability, or practicality of food need to be assessed not only through a public health lens, but through their broader economic and social consequences. A strategy that fails to account for these constraints risks producing outcomes that are not aligned with the reality of European consumers.
The critique of ultra-processed foods
Criticism of ultra-processed foods has gained traction in recent years, supported by a growing body of research linking high consumption to obesity, cardiovascular disease, and metabolic disorders. Diet quality is a key determinant of long term health, and excessive consumption of products high in salt, sugar, and saturated fats can present risks. However, the policy leap from identifying dietary risk to targeting ultra-processed foods as a single category is scientifically unsound.
The classification itself, “ultra-processed”, lacks scientific clarity, with multiple definitions in circulation, and groups together products that vary widely in nutritional profile and use. Wholegrain bread, fortified cereals, dairy products, and infant nutrition all fall under the same category as candy and soft drinks. Treating these items as functionally equivalent leads to the risk of obscuring important distinctions and may lead to blunt policy instruments that fail to target the drivers of poor health outcomes.
It should also be noted that there are limits to what the current evidence can establish. Much of the research on ultra-processed foods is observational, making it difficult to disentangle the effects of processing from broader dietary patterns and socioeconomic factors. High consumption of these foods often correlates with lower income, time constraints, and reduced access to fresh alternatives. Without addressing those underlying conditions, focusing on processing alone risks confusing correlation with causation, which is not the basis upon which policy should be built.
What do ultra-processed foods actually do
The debate is often framed around what ultra-processed foods are, rather than what they do. In practice, they perform a set of functions that are deeply embedded in the European food system. Processing allows for consistency in nutritional content, ensuring that food delivers predictable levels of calories and key nutrients regardless of season or geography. This is particularly relevant in a Union that relies heavily on imports for fresh produce and is exposed to climatic and logistical disruptions.
Shelf life is another critical factor. Foods that can be stored and transported efficiently help stabilize supply chains and reduce vulnerability to shocks. When fresh imports are delayed or disrupted, longer-lasting products provide continuity. This is not a marginal benefit. It is a core element of food system resilience.
Convenience is often dismissed in policy debates, but it reflects structural realities. Working patterns across Europe, particularly in urban areas, leave limited time for food preparation. Dual-income households, long commutes, and childcare responsibilities greatly reduce the time available for cooking. In that context, ready-made meals, packaged foods, and shelf-stable products enable households to maintain regular eating habits without additional strain.
Cost reinforces these dynamics. Ultra-processed foods often benefit from economies of scale in production and distribution, resulting in more predictable pricing. For households managing tight budgets, that predictability matters. It reduces the risk of waste, supports meal planning, and allows for a degree of financial stability in an otherwise volatile environment.
Public health gains often overlooked
Processing has also delivered measurable public health benefits that tend to receive less attention in current debates. Techniques such as pasteurization, preservation, and controlled packaging have significantly reduced exposure to foodborne illness across Europe. These improvements have been incremental and largely invisible, but they form the foundation of consumer trust in the food system.
Processing also enables fortification and adaptation. Foods can be designed to meet specific nutritional needs, from infant formula to products tailored for particular deficiencies or dietary restrictions. This flexibility has expanded access to adequate nutrition across diverse populations. A framework that treats processing primarily as a risk factor risks overlooking these vital contributions.
Toward a more credible policy approach
None of this suggests that the EU should step back from addressing cardiovascular health. The question is how to do so effectively. A strategy that relies on broad categorization and generalized discouragement may offer easy political clarity, but it runs the dangerous risk of missing the complexity of how food systems operate and how people live.
A more credible approach would focus on targeted measures. Policies that address affordability and access to a wider range of foods can help improve diet quality in a way that reflects real constraints.
The current debate needs to recognize that resilience and health are not opposing objectives. In a context shaped by instability, ensuring that food remains available, safe, and affordable is itself a public good. Policies that undermine these attributes in pursuits of simplified narratives risk creating new pressures rather than resolving existing ones.
Avoiding a false analogy
The temptation to draw parallels between ultra-processed foods and tobacco is understandable from a communications perspective. It offers a clear storyline and a familiar policy playbook. But it is also a misleading comparison. Tobacco has no safe level of consumption and no functional role in sustaining daily life. Food, including processed food, is different. It is part of the infrastructure that allows societies to function.
As the Safe Heart plan evolves, there is still time to adjust its framing. A strategy that gives due consideration to the functions of ultra-processed foods will be better equipped to deliver meaningful outcomes. Ignoring that balance may simplify the message, but it risks profoundly weakening the policy.
Europe’s challenge is not to eliminate complexity, but to manage it. In the case of food, that means recognizing that improving public health requires more than identifying what to reduce. It requires understanding what must continue to work.

