Defining ultra processed foods: What it means for dairy

Roberta Wagner, left, is senior vice president of regulatory and scientific affairs at IDFA. Michelle Albee Matto is associate vice president, regulatory affairs and nutrition at IDFA.

Consumers have long been advised to eat more whole and minimally processed foods low in added sugars, sodium and saturated fat. More recently, consumers are also being advised to eat less “ultra-processed foods” (UPF) or avoid them completely. Yet, unfortunately there is not a single definition for UPF that scientists and policymakers can agree upon. To complicate matters further, other terms are being used synonymously with UPF, including most recently “highly processed foods.”

Regardless of the term used, there is extreme pressure to reduce the consumption of foods that have undergone multiple processing steps and/or that contain ingredients derived through extensive extraction and processing steps driven in part by the “Make America Healthy Again” (MAHA) movement and the recent strategy provided by the Administration’s MAHA Commission.

While there is not an agreed-upon definition for UPF, one of the most commonly referenced processing-based categorization schemes for foods is Nova, which includes dairy in all four categories of its scheme. These include unflavored milk as an “unprocessed or minimally processed food” and flavored yogurt as an “ultra-processed food.”

In 2025, the federal government (USDA and FDA) issued a request for information soliciting (RFI) public input on a potential national definition for UPF for research and policymaking purposes. In our comments, IDFA emphasized the following:

• It is premature to adopt a regulatory definition for UPF given “the inconsistent and inconclusive body of existing science” and the lack of clear causal links between UPF consumption and specific adverse health outcomes. We called for a robust, evidence-based foundation before a regulatory definition is adopted and emphasized that any regulatory definition should focus first and foremost on the nutrient richness or composition of foods, and not solely on the processing and/or the ingredients used to make the foods.
• If the federal government chooses to define UPF in the near term, it must avoid unintended consequences for nutrient-rich processed foods including dairy products. We emphasized that many dairy foods are “nutrient-rich, yet under-consumed” by Americans and offered that any UPF definition should not disincentivize the consumption of such foods. Further, we cautioned that an overly broad definition might inadvertently harm public health goals by discouraging the consumption of foods that deliver important nutrients.
• Processing foods and adding ingredients that have been processed does not automatically make the food “unhealthy.” We emphasized that industry uses various processing methods to deliver safe, nutritious and accessible foods to consumers. We stated more specifically that processing can ensure food safety (e.g., pasteurization), enhance nutritional value (e.g., vitamin D fortification of milk), address dietary needs (e.g., lactose-free products), and extend the shelf life of foods, which reduces food waste.
• To achieve the goal of reducing food-related chronic disease, the focus must remain on a balanced diet and dietary patterns. We recommended that instead of singling out the processing level, federal efforts to reduce diet-related chronic disease should continue focusing on encouraging moderation, portion size and balanced diets aligning with existing federal dietary guidance, including the consumption of nutrient-rich foods like dairy.

The federal government received tens of thousands of comments in response to the RFI, reflecting a wide range of perspectives and often conflicting views on how — or whether — UPF should be defined. With so many scientific, practical, and policy considerations at play, developing a national definition will be challenging. Notably, California recently established the first regulatory definition for UPF specifically to inform K through 12 school meal program policies.

If this approach is deemed feasible, this state definition could inform the federal government’s future approach to defining UPF. Even without a federal level definition for UPF, we anticipate the upcoming Dietary Guidelines for Americans will have a general recommendation to eat more whole and minimally processed foods and less highly processed foods or UPF — while still recognizing the important role nutrient-rich foods like dairy play in a healthy diet. DF