Scientific Considerations and Potential Implications for Ultra-processed Food Definitions, Classifications and Policy
A Unique Example of Dairy Foods
We appreciate the opportunity to provide information for consideration regarding the role of ultra-processed foods in nutrition and health. As discussions on food processing continue to evolve, we encourage a balanced, evidence-based approach that evaluates foods based on their nutritional contributions to the diet and their role in helping individuals meet dietary recommendations.
Executive Summary
California’s AB 2244 proposes the development of a voluntary "Non-Ultraprocessed Certified Food Standard” intended to help consumers identify foods that meet specific processing and ingredient criteria. While improving diet quality and reducing chronic disease are important public health objectives, significant scientific questions remain regarding how ultra-processed foods (UPFs) should be defined, measured and regulated. Current evidence suggests that food processing alone is not a reliable indicator of nutritional quality or health impact. Policies focused primarily on processing classifications may create unintended consequences for consumer understanding, nutrition security and access to nutrient-dense foods, including dairy products and other healthy items like canned beans, frozen fruits, and whole grain cereals.
Scientific Uncertainty Surrounding UPFs
Interest in UPFs has grown substantially due to observational studies linking higher UPF consumption with obesity, cardiovascular disease, type 2 diabetes and other chronic conditions. However, many experts caution that the evidence remains insufficient to conclude that processing itself causes these outcomes. Most UPF studies are observational and cannot establish causality. In addition, studies often use inconsistent definitions and classify nutritionally diverse foods within the same category, making results difficult to interpret.
The 2025 Dietary Guidelines Advisory Committee identified limitations in the current evidence base and did not provide recommendations related to UPF consumption due to concerns regarding definitions, classification methods and interpretation of findings. Experts continue to debate whether observed health risks are attributable to food processing itself or to nutritional characteristics that frequently co-occur in some UPFs, such as higher calorie density, added sugars, sodium and lower fiber content.
Why Processing Alone May Not Reflect Healthfulness
Food processing serves important functions in the food supply, including improving food safety, extending shelf life, reducing food waste, increasing accessibility and preserving nutritional quality. Processing can also support product reformulation efforts aimed at reducing sodium, sugar and saturated fat while improving nutrient content.
Several experts have noted that current classification systems, particularly NOVA, focus largely on formulation and ingredients rather than nutritional value. As a result, foods with strong nutrient profiles may be classified as UPFs, while foods with lower nutritional value may receive more favorable classifications. This can create conflicting messages for consumers and confusion within nutrition education efforts.
Dairy Foods Highlight the Complexity of UPF Classification
Dairy foods provide a practical example of why processing-based classifications may not align with nutrition science and intended public health outcomes. Processing is essential to dairy food safety and functionality. Pasteurization ensures the safety of milk, while fermentation produces products such as yogurt, kefir and cheese that have demonstrated health benefits. Depending on ingredients and formulation, dairy products can be classified across multiple processing categories despite providing similar nutrients and health benefits.
Dairy foods provide nutrients that work together to support health and well-being. Emerging evidence highlights the importance of the dairy matrix, the natural combination and interaction of nutrients, bioactive compounds and food structure found in milk, yogurt and cheese. These interactions help explain the health benefits associated with dairy foods that extend beyond the effects of individual nutrients such as naturally occurring saturated fats, sodium and sugars, or processing levels.
Evidence-Based Health Benefits of Dairy Foods
Across fat levels, dairy foods provide a unique combination of nutrients, including high-quality protein, calcium, vitamin D, potassium, iodine and other essential nutrients that work together to help support strong bones and muscles, cardiometabolic health, cognitive health and overall well-being across every life stage.
Offering consumers a range of food varieties and nutrient-dense options gives individuals the flexibility to choose dairy foods that fit their personal preferences, culture and lifestyle needs.
UPF Policy Considerations
A recent Healthy Eating Research consensus paper proposed defining UPFs using NOVA Group 4 and classifying packaged foods as UPFs when they contain at least one cosmetic additive or ingredient of non-culinary use. While intended to support future policy efforts, this ingredient-based approach could classify many nutrient-dense dairy foods as UPFs, including certain yogurts, flavored milk, dairy protein beverages, processed cheese products and meal replacements. It could also categorize dairy-derived ingredients such as whey protein, casein, lactose and milk protein isolate as UPF markers, regardless of their role in improving nutrient density, protein quality or product functionality.
As California considers a Non-Ultraprocessed Certification standard, policymakers should evaluate whether the framework:
Conclusion
California is a leader in addressing legitimate concerns about diet quality and chronic disease; however, the scientific understanding of UPFs remains unsettled. Current evidence suggests that processing alone is not a sufficient measure of a food's nutritional value or health impact. Dairy foods illustrate how processing can enhance food safety, preserve nutrients, and contribute to positive health outcomes. A science-based certification framework should therefore consider nutrient density, dietary contribution, food matrix effects, accessibility, food safety, affordability, cultural foodways and consumer understanding to ensure California's policies support both public health and nutrition security.
About Dairy Council of California
Dairy Council of California is a science-based nutrition organization that collaborates with partners to elevate the health of children and communities through the pursuit of lifelong healthy eating patterns. Funded by California’s dairy farm families and milk processors and under the guidance of the California Department of Food and Agriculture, Dairy Council of California’s registered dietitian nutritionists and experts in nutrition science, education, agricultural literacy and community health engage with partners in school, health care and community settings, working together to achieve nutrition security and optimal health. Each year these collective efforts improve access to nutritious foods and provide nutrition education and resources for millions of people in California and beyond, demonstrating the dairy community’s contribution to sustainable nutrition and community health.
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