WCMA Notes: UPF Definition Poses Threat to Dairy Consumption, Americans’ Best Health
America faces rising rates of obesity, diabetes, cancer, and cardiovascular disease that strain our health care system, and negatively impact the lives of millions. Policymakers are right to seek nutrition-based solutions and the latest report from the Make America Healthy Again (MAHA) Commission includes some proposals dairy leaders can applaud – namely, calls for enhanced nutrition in schools and veterans' programs, along with new educational campaigns focused on healthy eating.
The MAHA report, however, also shares ideas that raise concern for our industry – including a strong push for a federal definition of “ultra-processed foods” (UPFs). This comes after a formal request for public comments on the concept of defining UPFs from the U.S. Food & Drug Administration (FDA) and the U.S. Department of Agriculture (USDA), along with messaging from U.S. Health & Human Services Secretary Robert F. Kennedy, Jr. pointing the finger at UPFs for “driving our chronic disease epidemic.”
It is clear that federal regulators are now seriously considering the use of foreign frameworks like Brazil’s NOVA classification system, which categorizes foods based on the extent of processing or the number of ingredients, rather than nutrient content of a food product.
Wisconsin Cheese Makers Association (WCMA), representing more than 850 companies and cooperatives across 44 states, finds this a misguided approach – and one that threatens both dairy consumption and Americans’ best health.
Both in WCMA’s filed public comments on defining UPFs and in direct communication with policymakers, our Association is strongly urging agency leaders to rethink their strategy. Defining UPFs and creating a classification system stands to stigmatize many dairy foods that are safe, nourishing, and essential to diets – simply because of the way they’re made. In practice, a cup of fortified yogurt or a protein-packed slice of cheese could be treated as nutritionally suspect, because it required pasteurization, culture development, or added rennet to create. This outcome would run contrary to established nutritional science standards.
Make no mistake, the U.S. has a gold-standard food regulation system. Between FDA’s Nutrition Facts panel, mandatory ingredient labeling, and tightly regulated health and nutrient claims, consumers have more transparency in the marketplace now than ever. Add to that the Dietary Guidelines for Americans, updated every five years, historically with rigorous scientific review, and Americans already have the tools they need to make informed food choices.
Layering a new “ultra-processed” label over this framework risks confusing the public, potentially turning them away from all the goodness dairy has to offer. Milk, cheese, yogurt, and other dairy products deliver high-quality proteins, calcium, potassium, phosphorus, riboflavin, vitamin B12, and vitamin D in fortified varieties. Decades of peer-reviewed studies demonstrate the association of many dairy products – including those that go through multi-step processing – with lower risks of cardiovascular disease, hypertension, osteoporosis, and even certain cancers. Meta-analyses of randomized controlled trials have found dairy consumption can help reduce body fat while preserving lean muscle. Large cohort studies have linked higher dairy intake with lower incidence of metabolic syndrome and type 2 diabetes.
Processing does not create a barrier to those health benefits – and, in fact, it protects against threats to consumers’ wellness. Pasteurization keeps milk and other dairy products safe for consumption. Fermentation gives us probiotic-rich yogurts. Fortification has helped eliminate diseases in the U.S. More recent innovations like lactose-free dairy, A2 milk, and extended shelf-life technologies have opened doors for millions more consumers to enjoy dairy’s benefits, no matter their individual dietary needs.
If “processing” becomes shorthand for “unhealthy,” we risk discouraging the very practices that keep food safe, reduce waste, and deliver innovation. For dairy processors, it could stifle investment in new health-forward products just as consumer demand for high-protein, functional foods is exploding.
Public health progress will not come from a federal definition of “ultra-processed foods” or from any food classification system that penalizes products based primarily on factors like the number of ingredients they include or how they are made. Progress will come from strengthening the tools our country already has – transparent labeling, rigorous science, strong dietary guidance - and efforts to ensure consumers trust and use them. It will come from partnering with the dairy industry to build increased access to the milk, cheese, yogurt, and other dairy products essential to Americans’ best health.