By Stephanie Clark, Ph.D.
Manager of Academic Engagement | American Dairy Products Institute
To scientists, the term ultra-processed may evoke ideas of innovation and technological advancement. To consumers, however, it may conjure images of artificial ingredients with unpronounceable names and hyperactive children. Paradoxically, food processing was—and still is—primarily designed to protect and please consumers. Yet have our efforts to please consumers gone so far that we cause more harm than good? The term ultra-processed is at linguistic and scientific crossroads—intended for classification, yet often leading to overgeneralized condemnation.
In preparing to write this piece, I pulled from my shelf the high school graduation gift from my brother—a hard copy of Webster’s Ninth New Collegiate Dictionary (1986, Merriam-Webster Inc., Springfield, MA). Neither ultra-processed nor ultraprocessed appeared. The Eleventh[1] Edition (originally published in 2003, available at https://www.merriam-webster.com/dictionary/ultra-processed), defines ul·tra-pro·cessed[2] as “of foods and beverages: containing or made primarily with highly processed ingredients including artificial additives (such as coloring, flavoring, and preservatives) and typically having high levels of fat, sugar, or salt.” Similarly, the Oxford English Dictionary[3] (https://www.oed.com/dictionary/ultra-processed_adj) defines ultra-processed as “(of food) subjected to a high degree of industrial processing during manufacture, and usually containing large quantities of additives.”
While these definitions capture some elements of the science of food processing, they do not convey the emotional charge the term carries in public discourse.
Efforts have been made to classify ultra-processed foods (UPF or UPFs). In 2019, the Food and Agriculture Organization of the United Nations (Monteiro et al. 2019[4]) detailed the Nova food classification system initially proposed in 2009[5]. Nova divides foods into four groups:
- Group 1, unprocessed or minimally processed foods
- Group 2, processed culinary ingredients
- Group 3, processed foods
- Group 4, ultra-processed foods
While acknowledging that practically all food is processed to some degree, the authors argued that foods in Group 4 (UPFs) are typically nutritionally unbalanced and liable to be over-consumed to the point of displacing foods from the other three groups. They attributed this to convenience and attractiveness of UPFs, and aggressive marketing—among the reasons why UPFs account for more than half of the dietary energy consumed in high-income countries. Although Nova’s intent was to create a research-based framework for dietary guidance, it can read as condemnation—even of some nutrient-rich foods.
As a food scientist—and dairy food scientist in particular—it is troubling to see nutrient-dense foods that often contain dairy listed among maligned UPFs (e.g., energy bars and drinks, milk drinks, fruit yogurts, ice cream, instant soups and sauces, infant formulas, meal replacement shakes and powders (Monteiro et al. 2019)).
The authors argued that processes and ingredients used to manufacture UFPs are designed to create “highly profitable products (low-cost ingredients, long shelf-life, emphatic branding), convenient (ready-to-consume) hyper-palatable products liable to displace freshly prepared dishes and meals” made from Nova Groups 1, 2, and 3.
There is no doubt that what we put into our bodies matters—potentially as much as how much we put into our bodies. However, to state that UPFs should be limited, and to so broadly include nutrient-dense foods like fruit yogurt and infant formula in that group risks serious public health misdirection. While high sugar intake is indeed associated with negative health outcomes[6], multiple controlled studies and meta-analyses demonstrate the benefits of dairy intake—including processed and full-fat dairy—across diverse populations, ages and health statuses[7],[8],[9],[10]. Broadly labeling such foods as ultra-processed risks equating indulgent or nutrient-poor foods to scientifically formulated, nutrient-rich foods that support growth, recovery and wellness.
In July, 2025, the U.S. Food and Drug Administration, U.S. Department of Health and Human Services, and the U.S. Department of Agriculture issued a request for information on “Ultra-Processed Foods. The comment period, extended in September, 2025[11], closed on October 23. Data and information to help “develop a uniform definition” of UPFs was requested in order to create a uniform definition for “consistency in research and policy to pave the way for addressing health concerns associated with the consumption of UPFs.”. As a part-time staff member of the American Dairy Products Institute, I contributed to a response in defense of seemingly ultra-processed dairy foods and ingredients that, while technically UPFs, provide up to 13 essential nutrients that are critical to health. As regulators consider thousands of public comments, I hope that balanced, evidence-based perspectives prevail in the effort to define ultra-processed, develop policy, and communicate the true value of nutrient-dense foods to consumers.
[1] The Twelfth Edition of Merriam-Webster’s Collegiate Dictionary is to be released on November 18th, 2025.
[2]The term ultra-processed was added to the Eleventh Edition of Merriam-Webster’s Collegiate Dictionary in October, 2024.
[3]The term ultra-processed was added to the Second Edition of the Oxford English Dictionary in March, 2024 update.
[4]Monteiro, C.A., Cannon, G., Lawrence, M., Costa Louzada, M.L. and Pereira Machado, P. 2019. Ultra-processed foods, diet quality, and health using the NOVA classification system. Rome, FAO.
[5]Monteiro, C.A.. “Nutrition and Health. The issue is not food, nor nutrients, so much as processing. Public Health Nutrition. 12: 729-731.
[6]Huang et al. 2023. BMJ. https://doi.org/10.1136/bmj-2022-071609.
[7]Gaeini et al. 2022. Nutr. https://doi.org/10.1093/advances/nmac071.
[8]Shi et al. 2021. J Acad Nutr Diet. doi:10.1016/j.jand.2021.02.029
[9]Otto et al. 2013. JAMA. DOI: 10.1161/JAHA.113.000092.
[10]Mitri et al. 2020. Am J Clin Nutr. Effect of dairy consumption and its fat content on glycemic control and cardiovascular disease risk factors in patients with type 2 diabetes: a randomized controlled study. 112:293-302.
[11]Accessible at: https://www.federalregister.gov/documents/2025/09/19/2025-18169/ultra-processed-foods-request-for-information-extension-of-comment-period.
