Mrągowo, 28 April 2026
IIPM Position Paper on Introducing Food Classification Systems Based on Degree of Processing
The Dairy Industry Innovation Institute (Instytut Innowacji Przemysłu Mleczarskiego Sp. z o.o.) expresses a critical stance, aligned with the position of the International Dairy Federation (FIL/IDF), regarding the application of the NOVA food classification system. In the Institute's assessment, this system is an overly simplistic tool that depreciates the genuine nutritional and health value of dairy products.
We agree with the FIL/IDF position that "linking food processing to health outcomes is an oversimplified and potentially misleading approach for consumers."
Researchers and international organizations are devoting increasing attention to the production, labeling, and marketing of ultra-processed foods (UPF). Recent reports (late 2025 / early 2026) indicate a hardening stance among certain stakeholders toward UPF, linking its consumption to serious health hazards, including obesity, cardiovascular disease, and fertility issues. The most widely known ranking system is NOVA [1], which is applied by scientists and stakeholders to evaluate diet quality based on products grouped according to their level of processing. However, this system relies on vague, scientifically unsubstantiated, and arbitrary criteria for categorizing foods into different processing categories.
The International Dairy Federation is concerned by the growing efforts of certain policymakers and international organizations to implement policies aimed at classifying food and/or discouraging its production or consumption based on the degree of processing.
While proponents of NOVA argue that such an approach can improve population health, FIL/IDF emphasizes that attributing inherent health superiority to less-processed foods is an oversimplification not supported by robust scientific evidence. Similar concerns are voiced by other nutrition experts [2], pointing out that implementing policies based exclusively on food processing degree may mislead consumers regarding the actual nutritional value of products, thereby adversely affecting their dietary choices.
Dairy products have been shown to form an integral part of a healthy diet, providing key sources of numerous essential nutrients and supporting a wide range of documented positive health outcomes [3]. Nonetheless, numerous dairy items, including cheeses and fruit yogurts, are classified under NOVA as processed or ultra-processed foods whose consumption is recommended to be restricted [3]. In many instances, national dietary guidelines designate these very products as vital sources of nutrients of public health concern. For example, whey proteins are widely used to enhance the nutritional profile of food products. Yet a paradox arises: many products formulated with them are classified by NOVA as ultra-processed foods to be limited. This occurs despite the fact that such ingredients are produced through standard physical processes (such as filtration and drying) and derive from valuable co-products (whey and buttermilk), thereby further contributing to the reduction of food waste.
In the face of mounting pressure to implement regulations targeting processed food and UPFs, policymakers should critically examine the limitations of processing-based classification systems beforehand. Particular attention should be paid to the tendency of such ranking schemes to mislead consumers about the healthfulness of certain products, including dairy foods. Ranking systems such as NOVA overlook the following aspects [1]:
- evidence-based dietary guidelines that encourage the consumption of dairy products and ingredients [4];
- the fortification of commonly consumed staple foods to improve public health outcomes (e.g., enriching rice gruels with high-quality protein, especially in regions with protein deficiencies);
- the complex interactions of nutrients and bioactive compounds within whole foods (the dairy food matrix);
- the positive contribution of formulation and approved additives to ensuring safety, nutritional adequacy, quality preservation, and extended shelf-life;
- the significance of reducing food losses and waste in the context of environmental sustainability;
- the use of ingredients, additives, and processes ensuring microbiological safety throughout product shelf-life, especially in regions lacking reliable cold chains;
- economic affordability;
- the imperative of nourishing a growing global population [1,2];
We endorse the FIL/IDF position and support dietary guidelines and policies that yield genuine public health benefits and empower consumers to achieve a balanced diet through informed dietary choices aligned with national and international recommendations. A holistic perspective is essential, rather than narrowing food evaluation strictly to the degree of processing while disregarding its inherent nutritional benefits.
Dairy products are recognized globally as an integral part of a healthy diet and a vital source of essential nutrients. Any oversimplified and scientifically unfounded approach to dietary guidance or food classification focusing on "degree of processing" is likely to cause the avoidance or exclusion of nutrient-dense, beneficial foods and ingredients. This applies to many dairy items classified under systems like NOVA as processed or ultra-processed [5]. Examples include: protein-enriched dairy beverages, certain fermented milks such as fruit yogurts, kefir, and doogh, cheeses, as well as nourishing and bioactive milk-derived ingredients produced through processing, such as casein, whey proteins, lactose, and lactoferrin.
In conclusion, dairy foods are widely recognized by both experts and consumers as valuable, affordable, and safe nutrition. They demonstrate long-term positive effects on human health, regardless of processing level. Discouraging the consumption of foods based on the NOVA scope of "processing" represents an arbitrary, scientifically unsubstantiated, and often contradictory approach, unsuitable for nutritional policy-making and detrimental to consumer dietary choices. Accordingly, in line with FIL/IDF, we strongly oppose the adoption of the NOVA classification system. Dietary guidelines, national policies, and international food standards must be grounded in solid scientific evidence evaluating actual health impacts.
References:
[1] The NOVA classification system classifies foods into categories based on a number of
ingredients, type of processing and use of (some) food additives.
[2] Jones, J. Food processing: Criteria for dietary guidance and public health? (2019). Proceedings of the Nutrition Society, 78(1), 4-18.; Gibney, MJ. Ultra-Processed Foods: Definitions and Policy Issues (2019), Curr Dev Nutr. 3(2).
[3] Milk and dairy foods are well-known for being naturally nutrient rich, providing an abundant supply of in particular high-quality protein, calcium, phosphorus, potassium, iodine, and vitamins B2 and B12. The unique package of essential nutrients contained within dairy products contributes to the prevention of all forms of malnutrition. A growing evidence base supports no or an inverse association between the intake of dairy products and the incidence of obesity, type 2 diabetes, stroke, certain cancers and cardiovascular disease.
[4] FAO database shows 83 countries including dairy recommendations in their dietary guidelines: http://www.fao.org/nutrition/education/food-dietary-guidelines/home/en/
[5] Jones, Julie Miller. “Food processing: criteria for dietary guidance and public health?” (2018) Proceedings of the Nutrition Society 78 :4 – 18.
