ISDI comments on the WHO Guideline Development for so-called “ultra-processed foods”
ISDI responded to the call for comments on the provisional ‘WHO Guideline Development Group for ultra-processed foods’. Read them in full below.
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The International Special Dietary Foods Industries (ISDI) would like to thank WHO for the opportunity to comment on the current status of the Guideline Development Group for so-called “ultra-processed foods”. As the leading international association representing foods for special dietary uses, we would like to draw the WHO’s attention to this matter.
Ensuring Balanced and Diversified Expertise within the WHO Expert Group
The intention of WHO is to develop a “more objective, operational definition of ultra-processed foods than is currently used, which will provide regulators and policy-makers with an intuitive, streamlined method of assessing whether individual foods are UPF or not.[1]”
The concept of degree of food processing extends beyond diet and nutrition and requires a holistic perspective. Developing an objective, operational definition that is practical for regulatory use calls for diverse expertise. From our perspective, it is important that the expert group includes broader representation in key disciplines such as food science and technology, food processing, social and consumer science, food toxicology and food safety. These areas are critical to understanding how processing contributes to nutritional quality, safety, sensory, accessibility and suitability for different population needs.
In addition, we respectfully suggest that WHO consider including experts from national competent authorities and their independent scientific advisory bodies—such as France’s ANSES, the US Dietary Guidelines Advisory Committee, the UK SACN, Germany’s BfR and Spain’s AESAN—that have established work on the concept of so called “ultra-processed foods” and other relevant fields to enrich the discussion and ensure recommendations are comprehensive and balanced.
Promoting Transparency and Inclusivity in the Process
ISDI values transparency in expert selection and encourages clarity regarding the criteria used for appointments. We note that the current group appears to share similar perspectives on the topic, which may limit the diversity of scientific viewpoints. A wider range of perspectives would foster constructive dialogue and strengthen the robustness of the guidelines and the objectivity of the proposed definition.
We also recognise that conflicts of interest can extend beyond financial ties to include intellectual positions shaped by prior academic or professional engagement. Addressing these considerations will help maintain trust and credibility in the process.
Recognising Role of Processing in Meeting Nutritional and Safety Needs
Processing plays an essential role in producing foods that meet specific dietary requirements and ensure food safety. Foods for special dietary uses, as defined by Codex Alimentarius[2], are specially processed or formulated to address particular physiological conditions or health needs. For vulnerable groups such as infants, young children and patients, processing is indispensable for safety and nutritional adequacy. Without processing, companies wouldn’t be able to provide specialised nutrition products.
Moreover, processing enables public health interventions such as fortification to combat micronutrient deficiencies[3] and supports initiatives like the removal of industrial trans fats[4]. These examples illustrate that processing can be a positive tool for improving health outcomes.
We caution that creating overly broad definitions of so-called “ultra-processed foods” could inadvertently restrict access to safe, nutritionally necessary foods, in particular for vulnerable populations. We recommend WHO conduct an impact assessment to evaluate potential unintended consequences when developing its guidelines.
Conclusion
ISDI encourages WHO to adopt an inclusive, evidence-based approach that reflects the full spectrum of scientific knowledge. By integrating diverse expertise and perspectives, the guidelines can better serve global health objectives and remain relevant to all population groups.
[1] See CX/CAC 25/48/15 Matters arising from WHO and FAO (link)
[2] CXS 146-1986 General Standard for the Labelling of and Claims for Prepackaged Foods for Special Dietary Uses
[3] See Vit D as an example – WHO guideline on fortification of edible oils and fats with vitamins A and D for public health