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WHO's Draft Food Profiling Model Would Flag Packaged Foods for Taxes, Labels and Marketing Limits as Industry Objects

A draft the agency opened for comment this week sets sugar, salt and fat criteria plus a flag for flavours, colours and sweeteners, giving governments one yardstick for regulating packaged food.

Outspoken Digest Nutrition Desk

Friday, November 6, 2026/2 min read

The long glass and concrete slab of the World Health Organization headquarters in Geneva rising above a car park under a blue sky, photographed on 18 October 2020, a file photograph of the building and not of the consultation
Photo: Guilhem Vellut from Annecy, France via Wikimedia Commons (CC BY 2.0)

Every country that wants to tax a fizzy drink, warn on a cereal box or keep a biscuit advert away from children has to answer the same awkward question first: which foods count? On 2 November the World Health Organization put a draft answer out for public comment, and within days the people who would be regulated were already objecting.

The document is the draft Integrated Food Profiling Model for Regulatory Measures. WHO's consultation page says it consolidates the agency's nutrient recommendations, regional profile models, sodium benchmarks and trans-fat guidance into one approach, and that comments close at 23:59 CET on Friday 27 November.

What does the WHO food profiling model actually do?

It identifies industrially produced, pre-packaged foods that should be eaten in moderation, so that governments can apply measures such as marketing restrictions, front-of-pack labelling, taxes and rules for public procurement. A product is captured if it exceeds one or more nutrient criteria, set for saturated fat, trans fat, sugars and sodium, or if it contains one or more specified ingredients: flavours, colours and sweeteners used mainly for sensory purposes.

WHO says including those ingredients does not mean they are unsafe. The point, it says, is to find products designed to increase appeal and consumption. The draft also states that a profiling model does not by itself constitute a regulatory instrument, so each government would decide whether and how to use it.

How does it define ultra-processed food?

According to a National Law Review summary, the draft glossary describes ultra-processed food as industrially formulated products made mainly from refined food-derived substances, often with cosmetic additives and little or no intact whole food, and notes that most research on the subject uses the Nova group 4 classification. The definition sits in the glossary rather than in the criteria that decide which products are flagged.

The Center Square, in a report updated on Thursday evening, says the draft flags added sugars above 5 percent of calories in drinks or 10 percent in foods, and that artificial sweeteners do not exempt a product. This desk has not been able to verify those thresholds against the draft itself, so treat them as that outlet's reading.

Who is objecting and why?

Ross Marchand of the Taxpayers Protection Alliance called the approach a recipe for soaring regulatory and litigation costs that shoppers would pay at the till. The International Food and Beverage Alliance warned that penalising products for using certain ingredients risks discouraging the improvements WHO and governments have encouraged, such as cutting sugar, salt and unhealthy fats.

The argument will turn on whether a rule based on ingredients rather than nutrients helps shoppers or merely punishes reformulation. The same debate is live in Washington, where the FDA and USDA sent their own proposed definition of ultra-processed food for final review in August and, according to the same report, it is still pending.

This is reporting, not dietary or medical advice. Decisions about what you eat, particularly with a medical condition, belong with a clinician or dietitian who knows your history. The consultation is open to anyone, through WHO's online form with a signed declaration of interest, and the final model will follow once comments are weighed.

Published in The Outspoken Digest

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Outspoken Digest Nutrition Desk

Diet, food science and the evidence behind claims about what we eat.

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