Ultra-Processed Foods Definition Elusive

What, exactly, is an ultra-processed food? Proposals about, and FDA may be weighing in. But figuring out what a definition should and shouldn’t cover is a difficult task, said Chad Galer, vice president of product innovation and food safety for Dairy Management, Inc.

“I think it's a risk that it might be a bit oversimplified,” said Galer, who worked for 16 years at Kraft Foods before joining DMI. “It should be more of a matrixed approach where you are balancing the nutrition and the processing.”

Galer discusses some of the health benefits of dairy products that can be affected by differing ultra-processed definitions, including flavored yogurt and cheese.

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Alan Bjerga: Hello and welcome to the Dairy Defined Podcast. Ultra-processed foods, everybody's heard of them, but what are they? Chad Galer is Vice President of Product Innovation and Food Safety for Dairy Management Inc. And he's going to try to help answer that question for us today. Chad has spent his entire life in the dairy industry growing up on a Wisconsin farm and graduating from the University of Wisconsin-La Crosse before spending 16 years working at Kraft Foods where he worked a lot with cheese, which is an interesting case as the UPF debate evolves, by the way. Galer has been an invited judge for the world and US Cheese Championships and he coordinates the National Collegiate Dairy Product Evaluation Contest. Welcome to the podcast, Chad.

Chad Galer: Thanks, Alan.

Alan Bjerga: Starting with the lay of the land. Now, we're hearing that Health and Human Services Secretary Robert F. Kennedy Jr. is talking about a definition of ultra-processed foods. What is he generally talking about when that term is used and why should the public care?

Chad Galer: Yeah, at a high level, he's trying to define what foods are more highly processed, maybe more highly formulated, and trying to give a simpler approach for consumers to know what foods to select. There is research that when people are consuming too much of this food, it might become unhealthy and lead to some chronic diseases that we could prevent just by what they're eating. But I think it's a risk that it might be a bit oversimplified.

Alan Bjerga: There have been attempts at defining ultra-processed foods at the state level, usually revolving around ingredients or classification systems. Could you explain some of the approaches?

Chad Galer: Yeah, many states are trying to pass bills focused on removing ultra-processed foods and this actually targets school meal programs, a lot of times they're SNAP benefits. And this can be concerning because then we may limit what is available when you think about nutrient dense. But the other concern with the state level and specific ingredients is that now you're going to have a patchwork for companies to try to make foods that meet all of these different attributes that they're laying out. So that becomes very difficult when you think about a supply chain, reformulation or how they're going to do it. It likely could drive up food costs or decrease consumer availability of these different foods, like, dairy depending on how those are implemented.

Alan Bjerga: And where does dairy fit into all of this?

Chad Galer: Dairy, it's at kind of the center of it being a complex issue because some things are obviously minimally processed like milk, just heating it up to make it safe. But yogurt, you're doing the same thing, you're heating that milk up, you're just adding a culture and making a gelled milk, really, for consumers to enjoy and still get that nutrient density. But in this case, especially if you start adding things that consumers like, like, flavors or fruit preps or different things, this could tip it into some of the higher levels of these ultra-processed foods. So now you're looking at a very nutrient dense food that's very minimally processed but is going to get that tag. So it could start to have that halo effect. Another interesting example is whey protein, right. We think of that as a very nutritious food. A lot of people are eating it. It's simply removing water from the byproduct of cheese making.

And once that water is removed because it takes several steps, this could very likely be a ultra-high processed food, which we know is one of the highest quality proteins, is super nutritious for people. So there's definitely concerns for dairy with some of what we feel are very natural simple foods that could have these tags associated with them.

Alan Bjerga: So let's drill down into that a little bit further. For example, you will hear a lot in these discussions of what makes something ultra-processed or not. You hear a lot about stabilizers and emulsifiers. Can you explain what these are used for and why they're helpful and not harmful?

Chad Galer: From a standpoint of allowability, they're well allowed in foods. They've been around for a long time and they're used to really stable, as the name implies, stabilize the food in the case of emulsifiers, help things that don't typically mix, like, oil and water blend together better and be stable. And stabilizers help carry things or get a better texture and don't allow for water separation during that. Because when you start to have some of those things happening, these separations, now you're changing the moisture in the food, which could shorten the shelf life or even lead to some concerns with the safety of the food. So that's why we want to use these types of things. A great example is processed cheese has emulsifiers in it to get that smooth texture. It allows it to melt. It's been an important food for well over a hundred years that people have been consuming and we don't see a lot of safety concerns with a lot of these, used in the right level and used judiciously.

A lot of the stabilizers are actually natural products from plant and plant fibers. So the concerns with these, I like to think of it as, if you want to make some of the best mac and cheese in your kitchen, you're probably going to warm up some butter and flour. That flour is actually acting as a stabilizer, a very natural product that you're getting to hydrate with the rest of the butter and cream and then carry the cheese so the oil doesn't separate off. It's that, but with a more defined process as they go through that.

Alan Bjerga: Sure. You hear about cheese. You also hear about flavored milk. Why wouldn't that have a stabilizer?

Chad Galer: Yeah, that's a great example because in flavored milk, you're adding some sugar, which we've greatly reduced over the years, the amount of sugar in those. And we're also adding some stabilizer because of the cocoa or the fruit flavor in there. We don't want that to settle in the bottom and if someone forgets to shake it, they drink it and they say, this doesn't taste very good. And then it tastes very strong at the end, right. So by having a stabilizer in there: one, it looks more appealing; and two, that product and those flavors are just going to be more consistent as consumers enjoy them. So stabilizer systems in there are very important to the overall ... Consumers don't like it without it. We have the research on that as well. So very simply put, consumers don't enjoy it without, and they have expectations of the product with the stabilizers in it.

Alan Bjerga: It seems, Chad, like, one of the challenges with this whole discussion of ultra-processed foods is that there's a broad consensus that people know that there's heavily processed junk food out there and nobody has wanted to feed their kids Ding Dongs for lunch since 1982, but you have challenges with developing what the net should catch and what shouldn't catch. And it seems like one of the challenges is weighing the processing versus the nutritional value. And that would seem to be a real challenge with a nutrient dense category like dairy. For example, what is some of the challenges about balancing processing versus nutritional value in flavored yogurt?

Alan Bjerga: Yeah, great question. And I think what's happened is, to help consumers make better choices with good intentions, these labels are coming out, right. And so it's very focused on processing right now and the number of steps or the number of ingredients and it's not taking nutrition into account. So enough, I think, my personal opinion is it should be more of a matrixed approach where you are balancing the nutrition and the processing. I mentioned the whey example already, and then yogurt is another good one and I talked about that a little bit, but especially as you get into some of the flavored yogurts, we know ... We have mountains of research on the benefits of yogurt to the health, to gut health and other things, but yogurt with any added flavors, ingredients or sugar would more than likely be an ultra-processed food. And then it would not be available for students in some of the meal programs. It may not be available to SNAP and consumers might not enjoy it as much or as often. So now we're taking a nutrient-dense product out of their hands, unfortunately.

Alan Bjerga: So if the concern is that a healthy product gets lumped in with the ultra-processed foods, if the government just came up with a definition, you can categorize a food as healthy, could you just take all the dairy products that are healthy and say, "Hey, you are not going to have to be under this ultra-processed definition if it's healthy." Would that create any issues?

Chad Galer: That's pretty nuanced. I think it would start to segregate dairy products, right, based on the ones that over the years consumers say that they said they want, they appreciate dairy for a lot of different attributes of it. It might be hard to then enjoy some of your ice cream, right, if we're looking at a healthy halo. So it would still be challenging for dairy, it might help, but I think there'd be a lot of different products and you'd have to look at it within the same category, like we just spoke about yogurt. Some yogurts would be good and some might not be. And we know that the majority of yogurts are healthy and a good source of protein and other nutrients. So that would be very limiting for the dairy industry if that happened as it's being stated now.

Alan Bjerga: So let's say whatever it says, a UPF definition comes into place and that is a label that is now applied to certain foods. When that happens, a common industry response is reformulation. You try to get out of that definition. To what extent are food manufacturers likely to reformulate products to avoid a UPF label and where are those changes potentially impractical from a technical or economic standpoint?

Chad Galer: Yeah, I think a lot of companies will try to reformulate. They're probably going to be limited about the processing they can do, but they'll try to reformulate these to get rid of that because right now our assumption is ultra-process is going to be associated with bad, right, and bad for you, which isn't always true. So I think we'll have to continue to communicate to consumers about dairy's benefits despite what some of these labels are, which is what we do a lot of. And then when you think about that reformulation, they will, but they will be limited depending on what's in and out with that. It will also increase potential supply chain issues. And in these reformulations, most of the time what they're doing is that's what consumers are used to. So to match that and keep that consumer demand up, it might drive the cost up 'cause they're having to go to more expensive ingredients.

So again, we're looking at cost to the consumers based on the supply chain complexities and/or ingredient use is limited. Some might just stop making these products, not only reformulate, but they might just say, "You know what, we don't want products in our portfolio with ultra-processed foods on them, so we're just going to prune these out so we're going to have limited availability for consumers in some cases." And this is not what we want our food supply chain to look like. We want to use technology to make the most nutritious, delicious, healthy dairy products we can for consumers.

Alan Bjerga: It seems like consumer perception is the issue here. A perception where ultra-processed equals unhealthy. Getting away from the technical specifics of a definition, how should the dairy industry respond to that narrative? Does a food being ultra-processed necessarily make it unhealthy?

Chad Galer: The intentions of having these labels does simplify it for consumers, but unfortunately I think we're oversimplifying the approach and not taking in this matrixed approach, as I thought about, where you're balancing processing an ingredient line length with nutrition and health benefits. And then when you start thinking about really highly nutritious foods that are associated with fitness and other things, like whey protein, that's very limiting. So I think we're going to have to continue to advocate for, you know, that dairy is different. Dairy carries these nutritional benefits and that all processing and all formulation isn't bad. To enjoy foods the way you come to be used to them. We're going to have to continue to tell that story of dairy and how simple these processes are. Really, if you think about it, most of our dairy products, when you get beyond milk, originated from trying to make them last longer through fermentation, through concentration, and that's really still the technologies we're using and unfortunately they're falling under this ultra-processed foods halo.

Alan Bjerga: We've been speaking with Chad Galer, an expert on food innovation and food safety for Dairy Management, Inc. Chad, anything else you would like to add before we let you go today?

Chad Galer: Yeah, I think as we think about this, this is a challenge for dairy as we go forward, but like many times in dairy, through R&D innovations and technology and farmer research dollars, which I get to work on a lot, I think will rise to the challenge and it'll be a combination of these technologies, reformulations, but also our strong advocacy where we all work together to really tell the true story of what's going on. And thankfully, consumers already see dairy as a very nutritious, enjoyable, and delicious product that they can enjoy with almost guilt-free pleasure most of the time. So I think we should just ... The future's still bright and it's another challenge we'll have to face.

Alan Bjerga: Chad, thank you for joining us.

Chad Galer: Thank you, Alan.

Alan Bjerga: For more of the Dairy Defined Podcast, all you have to do is go to our website or go to Apple Podcasts, Spotify, and Amazon Music. Search under the podcast name, Dairy Defined. We'll talk again soon.