Food Regulatory Science Update • Preliminary Assessment of the WHO Integrated Nutrient and Food Profiling Model for Regulatory Purposes

Executive Summary

After a considerable period of anticipation, the World Health Organization (WHO) has introduced its proposed Integrated Nutrient and Food Profiling Model during the 45th Session of the Codex Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU), on 2 November 2026, launching a public consultation on an approach intended to support regulatory interventions aimed at preventing obesity and diet-related non-communicable diseases (NCDs).

While addressing legitimate public health concerns, the proposed approach raises important questions regarding its scientific foundations and regulatory justification.

The principal concern is the apparent absence of an explicit risk analysis framework, consistent with internationally recognized principles of evidence-based food regulation, including scientific justification, proportionality, and regulatory impact assessment.

Beyond established nutrient criteria, the model introduces additional criteria based on the presence of colours, flavourings, and sweeteners, without clearly demonstrating how these ingredients independently contribute to adverse health outcomes. Furthermore, its validation relies substantially on correspondence with the NOVA classification of ultra-processed foods, rather than independent evidence linking the proposed classifications to health risks.

The intended application of the model to regulatory instruments, potentially including taxation, raises additional concerns regarding proportionality and demonstrated effectiveness. Addressing multifactorial challenges such as obesity and NCDs requires interventions supported by evidence of measurable public health benefits, rather than product classification alone.

This assessment remains preliminary, pending a detailed examination of the WHO consultation document and its supporting scientific evidence. Ultimately, food profiling should inform regulatory decision-making, not substitute for risk analysis, scientific justification, and assessment of regulatory impacts.