WHO Draft Food Profiling Model Would Flag Added Colors, Flavors and Sweeteners, Natural Ones Included

The World Health Organization (WHO) has released a draft model that would flag packaged foods for regulation if they exceed limits on fat, sugars or sodium, or if they contain added colors, flavors or sweeteners. The draft was published Nov. 2. Public comments close Nov. 27, 2026.

TLDR

• The draft is titled “Integrated food profiling model for regulatory measures.” It identifies “industrially produced, pre-packaged foods to be consumed in moderation.”
• A product is flagged if it exceeds one nutrient limit or contains one specified color, flavor or sweetener. It can be flagged on ingredients alone.
• The draft’s ingredient rules cover color extracts such as spirulina extract, turmeric extract and paprika oleoresin, not only synthetic dyes.
• In WHO’s analysis of about 1.5 million products, the combined criteria captured 97.27% of the nutrient-validated ultra-processed foods in the data set.

How the Model Works

The model has two parts. The first sets limits for saturated fat, trans fat, sugars and sodium. The second looks for ingredients that WHO says are used mainly for sensory purposes: flavors, colors and sweeteners.

A product that meets one or more criteria in either part is identified as a food to be consumed in moderation. A product with low sugar and sodium can still be flagged if its ingredient list includes a specified color, flavor or sweetener.

WHO writes that including these ingredients does not mean they are unsafe. It says they help identify products formulated to increase appeal and consumption, and that the criteria are separate from food additive safety reviews.

Natural Colors and Flavors Count

An appendix to the draft sets out how ingredient lists are read. Its color rule flags any color additive by Codex or European Union name or number, the FD&C dye family, and any ingredient described as a color, dye or pigment.

Plant and algae color extracts are covered by name. Spirulina extract, phycocyanin, turmeric extract, curcumin, paprika oleoresin and saffron extract all trigger the rule. Plain turmeric, paprika or spirulina powder used as a food or spice does not. Carotenes and plain caramel trigger the rule by default.

The flavor rule flags any ingredient described as a flavor, flavoring, aroma or essence, and vanillin in all forms, including natural vanillin. Real vanilla and vanilla extract are not flagged.

The Data Behind It

WHO tested the model on 1,503,075 food and beverage products sold in 84 countries and territories, drawn from the Mintel product database. Among 769,863 products classified as ultra-processed under the Nova system and checked for valid nutrition data, the nutrient limits plus the color, flavor and sweetener rules captured 97.27%. The share ranged from 95.59% to 98.30% across WHO regions.

Nova is a four-group food classification system. Its group 4 is the category most research uses to define ultra-processed food. WHO says its model does not classify foods by processing and does not decide whether a single product is “healthy” or “unhealthy.” The draft calls the two approaches complementary and the analyses preliminary.

Why It Matters

The draft is not a regulation. WHO says countries can adapt it for marketing restrictions, front-of-package warnings, taxes and public food purchasing. It says countries may need to update labeling rules so that added sugars and trans fat are declared, since most labels do not list them separately.

Under the draft, a color’s source would not change the result. A product colored with spirulina extract would be flagged the same way as one colored with a synthetic dye. WHO is asking for comments on the model’s clarity, its practicality and any missing evidence by Nov. 27.

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Sources: WHO draft, Integrated food profiling model for regulatory measures (Nov. 2, 2026); WHO public consultation page; Food Safety Magazine; National Law Review (Bergeson & Campbell).