Currently browsing posts about: Dietary-Guidelines

The USDA announced last week the arrival of the Scientific Report of the Dietary Guidelines Advisory Committee (DGAC).

The DGAC deserves much praise for getting this job done on time under what I consider to be difficult constraints (large committee size, large areas of research to review, requirement that all recommendations be “evidence-based” which sounds good, but is unreasonable given the inability to conduct long-term controlled clinical studies).

The report is now open for public comment (see information at bottom of post).

The process to develop the Dietary Guidelines for Americans, 2025-2030 is under way. Get involved by providing written and oral comments to the Departments on the Scientific Report of the 2025 Dietary Guidelines Advisory Committee (Scientific Report). You may also sign up to receive email updates on news related to the development of the next edition of the Dietary Guidelines…For more information, visit the Public Comments to the Departments page.

A reminder about the process:  The DGAC report is advisory.  Since 2005, the agencies appoint an entirely separate internal governmental committee to write the actual guidelines.  This, of course, makes the process far more political and subject to lobbying (file comments!).

The recent election will install new leaders of USDA and HHS.  If they follow the same process, they will appoint and instruct the new committee.  Or, they can change the process entirely.

Another reminder: When I was on the DGAC in 1995, our committee chose the research questions, did the research, wrote the scientific report, and wrote the actual guidelines.  Those were the days.

Comments on the DGAC report

For starters, it’s 421 pages.

Its bottom line:

This healthy dietary pattern for individuals ages 2 years and older is: (1) higher in vegetables, fruits, legumes, nuts, whole grains, fish/seafood, and vegetable oils higher in unsaturated fat; and (2) lower in red and processed meats, sugar-sweetened foods and beverages, refined grains, and saturated fat. A healthy dietary pattern, as indicated by the systematic reviews, may also include consumption of fat-free or low-fat dairy and foods lower in sodium, and/or may include plant-based dietary options.

The proposed guidelines:

1. Follow a healthy dietary pattern at every life stage. At every life stage—infancy, toddlerhood, childhood, adolescence, adulthood, pregnancy, lactation, and older adulthood—it is never too early or too late to eat healthfully.
2. Customize and enjoy nutrient-dense food and beverage choices to reflect personal preferences, cultural traditions, and budgetary considerations.
3. Focus on meeting food group needs with nutrient-dense foods and beverages, and stay within calorie limits.
4. Limit foods and beverages higher in added sugars, saturated fat, and sodium, and limit alcoholic beverages.

This looks like all the other Dietary Guidelines since 1980.  Its bottom-line statement is more explicit than previously about reducing red meat and sugar-sweetened beverages.

Worth reading

• Support federal data.  I especially appreciated the strong support for strengthening nutrition monitoring, food composition data (FoodData Central, an invaluable resource), and updating the Dietary Reference Intakes.  Yes!
• The chapter on portion size.  At last!  Larger portions have more calories!

What’s missing

• A separate chapter on calories stated explicitly.  The report discusses concerns about obesity and diet-related chronic disease in an excellent paragraph on page 1, and mentions calories but “stay within calorie limits” doesn’t get at what’s needed.  I want more on “…adults and children [should] consume smaller portions of foods and beverages that are high in energy density and low in nutrient density.”
• A guideline to reduce consumption of ultra-processed foods.  This committee, unwisely in my view, chose not to advise minimizing intake of ultra-processed foods, deeming their definition too uncertain and ignoring what are now three controlled clinical trials demonstrating that diets based on these food induce people to overconsume calories.

What’s confusing

–The addition of recommendations for diets in early childhood.  This was done for the 2020-2025 guidelines and it involved doubling the size of the committee. This makes the committee’s work much harder and its report insufferably long.  I would rather see a separate report on children (this could deal with the effects of food marketing as well).

–The health equity lens.  I’m all for this but its discussion dominates the report.  It is discussed in a separate chapter but then in boxes and other places throughout.  The word “equity” is mentioned 217 times and “health equity lens” 38 times.

Although prior Committees incorporated basic demographic factors such as age, race, and ethnicity into their reviews of the science, this Committee considered additional factors and did so in a holistic manner as it reviewed, interpreted, and synthesized evidence across data analysis, systematic reviews, and food pattern modeling. In particular, this Committee considered factors that reflect social determinants of health (SDOH). In doing so, the Committee could interpret the evidence based on both demographic factors (which are considered to be downstream, i.e., more proximal in terms of their influence on behavior) and socioeconomic and political factors (which are considered to be upstream, i.e., broader societal factors that influence the distribution of power and resources). Addressing SDOH is considered key to achieving a just, equitable society.

Other comments

From the Meat Institute:  Meat Institute Issues Statement on the Scientific Report of the 2025 Dietary Guidelines Advisory Committee

“The Meat Institute remains strongly opposed to the Report’s recommendation to reduce meat consumption and will urge the agencies to reject it,” said Meat Institute President and CEO Julie Anna Potts.

From the Physicians Committee for Responsible Medicine: Prioritizing Plant-Based Protein in the Scientific Report of the 2025-2030 Dietary Guidelines for Americans Committee is a Step Forward, Doctors Say

For the first time, the advisory committee tasked with making scientific recommendations for revising the Dietary Guidelines for Americans recommended that the 2025-2030 Dietary Guidelines “include more nutrient-dense plant-based meal and dietary recommendation options,” prioritize plant-based protein over animal protein, and recognize the many benefits of beans, peas, and lentils as a protein source. The Dietary Guidelines Advisory Committee (DGAC) continued to discourage consuming foods like red meat, eggs, and dairy that are high in saturated fat, while also suggesting that the next Dietary Guidelines for Americans specifically recommend plain drinking water as the primary beverage for people to consume.

I can’t wait to see what comes next.

How to commennt

A 60-day public comment period on the Committee’s Scientific Report is open through February 10, 2025. More information about how to provide written and oral comments to the Departments is available at DietaryGuidelines.gov.

• Read about opportunities to provide public comments, including requirements for oral comments 
• Register to provide oral comments to the Departments.   Note: do this now.  Spaces are limited.
• Submit written public comments to the Departments
• Register to attend the virtual public meeting to hear oral comments on the Scientific Report  

Read the Committee’s Scientific Report 

What are healthy diets? Joint statement by the Food and Agriculture Organization of the United Nations and the World Health Organization

What this is about:

Healthy diets promote health, growth and development, support active lifestyles, prevent nutrient deficiencies and excesses, communicable and noncommunicable diseases, foodborne diseases and promote wellbeing. The exact make-up of a diet will vary depending on individual characteristics, preferences and beliefs, cultural context, locally available foods and dietary customs. However, the basic principles of what constitutes healthy diets remain the same.

The guiding principles: Adequate, Balanced, Moderate, Diverse.

Here’s what they mean by Balance:

The actual guidelines are discussed under the Moderate principle.

• Sodium: restrict to 2 grams/d (5 g table salt)
• Sugars: restrict to 10% or less of daily calories.
• Saturated fat: restrict to 10% of calories, with no more than 1% from trans fat

FAO and WHO duck making a clear statement about the next two issues, although their implications are clear.

• Red and processed meat: even low levels may have negative health consequences
• Ultra-processed foods: these have negative health consequences

I wish they had stated these recommendations more clearly.  Yes they are controversial with big industries lobbying against any suggestion to eat less of these foods, but these agencies, or at least WHO, should put public health first.

I recognize that these agencies have constituencies of nearly 200 countries, many with strong meat and ultra-processed food industries.  I also recognize that the agencies have no power other than leadership to get any of those countries to do anything.

They at least stated what they thought.  It’s up to country governments to take action.  I hope they do.

DietaryGuidelines.gov provides handouts on Food Sources of Select Nutrients.

Alas, calories are not among these handouts, even though 75% of American adults are now considered overweight or obese.

These are meant for nutrition professionals but are fun to see if you want to see what they get.

The page lists lots of other resources.

• Download Handouts & SpreadsheetLearn More About Food Sources
• Print materials on the professional resources page 
• MyPlate Quiz
• MyPlate Plan
• MyPlate Kitchen
• Professional food photography

Will these help you make healhier dietary choices?

Nutrients are not the problem; calories are the problem.

To do something about them, we need a healthier food environment.

I wish the USDA would give that as much attention as it gives nutrients.

The 2025-2030 Dietary Guidelines Advisory Committee (DGAC) report is well underway.   The committee either has submitted or is about to submit its report to HHS and USDA;.  The report has not yet been posted, but presumably will be posted soon.

But understand: the scientific advisory committee is just that: advisory.

The agencies, HHS and USDA, are responsible for writing the actual guidelines.  They choose an internal committee to do that work.  That new committee can pick, choose, add, or subtract from the advisory committee’s report.

So yes, the new Secretaries of HHS and USDA can have a lot of input (and veto power) into the new guidelines.

As I’m fond of repeating, the guidelines process was quite different when I was on the DGAC in 1995.  Then, our committee chose the research topics, reviewed the research, wrote the advisory committee report, and wrote the actual dietary guidelines.  The agencies made only minor tweakings.

The agencies have written the guidelines since 2005, making the process much more subject to politics.

The DGAC, for example, viewed the evidence on ultra-processed foods as too limited to take a stand, yet RFK, Jr says ultra-processed foods are killing us.

The development of the 2025-2030 guidelines will be most interesting to watch.  Stay tuned.

Every five years since 1980, we get to go through the most enormous fuss about dietary guidelines that have not changed in any fundamental way since then.

Then and now, they say eat more vegetables, balance calories, and reduce intake of foods high in sugar, salt, and fat.

You don’t believe me?  Here is the much more straightforward 1980 version.

Reminder: The Dietary Guidelines Advisory Committee is just that: advisory.  The agencies will write the actual guidelines.  Until the guidelines actually appear, everything remains speculative.  They are due to appear by the end of 2025.  Between now and then, we have an election to deal with.  No matter who wins, political appointees in the two sponsoring departments will change and could greatly intervene.

I love the Dietary Guidelines.  They are endlessly entertaining examples of food politics in action.

The current Dietary Guidelines Advisory Committee has produced its draft recommendations.  These, as I discuss tomorrow, are mostly banal, much the same as all guidelines since 1980.

But this year there are two rather shocking exceptions, both having to do with what is not recommended.

Incredible non-recommendation #1.  Reduce the focus of the Dietary Guidelines on reduction of chronic disease risk.

What???  The entire purpose of the Dietary Guidelines is to reduce the risk of diet-related disease.  Chronic diseases—obesity, type-2 diabetes, heart disease, cancer, etc—are the leading causes of death and disability among U.S. adults.

Maybe this was a typo?  Surely this committee means to say “Recommend increasing the focus of the Dietary Guidelines on chronic disease risk reduction.

The current wording is a travesty.  I’m not the only one who thinks so.  See Jerry Mande’s Tweet (X).

Update: I gather the uproar over this did some good and the committee is changing the wording.

Incredible non-recommendation #2.  Say nothing about ultra-processed foods.

The committee made it clear that they were not going to say a word about ultra-processed foods.  At least not now.  Why not?

Scientific experts tasked with advising federal officials drafting the 2025-2030 Dietary Guidelines for Americans said the data were far too limited to draw conclusions…Ultra-processed foods don’t have a recognized definition or a robust body of scientific literature that has studied them, they said, so guidelines would be premature.

Another travesty.  An overwhelming body of observational research suggests harm from diets high in ultra-processed foods.  OK, these studies only demonstrate association, not causation.

But—not one, but two well-controlled clinical trials demonstrate that ultra-processed foods induce people to consume more calories than they would otherwise: 500 more in one trial and more than 800 in the second.  These are enormous differences.

Yes, it would be great to know why, exactly.  And yes, the definition of ultra-processed can be fuzzy with respect to a few—remarkably few—foods.

But what more do you need to know?  Isn’t this enough to tell people that if they want to keep caloric intake under control, a good way to do that would be to limit consumption of ultra-processed foods?

But this committee chose to ignore the controlled trials because they didn’t last long enough.

As I explain in that link, the committee’s hands are tied by having to make “science-based” recommendations.  But in nutrition, most of the science is observational, which is why those controlled trials, short in duration as they are, matter so much.

The committee needs to revisit this decision.  If the guidelines do not include a recommendation to limit intake of ultra-processed foods, they will be ignoring the science and will be behind the times.

Worse, the guidelines will not help Americans reduce their risks for chronic disease.

See: Stat News:  5 questions about the next U.S. dietary guidelines, and the ‘impossible restriction’ on them: Difficulty of nutrition research leaves problems like ultra-processed foods largely unaddressed. 

Tomorrow: the banality of the latest recommendations.

Despite all the fuss about the guidelines every five years, they say the same things every time: eat more fruits and vegetables (plant foods), balance calories (good luck with that), and reduce intake of saturated fat, sugars, and salt (euphemisms for ultra-processed foods).

You don’t believe me?  Take a look:

Ancel and Margaret Keys’ 1959 dietary guidelines for prevention of coronary heart disease.*

1. Do not get fat, if you are fat, reduce.
2. Restrict saturated fats, the fats in beef, pork, lamb, sausages, margarine, solid shortenings, fats in dairy products.
3. Prefer vegetable oils to solid fats, but keep total fats under 30% of your diet calories.
4. Favor fresh vegetables, fruits, and non-fat milk products.
5. Avoid heavy use of salt and refined sugar.
6. Good diets do not depend on drugs and fancy preparations.
7. Get plenty of exercise and outdoor recreation.
8. Be sensible about cigarettes, alcohol, excitement, business strain.
9. See your doctor regularly, and do not worry.

*Keys A, Keys M.  Eat Well and Stay Well.  New York: Doubleday & Co, 1959.

The concept of ultra-processed foods encompasses much of this.  We would be better off eating less of them.

It shouldn’t take all this work every five years to come to this conclusion.

So why all the fuss?  I’d call it food politics.

If people ate healthfully, chronic disease prevalence would decline and lots of industries would be out of business: junk food, diet foods, diet drugs, and those profiting from health care.

I don’t like writing about the dietary guidelines process while it is still ongoing because so much can change between now and the time the advisory committee submits its report, and USDA and HHS issue the actual guidelines.

But this Dietary Guidelines Advisory Committee is dealing with the concept of ultra-processed foods and is tied in knots over it.

So I will devote this week to the guidelines.

• Today: Why knots?
• Wednesday: Why isn’t NIH funding more rigorous nutrition research?
• Thursday:  Why all the fuss when guidelines always say the same things?

OK.  Let’s get to it.

Why do I think the Dietary Guidelines Advisory Committee (DGAC) is tied in knots over ultra-processed foods (UPF)?

1. It  is required to make evidence-based recommendations.  This is impossible with observational evidence.
2. It is required to exclude the one existing controlled clinical trial from consideration (because it was too short).

Therefore, it had to conclude: ““Limited evidence suggests that dietary patterns with higher amounts of foods classified as UPF consumed by adults and older adults are associated with greater adiposity (fat mass, waist circumference, BMI) and risk of obesity/overweight. Evidence Grade: Limited.”

The DGAC is in an impossible position, and doing the best it can under the circumstances.

I need to say a word about evidence-based recommendations.  How I wish they could be.   If all you have is observational studies, you need to interpret them carefully.  Interpretation is subject to bias.

When I was a DGAC member (1995 guidelines), the agencies recognized what we were up against.  They instructed us to review the available research and give the best advice we possibly could based on it.

All of this raises a philosophical question: Should government agencies issue advice based on incomplete and inadequately controlled observational research?  Or should they say nothing?

This committee, apparently, is considering saying nothing about ultra-processed foods: “It would be hugely problematic to tell people to avoid 60% of the food supply without having something good to replace it.”

Really?  Plenty of “something good” is available.  It’s called food: fruits, vegetables, grains, meat, fish, dairy, eggs.

These—unprocessed and minimally processred—can be delicious, nutritious, and satisfying, and at reasonable cost.

—–

Tomorrow: Why don’t we have more rigorous research?

Addition:  The video of the meeting.  The discussion of ultra-processed foods starts at 3:51:45 .