WASHINGTON — As the nomination window closed for appointments to the 2025 Dietary Guidelines Advisory Committee, the American Bakers Association collaborated with the Food and Beverage Issue Alliance and the Grain Chain to formally express concerns related to grain-based foods. On July 15, the ABA submitted its recommendations for the DGAC in letters to the US Department of Agriculture and the US Department of Health and Human Services.

In its letter under the auspices of the FBIA, the ABA said the 2025-2030 Dietary Guidelines for Americans includes a question regarding “ultra-processed foods” that would require expertise to address.

“In fact, the National Academies of Sciences, Engineering, and Medicine reports on the 2015 and 2020 DGA processes identified the need to have the right mix of credentialed experts in the areas relative to all the questions the DGAC is charged to address,” the ABA said.

The ABA requested each representative appointed to the DGAC be an expert with a well-known record of distinguished service in nutrition, research, health, or food science and technology.

“Our organizations strongly recommend that there be at least two food scientists with robust understanding of the science and engineering behind how food is formulated, manufactured, packaged, and stored included on the 2025 DGAC,” the letter said.

“As recommended in NASEM’s 2017 report on the DGA review process, DGAC members should be diverse, not only regarding gender, ethnic and cultural diversity, but also a diversity of perspectives,” the ABA said. “Further, during the analysis of scientific evidence, additional experts should also be brought in to inform the committee on the questions/topics posed, including technical experts with food manufacturing, processing, and packaging experience, as well as scientific and regulatory affairs and expertise in food marketing for the general population.”

The ABA warned that if the proper relevant expertise is not adequately represented among the members of the 2025 DGAC, “then a comprehensive evidence-based assessment for this question would be hampered. This could result in recommendations regarding ‘processed’ or ‘ultra-processed’ foods that do not reflect the preponderance of scientific evidence.”

Objecting to recent suggestions that any potential tie to the food and agriculture industry would create an overwhelming conflict for potential committee members, the ABA said, “Our organizations believe that those experts who are appointed to the DGAC can and will be objective in their review and assessment of the scientific evidence, and therefore should not be barred from participation on the DGAC if their expertise would be critical for the development of practical and achievable recommendations.”

In a separate letter from the Grain Chain, a grains industry coalition representing farmers, millers, grain processors, and end users, the ABA provided further recommendations for the upcoming White House Conference on Hunger, Nutrition, and Health. In the Grain Chain letter, the ABA endorsed comments from the FBIA and provided its grain-industry specific input “to emphasize grain foods’ critical role in a healthful diet, both in the United State and globally.”

The ABA urged the White House Conference to use “strong, evidence-based criteria to create recommendations that are consistent with existing federal nutrition policy rules.” The letter urged conference planners to clearly define terminology for food descriptors, including “nutrient-dense,” “non-dairy,” “non-meat alternatives,” “ultra-processed,” “processed” and “minimally processed.”

“Definitions must be data-driven and evidence-based with clear consensus around the scientific evidence,” the ABA said. “As grain producers, processors, and food makers that provide some of the most widely eaten and universally enjoyed staples in the American diet — whole (grain) and enriched bread, crackers, cereal, pasta, tortillas, and rice — we stand ready to work with government and industry to identify steps toward a healthier America and, most importantly, put those steps into concrete action.”

Every five years, the USDA and HHS publish Dietary Guidelines for Americans. The 2025 DGAC will review scientific evidence on topics and questions identified by the Department and provide a report on its findings. The committee’s report, along with public agency comments, will help inform the USDA and HHS’s development of the 2025-2030 Dietary Guidelines for Americans.