WASHINGTON — Pragmatism, rigorous science and affordability are among considerations that should be front and center for the Dietary Guidelines Advisory Committee (DGAC), according to a range of industry and other groups.
Brief comments from dozens of organizations were submitted as video presentations or delivered live virtually for the third public meeting of the DGAC held Sept. 12-13. Directed to a panel of 18 committee members, commenters responded to scientific questions identified by the Department of Health and Human Services (HSS) together with the US Department of Agriculture (USDA). Every five years, a new edition of the Dietary Guidelines for Americans (DGA) is published by the HHS together with the USDA.
For the 2025 guidelines, the DGAC is examining a lengthy list of scientific questions to review refined from a series of questions the HHS and the USDA posed to the committee. The committee divided into subcommittees to conduct its evidence review.
“The questions focus on diet and health outcomes across the lifespan and examine the relationship between diet and the risk of overweight and obesity with a new emphasis on weight loss and weight maintenance and a question on ultra-processed foods,” according to the DGAC.
The DGAC will view its scientific questions through the lens of health equity with the intention that the next Dietary Guidelines for Americans recommendations will be relevant to a racially, ethnically, socioeconomically, and culturally diverse population.
Following the Sept. 12-13 meeting, the DGAC will review the scientific evidence before submitting a report to the Secretaries of USDA and HHS. The departments will consider advice from the committee’s report prior to crafting the next edition of the DGA.
While common concerns and views were expressed by many groups, disagreements were present, too. For instance, the dairy industry said discouraging intake of higher fat dairy products was not “in the best interest of public health.” A consumer group urged the DGAC not to “muddy the waters” by carving out an exception for higher saturated fat intake in certain cases.
The following are highlights from the brief comments submitted by a range of food industry and related groups:
Egg industry advocates
“There is more work to be done” to dismantle “outdated perceptions” consumers have about egg nutrition, said Oscar Garrison, senior vice president of food and safety regulatory affairs with United Egg Producers (UEP).
“Egg consumption suffered because people were concerned about cholesterol in their diet,” Mr. Garrison said. “But science now tells us that for most people, there is no connection between dietary cholesterol and cholesterol in the blood.” He added that the AHA endorses consuming an egg daily.
He noted that eggs are rich in the nutrient choline, important for expectant and nursing mothers and their infants and young children.
Choline interacts with lutein and DHA, additional nutrients found in eggs, said Jenny A. Houchins, PhD, RD, director of nutrition research, American Egg Board. She then pointed to recent research findings that a combination of these nutrients predict healthy brain development in early life.
Dr. Houchins also addressed negative perceptions of dietary cholesterol in eggs.
“In FDA’s proposed rule for ‘healthy,’ there are no limits on dietary cholesterol, consistent with the most recent science that has accumulated over decades on this topic,” she said.
Most research rejects a relationship between egg consumption and cardiovascular disease (CVD), and that new research indicates eggs can contribute to people at risk for CVD and diabetes, said Dr. Houchins.
International Dairy Foods Association
Dairy should be part of healthy eating patterns for all Americans, at all life stages and with various dietary needs,” said Roberta Wagner, senior vice president for regulatory and scientific affairs at the International Dairy Foods Association (IDFA), in live comments.
“Deterring (dairy) intake due to fat level is not science-based nor is it in the best interest of public health” Ms. Wagner said, expressing concern at the 2020 DGA’s preference for low-fat and fat-free food options, especially as most people do not meet DGA recommendations for dairy.
Dairy products contain calcium, vitamin D and potassium, all of which were identified as under-consumed nutrients in the 2020 DGA, she said.
Eating dairy foods at a variety of fat levels is linked to reduced risk of chronic diseases, said Katie Brown, EdD, RDN, senior vice president at the National Dairy Council (NDC) and head of its scientific, regulatory and nutrition affairs team.
“This suggests flexibility across a range of fat levels within energy limits to help close nutrient and health gaps,” Dr. Brown said.
She also highlighted low-lactose and lactose-free dairy products, noting that these products “fit into a variety of culturally appropriate eating patterns.”
Lactose-free milk can be found at 98% of US retail, making it a widely accessible option, Dr. Brown said.
National Pork Board
“Pork is a food that embodies aspects of affordability, nutrition and cultural significance,” said Kristen Hicks-Roof, PhD, RDN, LDN, CLC, FAND, a registered dietitian and the director of nutrition research at the National Pork Board (NPB).
Dr. Hicks-Roof told the committee they should consider pork as a nutritious and culturally significant food source. She pointed to research showing that “there is no socioeconomic gradient when it comes to who is eating pork.”
By including lean cuts of pork in the dietary guidelines, “Americans have the opportunity to feel good about choosing an affordable protein that also promotes social and cultural connection,” she said.
National Cattlemen’s Beef Association
Most Americans who consume beef maintain intake within DGA’s recommendations, said Shalene H. McNeill, PhD, RD, executive director of nutrition science, health and wellness for the National Cattlemen’s Beef Association
She added that Americans choose to eat beef “because it is a delicious food that is part of many of our cultural ways of eating.”
While intake generally is in line with recommendations, Dr. McNeill expressed concern that “as beef consumption has declined, at-risk populations — the disadvantaged, the pregnant, the young, the aging — are experiencing nutrient gaps and deficiencies that beef can help fill — such as iron.”
Objectively examining the evidence about what works and is practical in improving dietary patterns should guide the drafting of the dietary guidelines, said Campbell Genn, director of nutrition policy at the Sugar Association.
Ms. Genn cited evidence that reducing sugar intake alone hasn't reduced obesity despite a 30% decrease in added sugar consumption since 2000, a period over which child and adult obesity rates increased.
Not all foods with added sugars have the same impact on health and diet quality, Ms. Genn said. She noted that sugar serves functional roles in food and removing it in some instances results in increased calorie content.
The committee should focus on practical guidance in the 2025 guidelines, such as telling consumers to cap the amount of sugar-sweetened beverages consumed each week, she added.
Seeking to put intake into perspective, Ms. Genn reminded the committee that “when consumed in moderation real sugar continues to bring taste, function and pleasure to a healthy, balanced diet.”
The Alliance for Potato Research & Education
Urging the subcommittee to address limitations in the current DGAC protocol for evaluating dietary patterns' impact on health, Mitch Kanter, PhD, chief science officer of The Alliance for Potato Research & Education (APRE), emphasized the need for accurate and current data.
Dr. Kanter highlighted concerns about the reliability of self-reported dietary assessment tools in observational studies and the unjust “a priori” grouping of potatoes with less healthy foods.
Additionally, he pointed out that data collected decades ago may not accurately represent today’s nutrient content and preparation methods for certain foods like potatoes. Additionally, limited databases that do not reflect the diversity of the American population may affect the generalizability of study findings, he said.
Dr. Kanter recommended including studies post-May 2023 and shorter-duration randomized controlled trials (RCTs) for improved protocols.
National Pasta Association
Emphasizing pasta’s nutritional value and role in promoting equity, Clarissa Russel, executive director of the National Pasta Association (NPA), told the committee that “pasta is affordable, versatile and culturally diverse, making it accessible to various income levels and cuisines.”
“Pasta, both enriched and whole grain, is a healthy, nutritious food that provides key nutrients” for people of all ages, she said.
Ms. Russel specified that pasta contributes to plant protein and fiber intake while containing minimal added sugar, saturated fat and salt.
She cited research showing that pasta consumption is linked to higher Healthy Eating Index scores. Ms. Russel also mentioned studies suggesting that pasta consumption is not associated with weight gain or obesity.
American Frozen Food Institute
Nutritious, convenient and affordable products that reduce food waste are the mainstay of the frozen food sector, said Jennifer Norka, MPH, director of regulatory and scientific affairs at the American Frozen Food Institute (AFFI).
The AFFI addressed the scientific question on the relationship between consumption of ultra-processed foods (UPFs) and growth, body composition and risk of obesity. Ms. Norka cautioned against excluding foods based on assessments of nutrient density linked to added sugars, saturated fat and sodium.
“Exclusion of these foods causes misrepresentation of typical dietary patterns and may lead to future exclusion of nutritious food items that are common in American diets from reports and guidance documents,” she said.
American Heart Association
“Until there is stronger evidence from RCTs (randomized controlled trials)” as to whether food sources of saturated fat affect the risk of cardiovascular disease, “the American Heart Association (AHA) supports the current recommendation to replace foods high in saturated fats with foods higher in unsaturated fats,” said Maya Vadiveloo, PhD, RD, on behalf of the association. Dr. Vadiveloo is an assistant professor of nutrition and health sciences in the Department of Nutrition and Food Sciences, University of Rhode Island.
“To help consumers implement this recommendation, the Guidelines should clearly specify commonly consumed foods high in saturated fats and suggest foods high in unsaturated fats as possible replacements,” she told the committee.
Center for Science and the Public Interest
“Science continues to support limiting the consumption of saturated fats to less than 10% of calories and replacing saturated fats with unsaturated fats,” said Catherine Cochran, a policy fellow at the Center for Science and the Public Interest (CSPI).
She urged the committee “not (to) muddy this advice by carving out exceptions for individual food sources without convincing evidence from RCTs that a given food does not raise LDL cholesterol, a surrogate endpoint for CVD (cardiovascular disease).”