77% of Comments to USDA-HHS Call for Review of Low-Carb Science

Calls for a review of the science on low-carbohydrate diets dominated responses to the U.S. Departments of Agriculture and Health and Human Services (USDA-HHS), during a public comment period asking for feedback on the development of the science for the next Dietary Guidelines for Americans.

Seventy-seven percent, or some 700 of the 916 comments submitted to USDA-HHS, asked the agencies to consider the science on low-carbohydrate diets, a subject that was not included in an initial list of scientific questions proposed to review for the next iteration of the guidelines. Each of the 700 comments was unique, not from a ‘robo-comment’ bot. In addition, one comment, submitted by the Society for Metabolic Health Practitioners, a group comprised of doctors and other healthcare practitioners, included 475 signatures in support of the need to review the science on therapeutic carbohydrate restriction. Thus, altogether, nearly 1,200 people submitted comments urging USDA-HHS not to ignore this important body of scientific literature.

The comments reflect the public’s growing awareness of the many clinical trials demonstrating the effectiveness of carbohydrate restriction in combating diet-related diseases, such as obesity, type 2 diabetes, high blood pressure and markers of inflammation among other cardiovascular risk factors.

The American Diabetes Association and American Heart Association have come out in support of a low-carbohydrate diet. Yet the federal government has yet to recognize the science.

Indeed, ample evidence indicates that federal agencies have turned a blind eye to this evidence. For the 2015 guidelines, the USDA-HHS expert advisory committee conducted a formal systematic review of low-carbohydrate studies but never revealed this publicly. The review comprised 43 studies, including 30 clinical trials. Five years later, the USDA team for the 2020 guidelines reported that it could only find a single study on low-carbohydrate diets, contradicting its earlier findings.

Why has the USDA-HHS not been interested in this highly promising body of data? The answer is unclear. This 2022 article, published by Cambridge University Press, found that 95% of the 2020 Dietary Guidelines Advisory Committee had at least one conflict of interest with the food or pharmaceutical industries.

The guidelines continue to promote a one-size-fits all diet that advises people to eat 45%-65% of calories from carbohydrates, despite the fact that carbohydrate is the one macronutrient that is non-essential, i.e., humans have no need to consume it.

As many of the commenters to the USDA-HHS indicated, restricting carbohydrate consumption has helped them achieve metabolic health, get off medication and thrive. One commenter wrote:

“I am a retired physician who personally struggled with overweight or obesity since childhood. I counseled patients on the same issues, using nutritional & exercise guidelines from government and medical experts. Those guidelines did not work for my patients or me. I would lose weight on calorie counting & exercise but could not sustain this when eating carbohydrates, including so-called healthy whole grains. Only when I discovered information about low carb/ketogenic way of eating at age 69 did my struggles end. I have been following low carb eating since then, feel wonderful, have excellent exercise endurance, saw my HDL increase to 104, and suffer no more joint pains.”

The Nutrition Coalition fully expects the USDA-HHS to respond to these public comments as it embarks upon updating the guidelines. 

“We hope the public comment period is meant sincerely and not simply as window dressing for a pre-determined processs,” said Jennifer Friedlin, President of The Nutrition Coalition. “It is time for the government to act in the best interest of all Americans and investigate this large body of high-quality evidence on low-carbohydrate diets.”

The Nutrition Coalition thanks the hundreds of healthcare practitioners, scientists and other individuals for taking the time to share their thoughts and experiences for the betterment of the health and well-being of all Americans.