Your Chance to Comment on the Next Dietary Guidelines
For the first time in years, I believe there’s reason to hope that we might truly see reform of the Dietary Guidelines for Americans. Finally, political energy exists to do something about our chronic disease epidemics. Now is the time for change—and you can help.
On the immediate horizon is the 2025-2030 Dietary Guidelines, slated for publication later this year by the U.S. Departments of Agriculture and Health and Human Services (USDA-HHS). In December, the Scientific Report (“Report”) by the expert committee was published. The next step will be for the USDA-HHS Secretaries appointed by the Trump administration to write the new Guidelines based on this report, although the Secretaries have the liberty to approve or reject its recommendations as they like. Part of this process includes a review of public comments.
Please consider submitting a written comment on the report.
It’s crucial to tell incoming USDA-HHS officials that the 2025 Report recommendations are not science-based and would likely worsen malnutrition and chronic disease in America.
Below are some of my observations that might be helpful to you in writing your comment:
The U.S. Dietary Guidelines still lack any dietary advice for people with chronic diseases
The 2025 Report, like those before it, provides no option to treat people with obesity, diabetes, or any other metabolic disease. The expert committee has not reviewed the science on disease reversal/remission. This is a grave omission, considering that 88%-93% of American adults, according to various estimates, have been diagnosed with or are taking medications for one or more chronic diseases.
The Report’s advice to replace meat, poultry, and eggs with plant-based proteins will very likely worsen health
The Report recommends reducing poultry, meat, and eggs by 3 ½ - 4 ounce-equivalents per week for people eating 2,200 calories or more and replacing these with proteins from plant sources, specifically peas, beans, and lentils. This proposed recommendation would presumably allow schools to serve children less meat and fewer eggs. This advice did not consider that plant-based proteins are not as complete as those from animals and also not as bioavailable. Plant sources like peas and beans additionally pack a hefty load of carbohydrates and calories for the same amount of protein, making them a far less healthy option for people with metabolic conditions such as obesity and diabetes who need to be mindful of controlling their blood sugars. For more details and references, see our post on “The Erosion of Protein in the Dietary Guidelines.”
The proposed recommendation to reduce red/processed meat is not supported by the Report's evidence
- To justify new advice for reducing red and processed meats, the Report cites three major systematic reviews—looking (in part) at the effect of red meat on obesity, type 2 diabetes, and heart disease in adults.
Yet the clinical trials listed in these reviews do not support these claims. I analyzed the reviews and found that 0% of the trials on heart disease (0/9), 29% on obesity (7/24), and 8% (1/13) on type 2 diabetes support the committee’s claims that red meat consumption is related to these diseases. Altogether, 17/46 trials or just 17% support the committee’s claims. Even if my numbers are not precisely accurate (as they might not be), they suggest that the most rigorous clinical trial evidence does not support the Report’s recommendation to reduce red/processed meat.
In addition to the systematic reviews, the Report uses food-pattern modeling by USDA to support the recommendation for red/processed meat. Unfortunately, these models lack accuracy. For instance, the USDA simulations make no distinction between a tomato (< 5 grams of carbs per serving) and a sweet potato (27 carbs); Both are part of the “red and yellow vegetables category.” The model did not control for portion size and did not include “mixed dishes,” such as lasagna and hamburgers, even though these are a major source of calories for Americans. The model also makes hundreds of questionable assumptions. If one assumes that saturated fats are bad for health, as the USDA does, then the model will downgrade all foods with those fats. The USDA office that conducted the modeling does not appear to provide information on its methods or assumptions, so the project, which reportedly produced 17,500 simulations, remains a virtual black box
The same three systematic reviews listed above are used to justify the Report’s assertion that the existing Dietary Guidelines prevent obesity, type 2 diabetes, and heart disease
To iterate: the clinical trial evidence cited by the Report does not support these claims. In a 2015 cover story for the BMJ, I reported that the Guidelines “are supported by a minuscule quantity of rigorous evidence that only marginally supports claims that these diets can promote better health than alternatives.” Since then, the evidence has grown no stronger.
Still no review on low-carbohydrate diets
The current Report did not ignore low-carbohydrate diets, as the USDA-HHS have done in the past. Yet rather than consult the now more than 1,000 papers on clinical trials (studies that can show cause-and-effect relationships) on this approach, the expert committee instead resorted to using simulations of the diet using the USDA’s computer models. This exercise discovered that when carbohydrates are removed (currently comprising some 52-54% of the Guidelines' calories per day), nutrient adequacy plummeted. But the models didn’t replace those 50+% of calories with any other foods. So, of course, nutrients take a nose dive when caloric intake is halved! For background, the USDA-HHS has for years failed to consider the evidence on low-carb diets. The suppression of this data has been going on since 2015, at least, as I discovered through emails obtained via the Freedom of Information Act. These included one from Harvard professor Frank Hu, who wrote to his fellow expert committee members and USDA colleagues, “I was wondering if we should have a separate section on low-carb diets rather than burying it.”
Lack of scientific rigor
See the bullet point above about the black-box food pattern modeling. These data were used to underpin many of the Report’s recommendations. Remember that the National Academies of Sciences, Engineering, and Medicine reviewed the methodology used to review the science for the Guidelines. The Academies' 2017 report found that the USDA did not use a "recognizable or verified” methodology and that the process “lacked scientific rigor." Congress had mandated and allocated 1 million dollars for this high-level report and another $1 million for a follow-up in 2022. Still, the USDA did not fully adopt even one of the Academies’ 11 recommendations. Similarly, a 2022 paper in PNAS Nexus that I co-authored detailed many problems with the guidelines, including the lack of strong evidence for numerous key recommendations. This year, the USDA-HHS staff responded to us in a paper entitled “Addressing misinformation about the Dietary Guidelines.”
Conflicts of interest on the expert committee
Members of the 2025 expert committee include Christopher Gardner, a Stanford professor entirely underwritten by the fake-food company Beyond Meat, and Fatima Cody, a Harvard doctor who has taken tens of thousands of dollars from Wegovy and other GLP-1 manufacturers. The latter went on 60 Minutes to emphasize that obesity is a genetic disease. If that is true, why is she on a committee to talk about diet, which presumably she thinks doesn't matter? Altogether, nearly 50% of committee members were found to have conflicts of interest with food or pharma companies, according to a report by the group US Right to Know.
I hope these points provide plenty of fodder as you formulate your comments!
The deadline for submitting a comment is February 10th. To submit written/hardcopy submissions, send correspondence to Janet M. de Jesus, MS, RD, Office of Disease Prevention and Health Promotion (ODPHP) Office of the Assistant Secretary for Health (OASH), HHS; 1101 Wootton Parkway, Suite 420; Rockville, MD 20852.
Wishing everyone a happy and healthy New Year, and let us hope that our years of hard work will bring reform of the Dietary Guidelines this year!
Nina
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