THE GUIDELINES RECOMMEND DIETS THAT ARE NUTRITIONALLY INSUFFICIENT
The 2020 Dietary Guidelines Advisory Committee Report states that the guidelines, even if followed perfectly, do not deliver the complete set of vitamins and minerals that are considered essential for basic health.
“Nutrients that do not meet Recommended Dietary Allowance or Adequate Intake goals include the following” Iron, Vitamin D, Vitamin E, Choline, and Folate.
For details, see the 2020 Report, Part D, Chapter 14, page 10.
Deficiencies in iron and folate are likely to be particularly significant, because the guidelines count the contribution of these nutrients from refined, fortified grains (only refined grains are fortified, not whole grains). The guidelines recommend three (3) servings of refined grains per day.
Yet it’s not clear that nutrients from fortified foods are as “bioavailable.”
The bioavailability of iron from fortified whole grains may be minimal. (see studies here, and here).
Folic acid from fortified foods may not be well absorbed.