Potentially significant changes to the federal Dietary Guidelines are on the horizon in 2025 – and the U.S. Department of Health and Human Services (HHS) and U.S. Department of Agriculture (USDA) are requesting public input to guide the agencies as they develop the next iteration, the Dietary Guidelines for Americans, 2025-2030, expected to be published in late 2025. This comes as the food and beverage industry both plans for potential Make America Healthy Again initiatives from the incoming Administration and continues to face increased scrutiny on processed foods and what foods may qualify as “healthy.”
The Dietary Guidelines impact the entire food industry and its ecosystem, including manufacturers and retailers, as well as components of the agriculture, nutrition, health care, and education industries. Businesses must adapt their practices and messaging regarding consumers’ food choices and healthy food consumption to the guidelines proposed by the USDA and HHS.
What Are the Dietary Guidelines?
The Dietary Guidelines were first published in 1980 as a way for the federal government to support consumers’ daily food choices and selections to ensure the intake of essential nutrients. They were initially based in part on a 1979 report by the U.S. Surgeon General, the findings of a task force convened by the American Society for Clinical Nutrition, and substantive work conducted by the Senate Select Committee on Nutrition and Human Needs.
The Dietary Guidelines are updated every five years and serve as the “cornerstone of federal nutrition programs and policies, providing food-based recommendations to help prevent diet-related chronic diseases and promote overall health.” The USDA and HHS work collaboratively – based on a congressional mandate – to develop the guidelines. The agencies share responsibility for overseeing the process and ensuring the guidelines reflect current nutrition research, facilitated by the Dietary Guidelines Advisory Committee (DGAC). On January 19, 2023, the USDA and HHS announced the appointment of 20 nationally recognized nutrition and public health experts to serve on the 2025 DGAC. Since that time, the DGAC has reviewed the current body of nutrition science on specific topics and questions in developing a report that includes its independent, science-based advice for the federal agencies to consider. Following review, the USDA and HHS are expected to jointly finalize the guidelines based on the DGAC’s recommendations.
The new Dietary Guidelines will have a far-reaching impact. Developed and written for a professional audience, including policymakers, health care providers, nutrition educators, and federal nutrition program operators, they are used for numerous rulemakings and policy decisions, including the school meals program, the regulatory definition for the implied nutrient content claim “healthy,” and potential front-of-package labeling requirements.
Request for Public Comment and Public Hearing
On December 10, 2024, after publishing their Scientific Report on the 2025 DGAC’s findings, which will inform changes to the Dietary Guidelines, the USDA and HHS announced a 60-day public comment period on all aspects of the report. Comments are due by February 10, 2025. Additionally, the agencies will hold a public meeting on January 16, 2025 to hear oral comments from the public on the report. While registration for the meeting has closed, the agencies encourage the submission of comments.
Key Areas of Focus
- One of the key changes proposed in the Scientific Report is the consolidation of the three existing dietary patterns – Healthy U.S.-Style, Healthy Mediterranean-Style, and Healthy Vegetarian – into one “Eat Healthy Your Way” pattern.
- The proposed modification promotes an increased focus on plant-based foods and encourages the intake of legumes and vegetables, as well as fruits, whole grains, nuts, and low or non-fat dairy consumption, while limiting the intake of red and processed meats, including foods high in saturated fats, added sugars, and sodium.
- This recommendation has been met with significant criticism from key industry stakeholders, who assert that beef and meat products are nutrient-rich foods that are essential to a well-balanced diet.
- Notably, the DGAC examined the impact of ultra-processed food consumption and associated health outcomes. Given the limited research on this type of food, the committee did not reach a clear determination on the impact of ultra-processed foods and instead encouraged additional analysis from future committees.
- President-elect Donald Trump’s nominee for HHS secretary, Robert F. Kennedy Jr., has described ultra-processed foods as detrimental to the overall American health system. He has also spoken critically of industry influence in the development of the Dietary Guidelines. That being the case, his leadership of HHS, if confirmed by the Senate, will be crucial to watch as the agencies develop the new guidelines in 2025.
- Moreover, the DGAC encouraged enhancement of the “U.S. food and nutrition surveillance system to facilitate continuous and accurate monitoring of food consumption patterns, dietary composition, nutrient intake, and overall nutritional status.” In doing so, the committee believes that improvements can be made for identifying evidence gaps and supporting population-based health interventions, which promotes public health.
We will continue to monitor developments related to the USDA and HHS nutrition initiatives.
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