As the Dietary Guidelines for Americans 2025-2030 Advisory Committee approaches its final meeting later this month, some food industry groups say the process for selecting science needs to be more clear, and solely focused on nutritional factors.
The process to develop the Dietary Guidelines for Americans begins with the DGA Advisory Committee, which submits a scientific report and recommendations to USDA and the Department of Health and Human Services. Ultimately, the secretaries of agriculture and health and human services issue the final guidelines.
Throughout several meetings, the advisory committee of about 20 people has worked to address scientific questions determined by the agencies after a public comment period, reviewing scientific studies to inform their recommendations. The committee's sixth meeting is planned for Sept. 25 and 26. The committee will hold its Scientific Report meeting to discuss findings and advice to the agencies on October 20 and 21.
Industry groups that have been watching the meetings are expressing concerns about the level of transparency and scientific rigor on display. Recently, milk and dairy leaders raised these issues in a letter to USDA and HHS secretaries.
Michael Dykes and Gregg Doud, the CEOs of the International Dairy Foods Association and National Milk Producers Federation, said the DGAC has not publicly disclosed the criteria it's using to select which studies submitted by stakeholders are used in drafting conclusion statements.
Along with the dairy groups, other agriculture sectors are closely monitoring how the process continues to unfold.
“The impact of the DGA is substantial, and therefore there's a lot of scrutiny on the process,” said Matt Herrick, executive vice president and chief impact officer at the IDFA. “When there's a lack of transparency or questions about the scientific rigor in the process, that becomes very concerning.”
During the last DGAC meeting in May, Herrick said groups had questions about how and why certain scientific studies are selected as well as why the committee has apparently relied more on food pattern modeling than established science.
The DGAC releases defined protocols for reviewing the science, which are informed by National Academy of Science and Medicine recommendations. But during the last meeting, Herrick said it appeared the committee was straying from these protocols after the scientific studies were already collected.
For example, in the protocol regarding dietary care in cardiovascular disease, the subcommittee identified over 100 relevant studies and articles that met the criteria. However, the subcommittee later decided it would limit studies to those conducted in the United States and those that met specific socioeconomic criteria.
This cut the number of studies to about 20, Herrick said.
"The Departments value transparency and scientific rigor in the process used to develop the Dietary Guidelines and have taken numerous steps to make sure that the public is able to follow and participate in the Committee’s review of the science," the HHS Office of Disease Prevention and Health Promotion wrote in an email.
The DGAC protocol for dietary care in cardiovascular disease for example was presented and discussed at public meetings before it was used in reviewing any evidence. The committee was able to look at a subset of studies that included more ethnic and socioeconomic diverse participants, but the conclusion statement represented the entire body of evidence.
The HHS office was unaware of other social, economic or environmental factors being used to determine the inclusion or exclusion of studies from the DGAC review.
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Aviva Musicus, science director at the Center for Science in the Public Interest, called the DGAs the “single most influential lever to shift food procurement in the U.S. and also to shift dietary patterns in the U.S.” This is because all federal nutrition programs are required by law to follow the guidelines, and can drive billions of dollars in food purchasing decisions.
She said the attacks are unwarranted and could open the door to more political and industry influence. The current process, she said, is largely apolitical, scientifically rigorous and informed by public input.
Aviva MusicusBut Herrick said that as the committee excludes more evidence, it has begun to rely more heavily on food pattern modeling, Herrick said. This could open the DGA process to more “suspicions of manipulation,” he continued.
This is highlighted as the committee aims to address other issues outside of nutrition like sustainability and socioeconomic factors, Herrick said. While these questions are important for the food system, it’s unclear if they should be answered by the DGAs, he said.
Using some food pattern modeling is not new for the committee, and has been used by five DGACs since 2005. However, the preference has always been to use established research and studies to draw conclusions rather than having to model, Herrick said.
Protocols for using food pattern modeling are developed similarly to systematic reviews, and are open to public input before any analysis is completed.
It’s also unclear exactly what is going into the food pattern modeling, which makes it difficult to understand how the committee reached conclusions, said Beth Johnson, CEO and founder of Food Directions and a consultant to the National Potato Council. With this process, the food pattern modeling has also focused more on how a combination of foods impacts health outcomes rather than the specific nutrients, Johnson said.
Even for long-time observers of the guidelines, this ongoing process looks different and has less clarity, Johnson continued.
“I think usually by this time we have some idea of where things are headed in … what the scientists know and are thinking and how they've interpreted the science,” Johnson said. “I think this time around, there's a lot that is left unknown.”
Another concern is the length of time associated with the process. Susan Backus, vice president of regulatory and scientific affairs at the Meat Institute, said the current timeline is not adequate for assessing the impact or effectiveness of the guidelines before starting the process over. Additionally, she said the data and science may not change dramatically within five years.
Overall, industry groups are concerned that the upcoming dietary guideline recommendations could include dramatic changes in suggested intake, without a clear understanding of what evidence supports these alterations.
Taking sweeping action could also impact the public’s adherence to the guidelines as well, said Backus. She’s concerned that the current process is trying to create a one-size fits all guidance that doesn’t reflect actual eating habits.
“Dietary guidance should be achievable, attainable, accessible, affordable, culturally relevant and meet people where they are,” Backus said. “Small shifts can help improve a person's overall health, but if they're so unrealistic that they're unattainable, are people going to embrace it?”
The committee is ahead of past updates, with some expecting to see the recommendations anytime from September to the end of the year.
In an entry to the American Journal of Clinical Nutrition earlier this year, Janet de Jesus, Nutrition Advisor at the Office of Disease Prevention and Health Promotion within the Office of the Assistant Secretary for Health at HHS, along with other authors, addressed some of the concerns about transparency within the DGA process.
Each DGAC completes a review of scientific evidence using data analysis, food pattern modeling and Nutrition Evidence Systematic Reviews. Each has a protocol-driven methodology to select the most “appropriate, relevant and direct body of evidence, while minimizing bias,” authors wrote in the journal.
The protocol for evaluating evidence is also created before the committee examines anything, and the public is encouraged to comment on these protocols.
“The DGA is based on rigorous scientific evidence and is applicable to the general public,” the authors wrote. “With every edition, the process to develop the DGA evolves to improve transparency, rigor, and relevance to the entire United States population.”
With the presidential election looming, there are questions about how a change in the party could affect the guidelines, Johnson said.
Heritage Foundation’s Project 2025, which lays out recommendations for how a conservative administration could overhaul the executive branch, suggests eliminating or reforming the DGAs. Under the policy proposal, a conservative USDA should work with lawmakers to repeal the guidelines, or at a minimum should help develop a more transparent process that focuses solely on nutritional issues rather than subjects like the environment.
Former President Donald Trump has attempted to distance himself from Project 2025, and even claimed he has not heard about the plan. However, many former senior members of his administration were involved.
Some groups are working under the assumption that the guidelines will be published before a change in administration, but this may not leave enough time to adequately review and provide comments, Backus said.
Already though there are political efforts to alter the DGA process. A provision in the draft farm bill that advanced from the House Agriculture Committee would create tighter definitions and change some of the procedures within the process. The provision came from House Agriculture Republicans' concerns with transparency, lack of scientific rigor and conflicts of interest, according to a House aide.
The bill would define systematic reviews for the first time, said an aide. Additionally, it would shift the requirement from a preponderance of evidence to a significant scientific agreement as determined by an evidence-based review.
The provision does not explicitly say what the science must look like, but aims to ensure public transparency and faith in the process, the aide said.
Under the House farm bill proposal, the DGAC would also be limited in what questions it can consider. It would block looking at topics like sustainability, race, ethnicity, culture and socioeconomic status, and could prevent different dietary preferences and cultural traditions from being considered.
The farm bill framework released by Senate Agriculture Committee Chairwoman Debbie Stabenow, D-Mich., does not contain these provisions on the DGA process. While there is no text or detailed framework for a farm bill proposal developed by ranking member John Boozman, R-Ark., the summary he released does not mention the guidelines either.
This story was updated to clarify the final DGAC meeting date and with additional information from the Department of Health and Human Services' Office of Disease Prevention and Health Promotion.
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