Dietary Guidelines Advisory Committee Submits 2025 Scientific Report to HHS and USDA

Executive Summary

On December 10, 2024, the Dietary Guidelines Advisory Committee (Committee) submitted its 2025 Scientific Report to the U.S. Department of Health and Human Services (HHS) and the U.S. Department of Agriculture (USDA) (collectively, the Departments). The Scientific Report, alongside public comments and federal agency input, will inform the Departments as they develop the Dietary Guidelines for Americans, 2025-2030 (2025-2030 Dietary Guidelines). The 2025-2030 Dietary Guidelines, which should be issued in early 2025, will set nutrition standards for federal nutrition programs, like the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) and the National School Breakfast and Lunch Programs (NSLP), and should inform FDA’s nutrition policy. It will also provide a critical framework for state and local health promotion and disease prevention initiatives.

Many of the Committee’s recommendations in the Scientific Report are similar to those made in previous iterations of the dietary guidelines—including those related to limiting consumption of sugar-sweetened beverages and foods high in sodium and saturated fat. In a marked shift from prior reports, the Committee recommends reducing intake of red and processed meats and eating more plant-based sources of protein. The Scientific Report notably lacks recommendations regarding ultra-processed foods, alcohol, and dietary supplements. The comment period closes on February 8, 2025. ^[1] Given the importance of the 2025-2030 Dietary Guidelines in shaping nutrition policy in the incoming Trump administration and the focus of the nominees for Secretary of HHS and FDA Commissioner on reducing the burden of diet-related diseases, interested stakeholders are encouraged to provide their input.

Background

The Committee was tasked by HHS and USDA to examine scientific evidence on specific nutrition and public health topics and provide independent, science-based advice and recommendations for the Departments to consider when developing the 2025-2030 Dietary Guidelines. The Committee addresses a broad range of important diet- and health-related questions in the Scientific Report, building on the work of previous committees and expanding its reviews to new topics such as food sources of saturated fat, dietary patterns with varying amounts of ultra-processed foods, plant-based sources of protein, and portion sizes. The Committee upholds its historic lifespan approach and utilizes health equity as a guiding principle when examining relevant evidence.

Key Elements of the Scientific Report

The Scientific Report emphasizes consuming vegetables, fruits, legumes (such as beans, peas, lentils), whole grains, nuts, and fish and seafood throughout the lifespan. It also encourages consumption of unsaturated fats as well as low-fat and non-fat dairy. The Scientific Report discourages consumption of red or processed meats, saturated fats, salty or sugary snacks, and sugar-sweetened beverages and foods. Throughout the Scientific Report, the Committee recognizes that Americans’ dietary patterns are associated with a host of health outcomes, including growth, body composition, and risk of obesity; cardiovascular disease; type 2 diabetes; breast cancer; colorectal cancer; and cognitive decline, dementia, Alzheimer’s disease, and mild cognitive impairment.^[2]

The Scientific Report does not include any recommendations specifically on ultra-processed foods. Though the Committee conducted a systematic review of ultra-processed foods, it cites (1) studies’ varying definitions of ultra-processed foods and (2) remaining gaps in understanding how ultra-processed foods affect health as limiting factors in drawing conclusion statements for ultra-processed foods. In lieu of providing concrete recommendations regarding ultra-processed foods, the Committee recommends that future committees consider examining the association between ultra-processed foods and growth, body composition, and risk of obesity.^[3]

Because the Departments determined that the topic of alcoholic beverages and health requires a comprehensive review with significant, specific expertise, the Scientific Report does not address alcohol consumption. The Committee notes that two separate scientific reviews on adult alcohol consumption and health are underway, and the Departments will consider the results of both studies when developing the 2025-2030 Dietary Guidelines.

Below, we summarize key recommendations from the Committee’s Scientific Report.

Beverages

The Scientific Report notes that sugar-sweetened beverages are the top food category contributor to added sugar intake.^[4] According to the Committee, consumption of sugar-sweetened beverages is associated with unfavorable growth patterns and body composition, higher risk of obesity in childhood up to early adulthood, and higher risk of type 2 diabetes in adults and older adults.^[5] In turn, the Committee recommends that plain drinking water should be the primary beverage for people to consume. Another healthy option is water beverages flavored with a small amount of 100% fruit juice. With respect to milk consumption, the Committee recommends unsweetened fat-free and low-fat dairy milk and unsweetened fortified soy beverages. The Committee also recommends that products added to beverages containing high amounts of calories and saturated fat and/or added sugars (such as half & half, cream, non-dairy creamers, and flavorings with added sugars such as syrups) should be replaced with versions lower in saturated fats and added sugars.

Though the Scientific Report recognizes that certain beverages, such as tea and coffee, often contain caffeine, the Committee does not offer new recommendations with respect to caffeine intake. Instead, the Committee recommends carrying forward into the 2025-2030 Dietary Guidelines the information about safe levels of caffeine consumption from the Dietary Guidelines for Americans, 2020-2025, which concluded that 400 milligrams per day of caffeine is an amount not generally associated with dangerous, negative effects in most healthy adults.^[6]

Saturated Fat

Food sources of saturated fat in the U.S. include both animal- and plant-based foods. The Scientific Report notes that saturated fat is commonly found in higher amounts in high-fat meat, full-fat dairy products, butter, coconut oil, and palm oil. The Committee reaffirms guidance from the Dietary Guidelines for Americans 2020-2025 to limit foods and beverages higher in saturated fat and to limit total saturated fat intake to less than 10 percent of calories per day.

The Committee also reiterates current guidance to lower consumption of butter and replace butter with vegetable oils higher in unsaturated fatty acids. The Scientific Report echoes existing recommendations to replace saturated fat with unsaturated fat, particularly polyunsaturated fat.^[7] However, this is the first Scientific Report to recommend explicitly that the replacement of saturated fats with polyunsaturated fats and monounsaturated fats should focus on plant-based sources such as beans, peas, lentils, nuts, seeds, and soy. Despite acknowledging that full-fat dairy products are a primary source of saturated fats, the Committee advises that there should be no change in recommendations for consumption of dairy.^[8]

Red Meat and Plant-Based Sources of Protein

The Committee notes there is compelling evidence that dietary patterns with higher intakes of red and processed meats are related to detrimental health consequences.^[9] In the strongest statement against the consumption of red meat in dietary guidelines documents to date, the Committee recommends increasing dietary intake of plant-based sources of protein and reducing intake of red and processed meats.^[10] The Committee does not distinguish between processed and unprocessed plant-based sources of protein.

In furtherance of this recommendation, the Committee urges the Departments to move the Beans, Peas, and Lentils Subgroup from the Vegetables Food Group to the Protein Foods Group to align with evidence to encourage greater consumption of plant-based Protein Foods. The Committee also proposes reorganizing the order of the Protein Foods Subgroups to list Beans, Peas, and Lentils first, followed by Nuts, Seeds, and Soy Products, then Seafood, and finally Meats, Poultry, and Eggs.^[11] This recommended reordering of Protein Foods emphasizes the Committee’s conclusions regarding the health benefits of more plant-based Protein Foods.

Grains

The Scientific Report acknowledges that dietary patterns associated with better health outcomes include higher intakes of whole grains and lower intakes of refined grains.^[12] In turn, the Committee recommends mostly whole grains and lower refined grains.^[13] Specifically, the Committee urges the Departments to provide clear definitions and/or examples of whole grains. The Committee also recommends that consumed grains be “mostly whole grains” instead of “at least half whole grains.”^[14]

Portion Size

The Committee recommends that adults and children consume smaller portions of foods and beverages that are high in energy density and low in nutrient density.^[15] Specifically, the Scientific Report concludes that the use of pre-portioned foods reduces energy intake among adults and older adults, and can be particularly important to help reduce intake of energy-dense foods. It also recommends preparing meals in the home in pre-portioned sizes, as well as opting for smaller-pre-portioned packages in retail and food service establishments.

Deadline for Comments

Comments on the Scientific Report are due February 8, 2025. In addition to providing written comments, the public is invited to present oral comments to the Departments at a virtual meeting that will take place on Thursday, January 16, 2025 from 1:00pm to 4:30pm.^[16]

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