2025 Dietary Guidelines

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U.S. DIETARY GUIDELINES REMAIN AN EVIDENCE-FREE ZONE

The highly anticipated scientific report for the 2025 U.S. Dietary Guidelines was released on December 10, 2024 by the U.S. Department of Agriculture (USDA) and the Department of Health and Human Services (HHS).¹ The tome’s four hundred twenty-one pages are meant to inform new guidelines due in 2025, although the task of writing the guidelines policy itself falls to USDA and HHS political appointees.

Typically, the scientific report is released in early fall, allowing the man­datory sixty-day public comment period to conclude before the outgoing administration finalizes the guidelines. However, in this case, the com­ment period extends beyond the Biden Administration into the Trump era, shifting responsibility for drafting the guidelines to the newly appointed Secretaries of the USDA and HHS.

While the Secretaries are legally required to issue dietary guidelines, the law sets few constraints on how they proceed. There’s no statutory requirement to promote the guidelines to the public, for instance, and the Secretaries can accept or reject recommendations from the scientific report as they please.

No doubt, any decisions they make will be seen as fueled by political considerations, yet there’s a far better reason to reject a number of the new recommendations: they are not based on rigorous science and, in many cases, would almost certainly harm our health. Four of the key recommendations in this report include declining to set limits on ultra-processed foods; replacing poultry, meat and eggs with peas, beans and lentils as sources of protein; reduc­ing red and processed meats; and continuing to cap intake of saturated fats, to be replaced by vegetable (seed) oils.

CONTROVERSY OVER ULTRA-PROCESSED FOODS

The question of whether the expert com­mittee should set limits on ultra-processed foods has sparked controversy ever since the group’s final public meeting, when it revealed it couldn’t make a recommendation to restrict these foods because the evidence on them was “limited.” Calls for reducing ultra-processed foods have transcended partisan lines—from Robert F. Kennedy, Jr. reportedly advocating for their removal from school lunches to Marion Nestle, New York University professor emerita, calling the committee’s “non-recommendation” a “travesty.”

Indeed, there is “remarkable, strong bipar­tisan concern about ultra-processed food,” as Jerold Mande, a former deputy undersecretary for food safety at the Department of Agriculture under two Democratic presidents, told TIME magazine.² Nevertheless, the expert committee responsible for the December report insisted that the evidence for urging reductions in ultra-processed foods was “limited.”

It’s possible that conflicts of interest on the expert committee may have influenced this decision. Nine out of the twenty members have ties with food, pharmaceutical or weight loss companies or industry groups with a stake in the outcome of the guidelines, according to an October 2023 report by the non-profit public interest group, U.S. Right to Know.³ Some of the most frequently occurring conflicts are with Novo Nordisk and Eli Lilly, makers of weight-loss shots like Ozempic and Wegovy.⁴

Still, it’s important to say that the com­mittee’s assessment of the evidence on ultra-processed foods as “limited” is correct. The USDA systematic review of these foods found only one small clinical trial testing the effects of these foods on health outcomes. This trial, conducted at the National Institutes of Health, involved twenty adults for only twenty-eight days (fourteen days on an ultra-processed food diet and fourteen days on a whole-food diet). The subjects were found to consume more calories while on the ultra-processed food diet, but even so, the test is too small and preliminary to generalize its conclusions to an entire nation. As I’ve written before, we have many more and better studies on some of the components of ultra-processed foods—sugars and starches, for instance—and should act on these more precise and robust data first.

Marion Nestle acknowledged on her blog that the advisory committee must stick to “evidence-based recommendations,” while giving the strong impression that she wished it weren’t so.⁵ She’s also quoted in a STAT article that headlines her comment about the “impos­sible restrictions” imposed on the guidelines by limiting recommendations to only those supported by strong evidence.⁶

In my view, we should not be arguing for guidelines based on lesser evidence. The near-complete lack of rigorous data for the original guidelines in 1980 set in motion a Titanic of misguided advice that has coincided with our astonishing epidemics in chronic diseases. Ac­cording to the best available government data, Americans have largely followed the guidelines, and despite this, we have not only become sick but very sick.

Echoing this view is a Congressionally mandated report by the National Academies of Sciences, Engineering, and Medicine, which concluded in 2017 that the U.S. dietary guide­lines are not currently “trustworthy,” in part due to a “lack of scientific rigor” in the process.⁷ Since then, little has changed (the USDA did not fully adopt even one of the Academies’ eleven recommendations). In this light, advocating for even less rigorous standards based on even weaker evidence seems to me misguided or possibly reckless.

LOWER STANDARDS FOR REDUCING MEAT, POULTRY AND EGGS

Paradoxically, the expert committee was not a stickler for rigorous evidence when it came to advising reductions in meat, poultry and eggs.

Before getting into the evidence, though, I’d like to revisit the likelihood that these changes, if adopted, would exacerbate our dis­ease epidemics.⁸ This advice does 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 also 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 sugar.

The expert committee also found that re­ductions in meat, eggs and poultry would lead to further shortfalls in fiber and vitamins D and E, a significant fact given that the existing guidelines already fail to meet goals for vita­mins D and E, folate, choline and iron. Here are the committee’s findings on some of those nutrients announced at its final public meeting:

• For nutrients with an Estimated Average Requirement (EAR), less than 10 percent of simulated diets are inadequate (< EAR) for each nutrient except vitamins D and E.
• For nutrients with an Adequate Intake (AI), median nutrient content of the distribution of simulated diets is adequate (> AI) for alpha-linolenic acid, potassium and vitamin K, but falls short on choline and fiber for select age-sex groups and for linoleic acid for foods consumed in Alaska Native diets.

A lack of essential nutrients leads to a myriad of diseases and health conditions. One has to wonder why the long-standing nutritional deficien­cies in the guidelines haven’t been corrected—and are getting worse.

STUDIES CITED DO NOT SUPPORT EXPERT REPORT CLAIMS

Most importantly, the evidence used to support new and existing guidelines’ recommendations is insufficient and contradictory.

Three major USDA systematic reviews—on obesity,⁹ type 2 dia­betes¹⁰ and heart disease¹¹—list randomized, controlled clinical trials (RCTs) to support claims that the U.S. Dietary Guidelines can prevent these conditions in adults. These reviews are also cited to support the new recommendation for reducing red meat and processed meats. Yet the clinical trials listed do not support these claims. (In these reviews, “NS” is reported to mean “not statistically significant.” The word “null” means that the results do not support the hypothesis—in this case, that a Dietary Guidelines-type diet can prevent chronic diseases.)

Table 1 shows the trials listed for heart disease. As you can see, one trial shows cardiovascular benefit from red meat. Four trials show little-to-no benefit, and three are not trials but observational follow-up studies of trials published long ago. Another study was from 2017 and would have been covered in previous guidelines’ reviews. Altogether, zero of the trials listed unequivocally support the claim that the ability of the guidelines to prevent heart disease is “strong.”

The reviews on obesity and type 2 diabetes are much the same. For obesity, the expert committee graded the evidence as “moderate,” with twenty-four trials as support. Other trials did not appear to test a diet similar to the Dietary Guidelines. Among the twenty-four:

• Nine are reported to have “not statistically significant” results on health outcomes for obesity.
• One¹² was conducted by the animal rights group Physicians Committee for Responsible Medicine,¹³ and is, therefore, likely to be biased.
• Three^14-16 are incorrectly listed as clinical trials; these are follow-up observational studies to clinical trials published more than a decade ago.
• Seven appear to show weight-loss benefits for a diet more-or-less like the Dietary Guidelines. However, quite a few of these are hard to in­terpret, since the intervention diet reduced both red meat and sweets, so it’s not clear which of these dietary elements, or indeed the many others, might be responsible for the weight loss observed.

For type 2 diabetes, the committee graded the evidence as “strong” and listed thirteen trials. Of these:

• Ten are reported to have “not statistically significant” results on health outcomes for diabetes.
• Two,^17,18 incorrectly listed as clinical trials, are follow-up observational studies on the Women’s Health Initiative, which had its results pub­lished in 2006.
• A single trial¹⁹ appears to have shown some health benefits, but the outcomes aren’t clear (to me).

In sum, zero percent of the trials on heart disease (0/9), 29 percent on obesity (7/24) and 8 percent on type 2 diabetes (1/13) support the committee’s claims. Altogether, that’s eight out of forty-six trials or just 17 percent. Moreover, there are bound to be some mistakes in my lists; this summary is just a first take.

Here’s the point: every step in the process that produces reviews like these is broken. The USDA office that conducts the reviews lacks rigor (as the National Academies found); the expert advisory committee doesn’t appear to have checked the evidence; and the “peer review” process for the systematic reviews was completed by federal employees with a conflict of interest. (Reviewers who criticize the USDA report rightly fear that they would lose their jobs.)

LACK OF EVIDENCE IS NOTHING NEW

If you have followed my work, you know there is a history here. When I fact-checked every single study cited in the 2015 Dietary Guidelines for a BMJ cover story,²⁰ it triggered one of the largest retraction efforts²¹ in recent history—though it was ultimately unsuccess­ful.²² A key finding of my investigation was that the USDA-HHS dietary patterns were supported by “a minuscule quantity of rigorous evidence that only marginally supports claims that these diets can promote better health than alternatives.”

My BMJ paper has been largely ignored. Seven years later, in 2022, I teamed up with top nutritionists, including former members of previous Dietary Guidelines Advisory (DGA) Committees, to write a critical review of the guidelines that was published in a journal of the National Academies of Sciences.²³ USDA and HHS officials responded with an article titled, “Addressing misinformation about the Dietary Guidelines for Americans.”²⁴

I’m not a fan of the term “misinformation,” but with respect to non-evidence-based dietary advice, the USDA and HHS are prominent ac­tors. The National Academies and many peer- reviewed publications have now established the faulty evidence underpin­ning the U.S. Dietary Guidelines, in addition to the lack of transparency and many conflicts of interest in the guidelines process.

We do not need more evidence. We require only the political will to create change so that we might have a national dietary policy that we can trust—and the good health that we deserve.

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SIDEBAR

BUTTER IS NOT BACK!
The DGA committee has made it very clear that butter will not be back on the table—and by inference, not in school lunches either. Testimony presented on Day 1 (videocast.nih.gov/livew.asp?live=55078, around the four-hour mark) showed that adults and older adults drinking full-fat milk sustained no increased risk for cardiovascular disease compared to those drinking lowfat milk, but adults and older adults using spreads and oils instead of butter had lower LDL-cholesterol (evidence ranked strong) and lower cardiovascular morbidity (evidence ranked “limited”). Based on this scant and contradictory evidence, and ignoring the fact that experts no longer consider high LDL as a good cardiovascular risk factor, the committee declared emphatically, “Butter is not back!” But not a word about what substituting spreads for butter does for growing children or women wanting to get pregnant.

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REFERENCES

1. 2025 Dietary Guidelines Advisory Committee. Scientific Report of the 2025 Dietary Guidelines Advisory Committee: Advisory Report to the Secretary of Health and Human Services and Secretary of Agriculture. U.S. Department of Health and Human Services and U.S. Department of Agriculture, December 2024. https://www.dietaryguidelines.gov/sites/default/files/2024-12/Scientific_Report_of_the_2025_Dietary_Guidelines_Advi­sory_Committee_508c.pdf
2. Popli Nik. The power RFK Jr. would have over food. TIME, Dec. 6, 2024.
3. Mensendiek H. Report: Nearly half of Dietary Guidelines Advisory Committee have conflicts of interest. U.S. Right to Know, Oct. 4, 2023.
4. Teller M. Weight loss medical mayhem: decades of harm and hype. Wise Traditions. Fall 2023;24(3):37-43.
5. Nestle M. The Dietary Guidelines Advisory Committee releases its report. Food Politics, Dec. 17, 2024.
6. Cooney E. 5 questions about the next U.S. dietary guidelines, and the “impossible restric­tion” on them. STAT, Oct. 27, 2024.
7. National Academies of Sciences, Engineering, and Medicine. Redesigning the Process for Establishing the Dietary Guidelines for Americans. Washington, DC: The National Academies Press, 2017.
8. Teicholz N. Get ready to eat beans, peas, lentils—as cuts in meat, poultry, and eggs are proposed for next Dietary Guidelines. Unsettled Science, Nov. 8, 2024.
9. Hoelscher DM, Tobias D, Deierlein A, et al. Dietary patterns and growth, body compo­sition, and risk of obesity: a systematic review. U.S. Department of Agriculture, Food and Nutrition Service, Center for Nutrition Policy and Promotion, Nutrition Evidence Systematic Review, November 2024. https://nesr.usda.gov/sites/default/files/2024-12/Dietary-patterns_growth-obesity-2025DGACSystematicReview_0.pdf
10. Talegawkar S, Tobias D, Fung T, et al. Dietary patterns and risk of type 2 diabetes: a systematic review. U.S. Department of Agriculture, Food and Nutrition Service, Center for Nutrition Policy and Promotion, Nutrition Evidence Systematic Review, November 2024. https://nesr.usda.gov/sites/default/files/2024-12/Dietary-patterns_type-2-diabetes-2025DGACSystematicReview_0.pdf
11. Anderson CAM, Gardner C, Talegawkar S, et al. Dietary patterns and risk of cardiovas­cular disease: a systematic review. U.S. Department of Agriculture, Food and Nutrition Service, Center for Nutrition Policy and Promotion, Nutrition Evidence Systematic Review, November 2024. https://nesr.usda.gov/sites/default/files/2024-11/Dietary-pat­terns_cardiovascular-disease-2025DGACSystematicReview.pdf
12. Crosby L, Rembert E, Levin S, et al. Changes in food and nutrient intake and diet quality on a low-fat vegan diet are associated with changes in body weight, body composition, and insulin sensitivity in overweight adults: a randomized clinical trial. J Acad Nutr Diet. 2022 Oct;122(10):1922-1939.e0.
13. Physicians Committee for Responsible Medicine (PCRM). Activist Facts, n.d. https://www.activistfacts.com/organizations/23-physicians-committee-for-responsible-medicine/
14. Alvarez-Perez J, Sanchez-Villegas A, Diaz-Benitez EM, et al. Influence of a Mediterranean dietary pattern on body fat distribution: results of the PREDIMED-Canarias Intervention Randomized Trial. J Am Coll Nutr. 2016 Aug;35(6):568-580.
15. Casas R, Ribó-Coll M, Ros E, et al. Change to a healthy diet in people over 70 years old: the PREDIMED experi­ence. Eur J Nutr. 2022 Apr;61(3):1429-1444.
16. Van Horn L, Aragaki AK, Howard BV, et al. Eating pattern response to a low-fat diet intervention and cardio­vascular outcomes in normotensive women: the Women’s Health Initiative. Curr Dev Nutr. 2020 Mar;4(3):nzaa021.
17. Howard BV, Aragaki AK, Tinker LF, et al. A low-fat dietary pattern and diabetes: a secondary analysis from the Women’s Health Initiative Dietary Modification Trial. Diabetes Care. Apr 2018;41(4):680-687.
18. Prentice RL, Aragaki AK, Howard BV, et al. Low-fat di­etary pattern among postmenopausal women influences long-term cancer, cardiovascular disease, and diabetes outcomes. J Nutr. 2019 Sep 1;149(9):1565-1574.
19. Pavić E, Hadžiabdić MO, Mucalo I, et al. Effect of the Mediterranean diet in combination with exercise on metabolic syndrome parameters: 1-year randomized controlled trial. Int J Vitam Nutr Res. 2019 Sep;89(3- 4):132-143.
20. Teicholz N. The scientific report guiding the US dietary guidelines: is it scientific? BMJ. 2015 Sep 23;351:h4962. https://www.bmj.com/content/351/bmj.h4962
21. Liebman B. Rapid Response: Re: The scientific report guiding the US dietary guidelines: is it scientific? BMJ. 2015 Dec 17. https://www.bmj.com/content/351/bmj. h4962/rr-36
22. Godlee F. Rapid Response: outcome of post-publication review of article by Nina Teicholz. BMJ. 2016 Dec 1. https://www.bmj.com/content/351/bmj.h4962/rr-48
23. Achterberg C, Astrup A, Bier DM, King JC, Krauss RM, Teicholz N, Volek JS. An analysis of the recent US dietary guidelines process in light of its federal mandate and a National Academies report. PNAS Nexus. 2022 Jul 20;1(3):pgac107.
24. De Jesus JM, Stoody EE, DeSilva DM, et al. Address­ing misinformation about the Dietary Guidelines for Americans. Am J Clin Nutr. 2024 May;119(5):1101-1110.
25. Jeong SY, Wee CC, Kovell LC, et al. Effects of diet on 10-year atherosclerotic cardiovascular disease risk (from the DASH trial). Am J Cardiol. 2023 Jan 15;187:10-17.
26. Juraschek SP, Woodward M, Sacks FM, et al. Time course of change in blood pressure from sodium reduction and the DASH diet. Hypertension. 2017 Nov;70(5):923-929.
27. Krishnan S, Adams SH, Allen LH, et al. A randomized controlled-feeding trial based on the Dietary Guidelines for Americans on cardiometabolic health indexes. Am J Clin Nutr. 2018 Aug 1;108(2):266-278.
28. Schroeder N, Park YH, Kang MS, et al. A random­ized trial on the effects of 2010 Dietary Guidelines for Americans and Korean diet patterns on cardiovascular risk factors in overweight and obese adults. J Acad Nutr Diet. 2015 Jul;115(7):1083-1092.
29. Sidahmed E, Cornellier ML, Ren J, et al. Development of exchange lists for Mediterranean and Healthy Eating diets: implementation in an intervention trial. J Hum Nutr Diet. 2014 Oct;27(5):413-425.
30. Tussing-Humphreys L, Lamar M, McLeod A, et al. Effect of Mediterranean diet and Mediterranean diet plus calorie restriction on cognition, lifestyle, and cardiometabolic health: a randomized clinical trial. Prev Med Rep. 2022 Oct;29:101955.
31. Roussell MA, Hill AM, Gaugler TL, et al. Effects of a DASH-like diet containing lean beef on vascular health. J Hum Hypertens. 2014 Oct;28(10):600-605.

This article appeared in Wise Traditions in Food, Farming and the Healing Arts, the quarterly journal of the Weston A. Price Foundation, Spring 2025

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