HHS and USDA Issue Dietary Guidelines for Americans, 2025-2030

Overview of the DGA 2025-2030

The U.S. Department of Health and Human Services (HHS) and U.S. Department of Agriculture (USDA) recently issued the Dietary Guidelines for Americans, 2025-2030.¹ The dietary guidelines are issued every five years and form the basis of federal nutrition programs such as national food assistance and school meal programs. The dietary guidelines are required by statute to be “based on the preponderance of the scientific and medical knowledge which is current at the time the report is prepared.”² While the new dietary guidelines include some longstanding recommendations from previous editions, the new guidelines also include many recommendations, including guidance discouraging the consumption of so-called “highly processed foods,” that represent a significant shift in federal nutrition policy. The new guidelines represent the latest action in the Trump administration's Make America Healthy Again strategy.³

Notably, the new dietary guidelines diverge from the recommendations of the Scientific Report of the 2025 Dietary Guidelines Advisory Committee (DGAC), the most recent scientific report of the DGAC, which was published in December 2024 prior to the Trump administration taking office and was open for a period of public comment.⁴ The DGAC is a committee of nutrition experts appointed by USDA and HHS tasked with reviewing the current body of science on key nutrition topics and developing a scientific report of its independent assessment of the evidence and recommendations for USDA and HHS in the agencies' development of the dietary guidelines. The new dietary guidelines identify “deficiencies” in the 2025 DGAC report, including the report's focus on nutrition policy from a “health equity” lens, which the new guidelines stated “constrained” the report's ability to “provide unbiased scientific assessment.” Instead, in an unprecedented move, USDA and HHS departed from the established scientific review process and convened a new panel of “scientific review authors” to conduct "supplemental scientific work," the results of which underpin the new dietary guidelines. The guidelines do not provide significant detail on how such “supplemental scientific work” was conducted or how it was incorporated into the guidelines.

The new dietary guidelines are broken into four key documents:

(1) Dietary Guidelines for Americans, 2025-2030⁵ (a nine-page consumer-facing document that contains the core dietary guidelines)

(2) Scientific Foundation for the Dietary Guidelines for Americans, 2025-2030⁶ (hereinafter the “Scientific Report”) (a 71-page document containing summaries of the priorities and scientific research that form the basis of the new guidelines)

(3) Scientific Foundation – Appendices⁷ (a 416-page document containing additional discussion of the priorities and scientific research that form the basis of the new guidelines, as well as copies of some published research)

(4) Daily Servings Guide⁸ (a short, consumer-facing document of daily food group serving recommendations by overall calorie intake)

In conjunction with the release of the new guidelines, HHS and USDA also unveiled a new inverted food pyramid designed to encourage consumption of “real food,” which recommends a dual focus on the categories of “protein, dairy, and healthy fats” (particularly from animal sources) and “vegetables and fruits” at the top of the inverted pyramid, with whole grains at the bottom of the inverted pyramid and a recommendation to choose whole grains while reducing consumption of “highly refined carbohydrates.”sup>9

Key Themes in the New Dietary Guidelines

While USDA and HHS have focused on highlighting major changes in the new dietary guidelines, many of the key recommendations have long been found in the dietary guidelines, including recommendations to consume vegetables, fruits, and whole grains and to limit consumption of added sugars, saturated fat, and sodium. At the same time, some recommendations represent either a shift in or escalation of federal nutrition policy. We discuss key themes in greater detail below.

“Highly Processed Foods”

The Scientific Report expressly acknowledges that there is “no consensus definition for highly processed or ultra-processed foods” and that a “joint USDA-U.S. Food and Drug Administration (FDA) effort to establish a uniform definition is underway.” Nevertheless, the new guidelines include recommendations to “significantly reduce” the consumption of supposed “highly processed foods” and broadly define “highly processed foods” for the purposes of “this report” – not for scientific purposes – as “any food, beverage, or engineered food-like item that is made primarily from substances extracted from foods (such as refined sugars, refined grains/starches, and refined oils) and/or containing industrially manufactured chemical additives.” Elsewhere in the guidelines, the agencies further define “highly processed foods” as foods that “tend to have” “refined grains and/or sugars,” “refined fats and oils,” and “long, complicated ingredient lists including chemical additives (e.g., artificial sweeteners, flavor enhancers, artificial colors, and emulsifiers).”

The recommendation to “significantly reduce” and “avoid” “highly processed foods” marks one area that is a major shift from previous dietary guidelines; the 2025 DGAC report characterized the evidence on “ultra-processed food” and bodyweight as “limited” and did not include specific recommendations other than further research. The new dietary guidelines take a different approach on appropriate review of the scientific evidence, stating, “[t]he guiding principles of the Dietary Guidelines for Americans, 2025–2030, are that minimally processed, naturally nutrient-dense foods are the standard for comparison and that high-quality, causal evidence is required before making recommendations that could favor consumption of highly processed foods.” In other words, the recommendation acknowledges that there is no causal evidence establishing that so-called “highly processed foods” are beneficial or that their consumption causes harm.

Importantly, the Scientific Report concedes numerous “Limitations and Evidence Gaps” in its discussion of “Highly Processed Foods.” In addition to the lack of a consensus definition for “highly processed” or “ultra-processed foods,” the Scientific Report ultimately acknowledges that the “majority of the evidence linking highly processed foods to adverse health consequences is therefore derived from non-randomized, uncontrolled studies, which can be subject to confounding due to healthy adherer bias, reverse causation, and other factors.” It also recognizes a lack of data on children and life-course stages and that overall, more research is needed.

“Chemical Additives”

Additionally, the new guidelines include extensive discussion of “chemical additives.” The guidelines recommend a “dramatic reduction” in “highly processed foods laden with refined carbohydrates, added sugars, excess sodium, unhealthy fats, and chemical additives.” The Scientific Report states, “[g]iven the large and growing number of chemical additives in the U.S. food supply . . . and historical context wherein it can take decades to attribute adverse health consequences to industrialized food ingredients, we anticipate that it will take many decades to fully appreciate the deleterious consequences of highly processed foods and ingredients.” The guidelines also focus on food packaging, stating, “[m]any processed convenience foods are packaged or heated in plastic packaging, films, and coatings that can migrate into foods prior to ingestion. Emerging evidence indicates that chemicals derived from food packaging materials can accumulate in human tissues, including atherosclerotic lesions, reproductive tissues, and brains. Additionally, an emerging but limited body of evidence links the accumulation of these compounds to adverse health consequences.”

The guidelines also include as an appendix a “non-exhaustive list of major chemical classes and representative examples of chemical food additives and food packaging contaminants.” The table includes substances such as certain preservatives, non-nutritive sweeteners, emulsifiers, certified colors, and food packaging materials. The agencies state that inclusion in the table “indicates presence or use in the food supply and does not imply adverse effects,” although elsewhere in the guidelines the agencies urge more research on “chemical additives” and highlight the “significant gaps” that remain in “our understanding of the long-term effects of dietary exposure to these chemicals and chronic diseases, especially when consumed in mixtures that are typically present in highly processed foods.” The table is reproduced below as an appendix.

Protein

The new guidelines recommend prioritizing protein intake at every meal (particularly animal protein), with suggested intake at 1.2 to 1.6 grams per kilogram (kg) of body weight per day (72 to 96 g protein per day for a 60 kg adult), an increase from the prior recommendation of 0.8 g per kg of body weight per day. The guidelines recommend consuming “meat with no or limited added sugars, refined carbohydrates or starches, or chemical additives.”

Added Sugars

The new guidelines include added sugars recommendations that build on and are stricter than recommendations in previous dietary guidelines. The previous dietary guidelines recommended consuming less than 10% of daily calories from added sugars starting at age 2 through adulthood, and avoiding added sugars entirely for infants and young children. The new dietary guidelines state, “[w]hile no amount of added sugars or non-nutritive sweeteners is recommended or considered part of a healthy or nutritious diet, one meal should contain no more than 10 grams of added sugars.” Additionally, the new guidelines state that added sugars should be avoided entirely during infancy and early-middle childhood (up to age 10).

At the same time, the Scientific Report notes several “important limitations” regarding the purported evidence linking concentrated sources of sugar and artificial sweeteners to adverse cardiometabolic and health endpoints, including that it is “not possible to definitively disentangle adverse health consequences due to sugars or artificial sweeteners from other chemicals that are often consumed together,” that “the majority” of the purported evidence is from non-randomized studies with potential for confounding, and that “further RCTs are needed to definitively determine whether replacement of sugars with artificial sweeteners has beneficial, harmful, or neutral metabolic and health effects.”

Whole Grains

The guidelines also include enhanced whole grains recommendations (2-4 servings per day) and encourage Americans to “significantly reduce” consumption of refined grains or “refined carbohydrates.” The guidelines do not address how such a recommendation could impact folic acid intake that has historically been addressed through FDA's fortification requirements for enriched (non-whole) grains. The Scientific Report also once again acknowledges several important limitations in the evidence cited and further research needs.

Saturated Fat

The new dietary guidelines encourage the consumption of “healthy” fats, with priority on “oils with essential fatty acids, such as olive oil,” as well as butter and beef tallow. Previous dietary guidelines discouraged the use of fats and oils higher in saturated fat like butter and recommended the use of canola, corn, olive, peanut, safflower, soybean, and sunflower oils. Unlike previous dietary guidelines, which encouraged the consumption of fat-free and low-fat dairy, the new guidelines encourage the consumption of full-fat dairy products, advising that Americans include full fat dairy options in their diet, while characterizing fat-free and low-fat dairy products as requiring a “suite of processed ingredients and manufactured chemicals” to “compensate for the loss of natural dairy fat.”

In discussing the purported evidence related to its recommendations and characterization of fat-free and low-fat dairy, the Scientific Report also notes that the studies demonstrate only “associations,” not causation, and that further research is needed to evaluate “whether nutrient-based labeling and health-claim criteria align with modern evidence on food processing and chronic-disease risk.”

Although the guidelines include an extensive critique of the scientific evidence supporting the benefits of replacing saturated fat with linoleic acid-rich oils, the new guidelines include the same saturated fat recommendation as the previous dietary guidelines – saturated fat consumption should not exceed 10% of total daily calories (for example, 200 and 250 calories from saturated fat when on a 2000 and 2500 calorie diet). A single meal that includes a serving of butter, whole milk, and ribeye steak (foods featured in the pyramid) would contain saturated fat and calorie levels, respectively, of 7 grams (65 calories), 4.5 grams (40 calories) and 7 grams (65 calories) and would represent 170 calories from saturated fat. The guidelines do not address how to stay within 10% of total calories from saturated fat when choosing foods highlighted in the guidelines such as red meat, butter, beef tallow, and full-fat dairy.

Alcohol

Finally, whereas the previous dietary guidelines recommended that alcohol consumption be limited to 1 drink or fewer per day for women and 2 drinks or fewer per day for men, the new guidelines recommend more generally that Americans “consume less alcohol for better overall health.”

Next Steps

The Dietary Guidelines for Americans form the foundation of federal nutrition programs such as the National School Lunch Program and Special Supplemental Nutrition Program for Women, Infants, and Children (WIC). USDA will likely begin implementing the recommendations of the new guidelines when it next revises the federal school nutrition standards, although revisions to the school nutrition standards require rulemaking and often take years to implement.

The guidelines also recommend additional areas for nutrition research, including research into the potential health effects of “highly processed foods,” the question of which dietary fats are most compatible with long-term health, the impact of certain protein sources (whole foods versus isolates) on health outcomes, and “cross cutting issues such as eating patterns and implementation strategies.” With respect to “highly processed foods,” the agencies note the “pressing need” for “harmonized definitions of processed foods” and “larger, longer randomized trials testing the effects of controlled alterations in different categories of processed foods, ingredients and specific chemical additives on biochemical, toxicological and clinical endpoints, including cardiometabolic and neurological diseases.”

It is unclear how the dietary guidelines will impact USDA's and FDA's ongoing efforts to develop a definition for “ultra-processed foods,” as well as the potential impact on state legislative efforts seeking to limit use of certain food ingredients, particularly in schools. It also remains to be seen whether the guidelines' substantial limit on the broadly defined “highly processed foods” can be feasibly implemented in schools and other federal nutrition programs.

We will continue to monitor regulatory and policy updates that are implemented as part of the Make America Healthy Again agenda. Please do not hesitate to contact us with questions on this or any other matter.

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