In a recent article, we discussed some of the key features of the newest edition of the dietary guidelines (2025–2030), including its recommendations for protein, full-fat dairy, processed foods, and alcohol. If you haven’t had a chance to read that article yet, now would be a great time to check it out.

As we wrote in that article, the guidelines are a mixed bag. Still, a lot more could be said of this mixed bag. In some ways, what the guidelines advise is only half the story. Judging them against previous iterations of the dietary guidelines is tricky; how we weigh the good against the bad is subjective. Moreover, for a fuller assessment of the updated guidelines and whether they represent progress in a larger context, we must consider the process by which they were formulated. And here, things get pretty messy.

In the past, if someone wanted more information about something contained in the dietary guidelines, they would be best directed toward the Dietary Guidelines Advisory Committee (DGAC) report. Likewise, criticism of the dietary guidelines would most likely be targeted at the DGAC, whose work is exactly what it sounds like: they create the advisory report, based on a lengthy scientific review, that is then finalized in the dietary guidelines. Their report represents years of work; although anyone can read the 421-page report, it is not specifically written with the layperson in mind. In theory, the layperson wouldn’t need to read the advisory report, because the most important information would generally be synthesized in the more accessible dietary guidelines.

Granted, it’s not always that simple. Discrepancies do sometimes exist between the DGAC and the final guidelines, but not necessarily to the extent that we are currently seeing. This time, along with the dietary guidelines, the departments of Health and Human Services (HHS) and Agriculture (USDA) released “The Scientific Foundation for the Dietary Guidelines for Americans,” a document outlining how the dietary guidelines deviate from the DGAC report.^[1]

Essentially, “The Scientific Foundation . . .” describes how the administration took the additional step of creating a new panel of expert reviewers, which conducted its own evidence review process. These experts “conducted rapid systematic reviews, umbrella reviews, and comprehensive literature syntheses.”^[1] Effectively, they came in at the end of the process and superseded much of the work of the DGAC. You might think this sounds counterproductive. Why would HHS and the USDA seemingly undermine the work of the DGAC, whose members are appointed by HHS and the USDA themselves? Because the DGAC appointments took place in January 2023, before the beginning of President Trump’s second term and the inauguration of the current secretaries for those departments.

What the dietary guidelines need more of are precisely what they claimed to provide at the time of their rollout: “a food culture rooted in health, science, transparency, and personal responsibility.”

Here is what the “Scientific Foundation” has to say about deviating from the usual process: “The American public deserves dietary guidance grounded in the best available science—free from ideological bias, institutional conflicts, or predetermined conclusions.” They allege that the DGAC report did not represent this high ideal primarily because of its focus on health equity. As an example, they describe how the DGAC report advocated for plant-based dietary patterns, “despite emerging evidence that calls these positions into question.”

Is this a fair characterization of the DGAC report? I don’t think so. After reading as much as possible from the DGAC report, my interpretation is that the administration is being disingenuous and reductive. Even if we were to agree unanimously that health equity should not factor into the dietary guidelines, a shift toward more plant-based sources of protein is supported by far more than a health equity argument; that so many proponents of plant-based nutrition do not prioritize health equity proves this fact. Clearly, there is a lot more going on here. Health equity serves as a red herring, distracting attention from the real issue, which, as I see it, is that HHS and the USDA seem remarkably reluctant to anger the animal foods industry.

I suspect some readers might wish that we could keep politics out of the conversation. I sympathize with that perspective, but this is exactly the problem: by heavily rewriting or dismissing recommendations from the DGAC report on the grounds of health equity and referring numerous times to the Trump Administration’s role in the final guidelines, the decision makers of HHS and the USDA make it impossible to disentangle politics from science. For better or worse, the research has been filtered through a political process.

Just how significant were the changes provided by the additional science review panel? Of fifty-six DGAC recommendations listed in the “Scientific Foundation,” thirty were not implemented in the final dietary guidelines (fourteen were implemented; twelve were partially implemented). In other words, these were not minor changes—only one out of every four DGAC recommendations were fully implemented in the final dietary guidelines.

This is not to say that the changes are inherently wrong or unjustified, or that the DGAC recommendations do not deserve the highest level of scrutiny. Of course they do. The DGAC is not exempt from criticism. And previous iterations of the dietary guidelines suggest that they need to be held accountable—their work should be questioned whenever necessary, on scientific grounds. This is one reason why the process includes a lengthy period for public comments (nearly twenty-two months).

The question, then, is whether the additional scientific review, seemingly conducted in a rush just before the end of the process, resulted in a less flawed, less biased, and more effective set of guidelines. Anyone can read all of these documents for themselves. If you are curious, I would encourage you to do so and to make your own assessment. Mine, for what it’s worth, is that the additional scientific review displays many of the hallmarks of what it claims to prevent: ideological bias, institutional conflicts, and predetermined conclusions.

The disclosures section is a good starting point. Here we can see that, not just one or two, but most of the authors disclose potential conflicts of interest. For example, the authors of the narrative review on the potential health risks of processed meats (Donald Layman and Heather Leidy) disclose numerous ties to the animal foods industry.^[1][2] Layman reports consulting fees from the National Cattlemen’s Beef Association and the National Dairy Council; Leidy reports grants from the National Cattlemen’s Beef Association, the National Pork Board, General Mills Bell Institute of Health and Nutrition, and Novo Nordisk. Leidy even sits on the advisory board of the National Pork Board. Are such experts really the best placed to conduct an abbreviated narrative review on the potential health risks of processed meats? They conclude: “Since there is a lack of experimental evidence, a specific amount should not be established at this time.”^[2]

(Read More: Does Industry Funding Affect Research Findings?)

The same pair conducted the review on “High-Quality, Nutrient-Dense Protein Foods,” in which they justify the recommendation of 1.2–1.6 grams of protein daily per kilogram of body weight.^[2] Their review focuses on weight management and nutrient adequacy (tellingly, it does not focus on heart disease, stroke, cancer, etc.) and concludes, “These analyses provide convincing evidence refuting the recommendations to limit red meat as part of a healthy dietary pattern.”

These examples only scratch the surface: many curious affiliations with the meat and dairy industries are listed in the disclosures section. I wonder: If it were not for this constellation of influence, would the final dietary guidelines list “vegetarians and vegans” as a special population, just beneath older adults and individuals with chronic disease, as if to suggest that plant-based diets require very careful planning? If this panel of experts were unencumbered by conflicts of interest, would plant-based diets still be framed in a language meant to instill fear?

The guidelines advise vegetarians and vegans to “pay careful attention to potential nutrient gaps.”^[3] But shouldn’t everyone pay attention to potential nutrient gaps? The evidence suggests so. A vast majority of the US population (around 95 percent as of 2017) is deficient in fiber.^[4][5] The prevalence of hypokalemia (low potassium levels in the blood) has increased at an alarming rate in recent decades.^[6] One study found that popular diets, including the Atkins for Life and South Beach diets, are deficient not only in a few but in most micronutrients.^[7] Why are these potential nutrient gaps not highlighted in the dietary guidelines? (The word fiber appears only twice in the guidelines, and neither time does it address our epidemic deficiency; the difference between this and how protein is discussed is night and day.) More importantly, why are none of the countless documented benefits of plant-based diets included?

If you are curious to step further into this morass, I would encourage you to read the narrative review on vegetarian and vegan diets in the “Appendices of the Scientific Foundation,” which we will analyze more closely in a future article.^[2] I doubt the meat and dairy industry could have hoped for a more favorable report.

Moving Forward, How Can We Do a Better Job?

What the dietary guidelines need more of are precisely what they claimed to provide at the time of their rollout: “a food culture rooted in health, science, transparency, and personal responsibility.”^[8][9] Funnily enough, this exact wording has been removed from realfood.gov since the launch of the dietary guidelines. But let’s assume these are still priorities. What do we take it to mean?

It means—or at least should mean—fewer experts paid by industries that have an interest in distorting the recommendations to favor their bottom line. It means moving beyond highly politicized and inconsistent processes that too often seem to rely on cherry-picking data. As for personal responsibility, I am sure most of us can agree on this as an ideal. But unless people are empowered to access the best available evidence, can we really expect them to make smart choices for themselves and their families? Absent a far better set of guidelines, personal responsibility sounds like just another deflection. If we want to advance beyond the world of pretend to achieve practical change, powerful decision-makers should themselves begin taking some personal responsibility.

References

1. US Department of Health and Human Services (HHS) and US Department of Agriculture (USDA). The scientific foundation for the dietary guidelines for Americans, 2025–2030. January 2026. https://cdn.realfood.gov/Scientific%20Report_1.8.26.pdf
2. US Department of Health and Human Services (HHS) and US Department of Agriculture (USDA). The scientific foundation for the dietary guidelines for Americans, Appendices, 2025–2030. January 2026. https://cdn.realfood.gov/Scientific%20Report%20Appendices.pdf
3. US Department of Health and Human Services (HHS) and US Department of Agriculture (USDA). Dietary guidelines for Americans, 2025–2030. January 2026. https://cdn.realfood.gov/DGA.pdf
4. Quagliani D, Felt-Gunderson P. Closing America’s Fiber Intake Gap: Communication Strategies From a Food and Fiber Summit. Am J Lifestyle Med. 2016;11(1):80-85. Published 2016 Jul 7. doi:10.1177/1559827615588079
5. Lin B-H and Guthrie J. Over time, racial and ethnic gaps in dietary fiber consumption per 1,000 calories have widened. US Department of Agriculture (USDA) Economic Research Service. March 28, 2023. https://www.ers.usda.gov/data-products/charts-of-note/chart-detail?chartId=106189
6. Sun H, Weaver CM. Rising Trend of Hypokalemia Prevalence in the US Population and Possible Food Causes. J Am Coll Nutr. 2021;40(3):273-279. doi:10.1080/07315724.2020.1765893
7. Calton JB. Prevalence of micronutrient deficiency in popular diet plans. J Int Soc Sports Nutr. 2010;7:24. Published 2010 Jun 10. doi:10.1186/1550-2783-7-24
8. Realfood.gov. Accessed January 16, 2026. https://realfood.gov/
9. Nestle M. The MAHA dietary guidelines II: personal responsibility vs. public health policy. January 9, 2026. Food Politics [blog]. https://www.foodpolitics.com/2026/01/https-www-foodpolitics-com-2026-01-personal-responsibility-vs-public-health-policy/