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USDA-HHS Response to the National Academies of Sciences, Engineering, and Medicine: Using the Dietary Guidelines Advisory Committee’s Report to Develop the Dietary Guidelines for Americans, 2020-2025

In 2016, Congress directed the Secretary of Agriculture to engage the National Academies of Sciences, Engineering, and Medicine (National Academies) to conduct a comprehensive study of the process used to establish the Dietary Guidelines. 

The National Academies study culminated in two reports available on its website, one on the process for selecting the Dietary Guidelines Advisory Committee (the Committee) and another on the remaining aspects of the Dietary Guidelines development process. In both reports, the National Academies committee identified five values to improve the integrity of the process to develop credible and trustworthy guidelines. USDA and HHS support these values and worked diligently to ensure that these values were thoroughly integrated throughout the entire process to develop the Dietary Guidelines for Americans, 2020-2025:

  1. Enhance transparency
  2. Promote diversity of expertise and experience
  3. Support a deliberative process
  4. Manage biases and conflicts of interest
  5. Adopt state-of-the-art processes and methods

The reports included several recommendations related to the Committee, and you can see the Departments' responses to the two reports by visiting our National Academies of Sciences, Engineering and Medicine Study: Process to Update the Dietary Guidelines page.

The second report also included a recommendation related to writing the Dietary Guidelines: “Recommendation 2. The secretaries of USDA and HHS should provide the public with a clear explanation when the Dietary Guidelines for Americans omit or accept only parts of conclusions from the scientific report.”

USDA and HHS support this recommendation, which aligns with the value of transparency. Below is an explanation of how the agencies used the Committee’s report to develop the Dietary Guidelines for Americans, 2020-2025.

Response:

USDA and HHS greatly appreciate the expertise and experience of the 2020 Dietary Guidelines Advisory Committee, whose high-quality review of the science on key nutrition topics was transparently documented in their Scientific Report to the Departments. USDA and HHS developed the Dietary Guidelines for Americans, 2020-2025 by relying on the scientific advice in the Committee’s report, consultation with subject matter experts within Federal agencies, as well as comments from these agencies and from the public. 

Any revisions to previous editions of the Dietary Guidelines must have sufficient scientific justification, and by law, must be based on the preponderance of scientific and medical knowledge current at the time. The Dietary Guidelines for Americans, 2020-2025 includes nearly all of the science-based recommendations of the 2020 Dietary Guidelines Advisory Committee, including new dietary advice for infants and toddlers. 

For two topics – added sugars and alcoholic beverages – the Dietary Guidelines includes part, but not all, of the Committee’s advice. The Dietary Guidelines emphasizes the importance of limiting intakes of added sugars and alcoholic beverages, but does not include the changes to quantitative limits recommended by the Committee. The evidence that the Committee reviewed supports the need to continue to limit intakes of added sugars and alcoholic beverages to promote health and prevent disease. However, there was not a preponderance of evidence in the Committee’s review of studies since the 2015-2020 edition to substantiate changes to the quantitative limits for either added sugars or alcohol. Thus, the 2020-2025 edition underscores the importance of limiting added sugars and alcohol intake, and retains the quantitative limits from the 2015-2020 edition. USDA and HHS encourage more research on the relationship between added sugars and alcoholic beverages and health, and will continue to monitor the evidence on these topics.

Added Sugars
The Committee identified added sugars as a dietary component of public health concern for overconsumption, acknowledged that the “addition of sugars to foods or beverages provides energy, generally without contributing additional nutrient intake,” recommended that children under age 2 not consume added sugars, and for those age 2 years and older, recommended that, “less than 6 percent of energy from added sugars is more consistent with a dietary pattern that is nutritionally adequate while avoiding excess energy intake than is a pattern with less than 10 percent energy from added sugars.” Regarding the evidence review on added sugars and those ages 2 and older:

  • The Committee’s systematic reviews supported low intakes of added sugars, but the conclusion statements did not specify an amount of added sugars that was associated with health promotion or disease prevention. The conclusions were consistent with those of the 2015 Committee.
  • The Committee’s food pattern modeling exercise showed that after meeting food group needs with nutrient-dense choices, and assuming Americans split their intake of saturated fat and added sugars proportionally according to current intakes, about 6 percent of calories remain for added sugars for most calorie levels. In addition, the Committee acknowledged that the foods and beverages included in the modeling exercise to meet food group needs as part of a healthy dietary pattern had a small amount of added sugars (1.5-1.9 percent), and that individual diets may be able to accommodate higher or lower intakes of added sugars depending on other dietary choices made.

The Dietary Guidelines for Americans, 2020-2025 includes the Committee’s advice to identify added sugars as a dietary component to limit and supports limiting intake of foods and beverages high in added sugars, including sugar-sweetened beverages, desserts, and candy. And, the Dietary Guidelines includes the Committee’s advice on added sugars for infants and toddlers, recommending that those under 2 years of age avoid foods and beverages with added sugars. In addition, the Dietary Guidelines includes the patterns modeled by the Committee. However, after careful consideration of the totality of evidence presented by the Committee, the Dietary Guidelines for Americans, 2020-2025 retains the recommendation to limit intakes of added sugars to less than 10 percent of calories per day in the 2015-2020 Dietary Guidelines. The introduction of this quantitative recommendation was based on significant scientific agreement from data analysis, systematic reviews, and food pattern modeling, and largely, the science has not changed. According to food pattern modeling, the amount of calories available from added sugars varies depending on caloric needs. Most Americans have less than 8 percent of calories available for added sugars, including the added sugars inherent to a healthy dietary pattern. Individuals who need 2,000 or 2,800 calories per day have less than 7 percent, or less than 8 percent calories available for added sugars, respectively. Individuals who need more than 3,000 calories per day have 9 to 10 percent of calories available for added sugars. For those people who need higher calorie intakes per day, an upper limit of 10 percent of calories from added sugars may be consumed while still meeting food group recommendations in nutrient-dense forms. The 10 percent added sugars limit allows for flexibility in food choices over time but also requires careful planning.

Alcoholic Beverages
The Committee recommended that the Dietary Guidelines advise adults “not begin to drink alcohol or purposefully continue to drink because [they] think it will make [them] healthier,” add clarity that the limits apply to “days when alcohol is consumed,” and state that “drinking less is generally better for health than drinking more” at all levels of consumption. Finally, the Committee recommended that, “For those who drink alcohol, recommended limits are up to 1 drink per day for both women and men."

  • The Committee’s systematic review supported low intakes of alcohol; their conclusion statements did not specify an amount of alcohol that was associated with health promotion or disease prevention. 
  • The Committee was unable to conduct systematic reviews on cancer or cardiovascular disease. Their report noted emerging evidence that a limit of 1 drink in a day for men may decrease the risk for cancer and cardiovascular disease compared to higher levels of consumption.

The Dietary Guidelines for Americans, 2020-2025 includes the Committee’s advice that individuals not start drinking and states that drinking less is better for health than drinking more. However, after careful consideration of the totality of evidence the Committee reviewed, the Dietary Guidelines for Americans, 2020-2025 recommends men limit intake of alcohol to 2 drinks or less in a day. The emerging evidence noted in the Committee’s report does not reflect the preponderance of evidence at this time. The recommendation to limit intake to 2 drinks or less in a day for men is consistent with the 2015-2020 Dietary Guidelines and is supported by the preponderance of evidence. The Dietary Guidelines for Americans, 2020-2025 also acknowledges that emerging evidence suggests that even drinking within the recommended limits may increase the overall risk of death from various causes, such as from several types of cancer and some forms of cardiovascular disease and therefore, caution is recommended. Further, clarity was added by stating that limits are “in a day, on days when alcohol is consumed.” Additionally, the Dietary Guidelines acknowledges that heavy drinking should be avoided and describes how calories from alcoholic beverages should be considered – as they can easily contribute to excess calorie intakes.