Architecture and options in the United States Dietary Guidelines 2025–2030

Given their importance, the 2025-2030 American Dietary Guidelines (DGA) warranted an immediate reaction from Marion Nestle, professor emerita at New York University, with decades of research and public involvement in the areas of food policy and systems, and one of the most influential voices in nutrition and public health in the United States, and the world, whose perspective we will also seek to incorporate here.

"Eat Real Food" and individual responsibility

The slogan “Eat Real Food” is presented in the DGA, especially in terms of communication, as a simple and mobilizing message.[1] Nestlé recognizes the positive appeal of this formulation, but underlines that it can be framed within a narrative centered on individual responsibility, to the detriment of a public health approach to transforming the food system.[2] And from this, several questions arise: is it possible to operationalize “eating real food” without ensuring the ecological, economic and political conditions that allow it to be produced and distributed sustainably? How to do so in a changing climate, with pollution, deforestation, loss of biodiversity, flooded crops and destroyed agricultural production? In its reflections, Nestlé[2] explains that a diet based on “real” food requires consistent public policies: agricultural subsidies directed towards food for human consumption, investment in school kitchens and culinary education, and equity measures that guarantee adequate income, time and infrastructure to prepare healthy food.[3]

Process, committee and governance

But Nestle also raises criticisms in areas concerning the processes, from the composition of the committee that establishes the recommendations (in previous editions, this committee was responsible for raising, beforehand, the scientific issues for review, which can then impact the establishment of the guidelines), to the perception of weaknesses in the process of developing the guidelines, the lack of a previously consolidated scientific consensus, and the transparent management of potential conflicts of interest. [4, 5]

Structure of dietary recommendations

Beyond the adoption of the “Eat Real Food” message, the DGA highlights the emphasis on “vegetables”, fruits, whole grains and the limitation of “highly processed” foods; it is a pity that for these foods, a single terminology that would be more conducive to consumer literacy was not adopted, such as that of Carlos Monteiro [6] – “ultra-processed” – and considerable controversy still remains around the definition of this group of foods, which is so important in terms of potential health effects. On the positive side, the DGA also mentions limiting the use of certain colorings, artificial sweeteners, flavorings and preservatives, and maintaining limits for “added sugars”, saturated fatty acids, and sodium. [4]

Furthermore, Nestlé points out that the DGA combines a positive message with internal inconsistencies and a pro-animal-based food bias that, as a whole, mixes priorities – for example, increased protein/meat and whole dairy products – with practical tensions: in this scenario, how to limit saturated fat to 10% of energy contribution? From the point of view of protein suppliers, the structural adjustment of food leads not to “less meat, more legumes”, but rather to “less refined cereals, more high-quality protein foods”, preserving the overall contribution of animal-based foods, which may challenge the goals set from the perspective of planetary health[7]. It is acknowledged that this global scenario of recommendations may have an impact on the (re)formulation of products, on the future food innovation strategy and on the evolution of the interpretation of what “healthy foods” are.

Cardiovascular perspective

In this context, and from the perspective of cardiovascular prevention, these guidelines are accused of, in some respects, doing the opposite of what was traditionally recommended; with regard to potential protein sources, for example, where the American Heart Association favored a protein pattern with a strong plant component, complemented by fish and low-fat dairy products, with careful selection of lean, unprocessed meats and replacement of animal fats (butter and lard) and tropical oils (such as coconut and palm) with liquid vegetable oils (olive oil, sunflower oil, corn oil and other polyunsaturated oils).[8]

When discussing foods of animal origin and cardiometabolic risk, the main founding document of the new DGA [9] is based on a methodologically important point, which is to seek to separate observational evidence from experimental evidence.

Among the works presented, a systematic review and meta-analysis of RCTs stands out, [10] on the intake of minimally or unprocessed beef (many studies mix red meat with processed meat), translating to an average beef intake of about 2 portions/day in the intervention group, compared with diets with no or less than 1 portion/day in the control group. There was no significant impact of beef intake on numerous cardiometabolic risk markers, but a small, statistically significant increase in LDL-C was observed, which disappeared when one of the studies was removed in the sensitivity analyses.

By citing Sanders et al.,[10] the committee[9] may be presenting the view that there is no robust experimental evidence to support the idea that the consumption of unprocessed beef, in itself, increases cardiometabolic risk, recognizing that discussing cardiometabolic risk requires distinguishing between food type, degree of processing and dietary pattern context. Obviously, food processing and preparation (frying at high temperatures, or grilling until burnt, for example) can also significantly modify the nutritional quality of proteins and their impact on health, through the formation of advanced glycation end products (AGEs), lipid peroxidation products, or through the ingestion of nitrates/nitrosamines, especially in processed meats. Again, the 10% limit on total energy contribution from saturated fatty acids will be a challenge in the context of the overall dietary pattern.

Plant vs. animal

The statement that nutritionally dense plant-based protein sources complement, but do not replace, the nutrients provided by animal-based protein sources [9] suggests in the DGA that exclusively plant-based standards may not fully reproduce the nutritional profile associated with animal-based foods. For vegetarians, this formulation may serve, above all, as a reminder that some of the nutritional advantages traditionally attributed to animal sources may depend on the contribution of eggs and dairy products or, alternatively, on fortification strategies and particularly careful meal planning.

Protein

The centrality given to “protein” in the DGA is pointed out by Nestle as possibly being interpreted, in practice, as an operational synonym for meat. [4] The author questions both the technical coherence of the proposed portions, and the need, in population terms, to promote increases in intake compared to current values, in order to obtain additional benefits [4, 11] highlighting that current consumption in the USA is already close to 1.2 g/kg/day – a value similar to that observed in Portugal [12]. She also adds an important criticism of an environmental nature, which she considers insufficiently reflected in the DGA, to which it is also important to associate the social and economic dimensions.

In the DGA (Dietary Reference Intakes), the quantitative protein intake target of between 1.2 and 1.6 g/kg/day, adjustable to individual energy needs, is above what is traditionally recommended for the general population. However, these values ​​in the DGA do not constitute a formal DRI (Dietary Reference Intake), just as the RDA/PRI (Recommended Dietary Allowance/Recommended Intake Principle) were never designed to represent a "functional optimum" or maximize muscle function. Their historical purpose was to establish a minimum safety threshold capable of preventing deficiency in almost the entire population. The proposal of higher intakes thus reflects a paradigm shift: from defining a preventive minimum to identifying a potential functional optimum, in light of emerging evidence suggesting benefits in preserving lean mass, regulating satiety, and controlling weight, particularly in contexts of metabolic risk or aging.

Presenting a range between 1.2 and 1.6 g/kg/day may lead to the perception of equivalent evidence across the entire spectrum. A more explicit link between dose and objective – functional maintenance in the elderly, preservation or gain of lean mass, weight control, or situations of risk of malnutrition – would allow these recommendations to be framed within a risk-benefit stratification framework, reinforcing the coherence of the public health message and its individual clinical suitability.

In a context of progressive demographic aging, both in the US and in Europe, the discussion about protein intake takes on particular relevance. Even so, European recommendations for the elderly are based on a more conservative minimum threshold than the functional range proposed in American guidelines, although they recognize that, at this stage of life, protein plays a crucial role in preserving muscle mass and function, autonomy, and functional capacity.

ESPEN, for example, recommends a protein intake in the elderly of at least 1 g/kg/day, which may be increased in the context of sarcopenia. [13] It also emphasizes the importance of adequate protein distribution throughout the day (25-30 g per meal) and a sufficient supply of leucine. However, the functional effectiveness of protein depends on adequate energy intake and its combination with resistance exercise. [14]

The eventual adoption of higher values ​​must be shown to be universally feasible and not entail increased risks, particularly in individuals with chronic kidney disease, a condition whose prevalence may be around 10% in the adult population and approach 44% in those over 65 years of age. [15] Furthermore, although a maximum tolerable level for protein has not been established, and there are studies suggesting metabolic safety even for intakes of at least 2.5 g/kg/day, [16] the absence of evidence of toxicity does not equate to universal net benefit — from a health and environmental point of view — if the ecological limits of the food system are not considered.

Future research should more closely reflect real-world practice, integrating sustainable food sources, strategies targeting aging populations and clinical settings, and approaches focused on minimally processed foods – in contrast to the predominance of studies based on protein isolates. It will also be important to delve deeper into determinants of protein requirements, such as energy balance, metabolic adaptation to habitual intake, criteria for assessing protein quality, [17] biological differences between sexes, the study of biological mechanisms associated with specific amino acids, such as the activation of mTOR signaling in immune cells, [18] and other contextual variables. [19]

Sodium

Regarding sodium (and salt), the difference between the American recommendation of less than 2300 mg/day of sodium, compared to the value of 2000 mg/day adopted by the WHO[20, 21] and EFSA[22], does not represent a huge numerical divergence, but reveals a distinct approach to the formulation of recommendations and the management of risk in public health. Maintaining a higher limit can introduce noise in health communication and diminish the perception of the magnitude of the problem.

Including exceptions – such as intense physical activity and sweat losses – and framing them at the population level could dilute the impact of the public health message, especially if it doesn't explicitly integrate the role of potassium (and the sodium/potassium molar ratio) and dietary patterns.

"Alcohol"

Nestle further criticises the ambiguity in the recommendation on “alcohol” (“limit”, “consume less”), arguing that the absence of explicit quantitative parameters weakens the intelligibility of public guidance (how much is, after all, “less”?) and obscures the centrality of the risk of multiple diseases.[23] Beyond the semantic divergence, the debate exposes substantial methodological differences between recent (since 2025) and very important reports, especially in the USA: the Surgeon General’s Advisory;[24] the National Academies review;[25] and the ICCPUD report[26].

The National Academies report [25] favors a structured synthesis of evidence approach, emphasizing methodological quality and bias control (namely “abstainer bias”), for example. The ICCPUD report [26] was mainly based on systematic reviews and meta-analyses of observational studies, and did not include data from quasi-experimental studies, such as Mendelian randomization (MR, a method that uses genetic variants associated with exposure – in this case, alcohol consumption – allowing the testing of causal relationships with less susceptibility to confounding and reverse causality), nor randomized clinical trials. In turn, the Surgeon General's Advisory,[24] while not an exhaustive review or a quantitative modeling exercise, adopts a public health logic oriented towards risk communication, emphasizing the causal evidence between alcohol and cancer even at low levels of consumption, focusing on the precautionary principle and mobilization for action.

Thus, the divergence lies not only in the conclusions, but also in the methodological architecture that underpins each report—from the type of studies included (observational vs. exclusion of trials or remote spectral studies in the case of ICCPUD), to the modeling of risk throughout life, to the communicational framework of risk. Since different methodologies produce distinct frameworks of risk, the selection of one of them reflects a choice regarding how risk should be interpreted and communicated to the population.

Globally, the methodology for assessing alcohol consumption has undergone transformations in its normative hierarchy: patterns that recommend avoiding or limiting alcohol may obtain the highest rating, while the recommendation for moderate consumption (as may occur in the Mediterranean diet) is classified as partially aligned. Thus, in this system, “moderation” is no longer treated as equivalent to “good practice”.[8] In elderly Portuguese people, we found that the association between adherence to the Mediterranean diet and cognitive performance depends on how wine consumption is assessed. When moderate consumption contributes positively to the score, no association with cognition is observed; when the criterion is reversed, valuing lower consumption or daily absence, a significant positive association emerges in a widely used cognitive screening instrument. Currently, the way of classifying “alcohol” consumption can substantially alter the interpretation of the benefits attributed to the Mediterranean pattern.[27]

Conclusion

If, as Nestle suggests, politics can “override” science in the formulation of the current Dietary Guidelines,[4] the response should not be merely reactive, but preventive. Inspired by Gonçalves and Boggio’s proposal – Is there a TRUMP brain?[28] which suggests evidence-based strategies to counter polarized thinking, perhaps the task of public health is precisely to recenter the debate on the integrity of processes, and on building a food system more consistent with the objectives of health and sustainability. Ultimately,[29] this is a collective responsibility, which requires leadership anchored in science and the creation of contexts that make healthy and sustainable choices as easy, accessible and socially valued as possible.

References

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