Dietary Guidelines for Americans

Kristin Koegel, USDA Food and Nutrition Service
Center for Nutrition Policy and Promotion
3101 Park Center Drive, Suite 1034
Alexandria, VA 22302

Document Number: 2018-04058
Dietary Guidelines for Americans: Request for Comments on Topics and Questions

March 28, 2018

Thank you for the opportunity to provide comments on the topics and questions to be addressed by the 2020-2025 Dietary Guidelines Scientific Advisory Committee. On behalf of our 58,000-member owners, we are writing to comment on three proposed topics, and suggest one new topic for consideration in the development of the 2020-2025 Dietary Guidelines for Americans.

Added Sugars

We encourage the USDA to reconsider the Added Sugar recommendation of 10 percent total caloric intake, established in the 2015 Dietary Guidelines for Americans (DGA), and to consider replacing it with the 5 percent of total calories recommendation endorsed by the American Heart Association and the World Health Organization 1,2. Added sugar consumption is associated with poor diet quality, as consumption of added sugars displaces nutrient dense foods and leads to overconsumption of empty calories 3.

The American Heart Association (AHA) recommends children should eat less than 25 grams of added sugar daily, as added sugars increase the risk for obesity and hypertension in children 4. This 25g/day guideline should become the upper limit for added sugars for both children and adults, and would be equivalent to the 5 percent of total caloric intake (based on a 2000 calorie diet) advocated by the AHA and WHO for optimal health benefits.

Saturated Fats

We encourage a revision of the current saturated fat recommendation and suggest moving saturated fat off the list of “nutrients of concern” in the 2020-2025 Guidelines.

Most Americans already are very close to the 2015 Dietary Guidelines for Americans (DGA) recommendation to limit saturated fat to less than 10 percent of calories. According to the American Heart Association’s 2017 advisory on Dietary Fats and Cardiovascular Disease:

“The average intake of saturated fat in adults in the United States is 11 percent of total daily energy intake”5

This demonstrates that saturated fat is no longer a primary nutrient of concern for the general population. Reducing this emphasis on saturated fat in the 2020 DGA will help encourage consumption of wholesome high-fat foods, including whole milk dairy products, which have a different fatty acid profile than meat and other animal products, as well as differential impacts on health 6,7.

We also encourage the USDA to consider research showing not all saturated fats have the same impacts on blood lipids. Research published in the British Medical Journal 8 found that consumption of 3-4 tablespoons of organic, extra-virgin coconut oil raised “good” HDL cholesterol more than extra virgin olive oil, and did not raise “bad” LDL cholesterol when compared to butter, which did raise LDL.

It is clear that not all saturated fatty acids have the same impact on blood lipids and, therefore, the blanket recommendation to limit intake of all saturated fats should be re-evaluated.

Plant-Based Diets

We encourage the USDA specifically to acknowledge a Plant-Based Diet as an example of a healthy dietary plan. A plant-based diet does not have to be a completely vegetarian diet, instead it emphasizes plant foods as the focal point of each meal. Plant-based diets should emphasize a variety of whole grains, vegetables, fruits, nuts/legumes over refined grains, sweetened beverages, fried foods and sweets.

Evidence continues to accumulate a wide range of health benefits from a plant-based diet 9. Plantbased diets are less restrictive and easier to follow than strict vegetarian/vegan diets. The American Institute for Cancer Research emphasizes plant-based diets as a key dietary strategy for cancer prevention because:

“Basing our diets on plant foods (like vegetables, fruits, whole grains and legumes such as beans), which contain fiber and other nutrients, can reduce our risk of cancer.” (10)

Ultra-Processed Foods (new topic)

We encourage the DGA Scientific Committee to review new evidence on the health impacts of ultraprocessed food consumption and health and to consider emphasizing minimally processed foods over ultra-processed foods in the next edition of the DGA.

Ultra-processed food consumption is associated with an increased cancer risk 11, and poor dietary quality 12. Consumption of ultra-processed foods in the U.S. is associated with poor diet quality and researchers have concluded:

“Decreasing the dietary share of ultra-processed foods is a rational and effective way to improve the nutritional quality of US diets.” 13

Ultra-processed foods contain additives used to imitate sensorial qualities of unprocessed or minimally processed foods and these questionable ingredients (sweeteners, emulsifiers, flavoring agents) disguise undesirable qualities of the final product and promote overconsumption.

Ultra-processed foods are multi-ingredient packaged foods containing one or more ingredients that don’t pass the “kitchen test” – meaning the ingredient is not used in home cooking. The NOVA system of food classification is an example of an evidence-based method of classifying food based on the extent and purpose of food processing 14.

The Dietary Guidelines in Brazil already have been able to incorporate this information successfully 15, stating:

“minimally processed foods, of different types and in large varieties, and predominantly of plant origin, are the basis of healthy diets”

Thank you for the opportunity to comment on the upcoming 2020-2025 Dietary Guidelines for Americans. In addition to the specifics above, we also encourage the USDA to continue to acknowledge (as in the 2015 DGA) that:

“Everyone has a role in helping to create and support healthy eating patterns in places where we learn, work, live, and play.”

The responsibility for healthy eating habits should not be placed solely on individuals. Instead, we need to make continuous efforts to improve the food environment, to support healthy food choices for all Americans.


Nick Rose, M.S.
Nutrition Educator
PCC Community Markets
Seattle, WA


  1. American Heart Association. Dietary Sugars Intake and Cardiovascular Health: a scientific statement from the American Heart Association. Circulation 2009: 120(11).
  2. World Health Organization. Sugars intake for adults and children. 2015.
  3. American Heart Association. Children should eat less than 25 grams of added sugars daily: American Heart Association Scientific Statement. August 22, 2016.
  4. Louie et al. Association between intake of total vs added sugar on diet quality: a systematic review. Nutr Rev 2015:73(12).
  5. Sacks et al. Dietary Fats and Cardiovascular Disease: A Presidential Advisory from the American Heart Association. Circulation. 2017 Jul 18;136(3):e1-e23.
  6. Elwood et al. The consumption of milk and dairy foods and the incidence of vascular disease and diabetes: an overview of the evidence. Lipids. 2010;45(10):925-939.
  7. Drouin-Charier et al. Comprehensive Review of the Impact of Dairy Foods and Dairy Fat on Cardiometabolic Risk. Adv Nutr. 2016 Nov 15;7(6):1041-1051.
  8. Khat et al. Randomised trial of coconut oil, olive oil or butter on blood lipids and other cardiovascular risk factors in healthy men and women. BMJ Open. 2018 Mar 6;8(3):e020167.
  9. Tuso et al. A plant-based diet, atherogenesis, and coronary artery disease prevention. Perm J. 2015 Winter;19(1):62-7.
  10. American Institute for Cancer Research. Recommendations for cancer prevention. Available online at
  11. Fiolet et al. Consumption of ultra-processed foods and cancer risk: results from NutriNet-Santé prospective cohort. BMJ 2018;360:k322
  12. Monteiro et al. The UN Decade of Nutrition, the NOVA food classification and the trouble with ultra-processing. Public Health Nutr. 2018 Jan;21(1):5-17.
  13. Steele et al. The share of ultra-processed foods and the overall nutritional quality of diets in the US: evidence from a nationally representative cross-sectional study. Popul Health Metr. 2017 Feb 14;15(1):6.
  14. Martinez Steele et al. Ultra-processed foods and added sugars in the US diet: evidence from a nationally representative cross-sectional study. BMJ 2016;6(3).
  15. Ministry of Health Brazil. Dietary guidelines for the Brazilian population. 2014.

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