WASHINGTON — Pragmatism, rigorous science and affordability are among considerations that should be front and center for the Dietary Guidelines Advisory Committee (DGAC), according to a range of industry and other groups.

Brief comments from dozens of organizations were submitted as video presentations or delivered live virtually for the third public meeting of the DGAC held Sept. 12-13. Directed to a panel of 18 committee members, commenters responded to scientific questions identified by the Department of Health and Human Services (HSS) together with the US Department of Agriculture (USDA). Every five years, a new edition of the Dietary Guidelines for Americans (DGA) is published by the HHS together with the USDA.

For the 2025 guidelines, the DGAC is examining a lengthy list of scientific questions to review refined from a series of questions the HHS and the USDA posed to the committee. The committee divided into subcommittees to conduct its evidence review.

“The questions focus on diet and health outcomes across the lifespan and examine the relationship between diet and the risk of overweight and obesity with a new emphasis on weight loss and weight maintenance and a question on ultra-processed foods,” according to the DGAC.

The committee will view its scientific questions through the lens of health equity with the intention that the next DGA recommendations will be relevant to a racially, ethnically, socioeconomically and culturally diverse population.

The DGAC will review the scientific evidence before submitting a report to the secretaries of USDA and HHS. The departments will consider advice from the committee’s report prior to crafting the next edition of the DGA.

While common concerns and views were expressed by many groups, disagreements were present, too. For instance, the dairy industry said discouraging intake of higher fat dairy products was not “in the best interest of public health.” A consumer group urged the DGAC not to “muddy the waters” by carving out an exception for higher saturated fat intake in certain cases.

The following are highlights from the brief comments submitted by a range of food industry and related groups.

International Dairy Foods Association

“Dairy should be part of healthy eating patterns for all Americans, at all life stages and with various dietary needs,” said Roberta Wagner, senior vice president for regulatory and scientific affairs at the International Dairy Foods Association (IDFA), in live comments.

“Deterring (dairy) intake due to fat level is not science-based nor is it in the best interest of public health” Wagner said, expressing concern at the 2020 DGA’s preference for low-fat and fat-free food options, especially as most people do not meet DGA recommendations for dairy.

Dairy products contain calcium, vitamin D and potassium, all of which were identified as under-consumed nutrients in the 2020 DGA, she said.

Eating dairy foods at a variety of fat levels is linked to reduced risk of chronic diseases, said Katie Brown, EdD, RDN, senior vice president at the National Dairy Council and head of its scientific, regulatory and nutrition affairs team.

“This suggests flexibility across a range of fat levels within energy limits to help close nutrient and health gaps,” Brown said.

She also highlighted low-lactose and lactose-free dairy products, noting that these products “fit into a variety of culturally appropriate eating patterns.”

Lactose-free milk can be found at 98% of US retail, making it a widely accessible option, Brown said.

American Frozen Food Institute

Nutritious, convenient and affordable products that reduce food waste are the mainstay of the frozen food sector, said Jennifer Norka, MPH, director of regulatory and scientific affairs at the American Frozen Food Institute (AFFI).

The AFFI addressed the scientific question on the relationship between consumption of ultra-processed foods (UPFs) and growth, body composition and risk of obesity. Norka cautioned against excluding foods based on assessments of nutrient density linked to added sugars, saturated fat and sodium.

“Exclusion of these foods causes misrepresentation of typical dietary patterns and may lead to future exclusion of nutritious food items that are common in American diets from reports and guidance documents,” she said.

American Heart Association

“Until there is stronger evidence from RCTs (randomized controlled trials)” as to whether food sources of saturated fat affect the risk of cardiovascular disease, “the American Heart Association (AHA) supports the current recommendation to replace foods high in saturated fats with foods higher in unsaturated fats,” said Maya Vadiveloo, PhD, RD, on behalf of the association.

Vadiveloo is an assistant professor of nutrition and health sciences in the department of nutrition and food sciences at the University of Rhode Island.

“To help consumers implement this recommendation, the guidelines should clearly specify commonly consumed foods high in saturated fats and suggest foods high in unsaturated fats as possible replacements,” she told the committee.

Center for Science and the Public Interest

“Science continues to support limiting the consumption of saturated fats to less than 10% of calories and replacing saturated fats with unsaturated fats,” said Catherine Cochran, a policy fellow at the Center for Science and the Public Interest.

She urged the committee to “not muddy this advice by carving out exceptions for individual food sources without convincing evidence from RCTs that a given food does not raise LDL cholesterol, a surrogate endpoint for CVD (cardiovascular disease).”