New Dietary Guidelines May Portend Battle Over Certain Ingredients and Additives

Rainer:
The most interesting thing about these new Dietary Guidelines is that there’s such a departure from previous guidelines. There are pretty big turns that this document took compared to previous iterations, which tend to have a milder slope. This one is a pretty aggressive turn.

In my opinion, the level of change from the previous iteration to this one is relatively dramatic compared to any other transition between versions.

I think folks expected these Dietary Guidelines to target ultraprocessed foods, or use the term ultraprocessed foods, which is sometimes abbreviated as UPF. But the term UPF wasn’t used, even though this administration has referred to UPFs elsewhere, like on the FDA website. That was a bit of a surprise, and maybe a relief to some.

That said, when you look at the content of the Dietary Guidelines, the anti-UPF or anti-processed food language is pretty clear. The explicit targeting of FDA-approved additives as being not OK in the diet is really interesting and may be a preview of things we’re going to see coming down the pike from this HHS administration.

I’ve never seen the U.S. government say that non-nutritive sweeteners are not a good thing to have in the diet. That hasn’t gotten much press, and I think it’s one of the more interesting elements. I’ve never seen HHS or FDA say that non-nutritive sweeteners should be treated like added sugars, or that there’s essentially no place for them in a healthy diet.

Ultraprocessed Foods and the Food Pyramid Shift

Hanacek:
You mentioned the abrupt change. For folks who’ve been in the industry long enough, we’ve been through new Dietary Guidelines in the past. There were even jokes on TV shows about how they took the Food Pyramid and turned it upside down.

The last time they renovated the Dietary Guidelines, the changes were a lot less drastic. Those are my words, of course, but point taken.

Moving into ultraprocessed foods, UPFs are still a topic of debate. There are definitions out there, but they’re not consistent. Not everyone agrees on what qualifies as a UPF. Do these guidelines communicate anything more definitive about UPFs?

Rainer:
The imagery of the inversion of the Food Pyramid is dramatic. Now, the 2020 to 2025 Dietary Guidelines used MyPlate, which showed a pretty balanced distribution of proteins, fruits and vegetables and grains.

The new version of the Food Pyramid puts protein foods at the top, while grains and whole grains are at the bottom. That’s a dramatic shift. It’s hard to anticipate how the food industry will react, but the changes line up with consumer expectations and trends. Consumers have been favoring protein-heavy foods, minimally processed foods and natural claims for years.

If I were making grain-based products like breads, this is a significant shift. While the guidelines aren’t binding, they do influence government meal programs and school lunches. That process takes years, and we’re still implementing the last set of guidelines in school lunch programs. However, over time, there will be a shift in what’s considered acceptable or healthy in those settings based on this new framework.

Public Health and Consumer Trends

Hanacek:
Right, this isn’t like a light switch that turns on overnight. Do the guidelines address public health or nutrition concerns more effectively? Do they lean into any trends we maybe didn’t expect?

Rainer:
From a Make America Healthy Again or wellness industry standpoint, this messaging isn’t unexpected. It validates what we already see in popular culture and conceptions around healthy eating.

The beef industry is certainly stoked about these changes. Tallow typically hasn’t been considered healthy for decades, and now alternative fats high in saturated fat are being discussed more openly. That shift has been percolating on social media and with influencers for some time.

Whole-milk dairy is another example. Historically, agencies pushed low-fat or non-fat dairy. Now whole-milk products feel more aligned with consumer thinking. The guidelines still recommend keeping saturated fat below 10 percent of calories. It’s not clear how easy that will be if people lean into whole-fat dairy and red meat. Overall, though, this reflects where consumer thinking has been heading over the past five to 10 years.

Protein Everywhere

Hanacek:
One thing people have pointed out is the lack of obvious mention of plant protein, when protein consumption is clearly the trend right now.

Rainer:
Absolutely. I was at the Fancy Food Show in San Diego earlier this month, and protein is everywhere, in places we didn’t see it 10 years ago. Products like protein-fortified cereals show how much protein has made its way into nearly every meal and snack. That trend is being emphasized and validated by these new Dietary Guidelines.

What Food and Beverage Companies Should Do Next

Hanacek:
What should food and beverage companies be doing now to prepare or respond?

Rainer:
Many of the messages aren’t new. Reducing sodium and reducing added sugars have been a focus for years, and clean-label, more natural, less processed products remain priorities. What’s interesting is the softer stance on saturated fat. I’m not sure whether companies will pull back from low-fat products or experiment with higher saturated fat formulations.

FDA stopped demonizing fat about a decade ago when it updated the Nutrition Facts regulation and shifted focus toward sugar. Whether that leads to products like potato chips using higher saturated fat oils remains to be seen. Another major question is non-nutritive sweeteners. These additives are FDA-approved, and this is the first time I’ve seen a government agency seriously question their place in the diet. It’s unclear whether that leads to fewer zero-added-sugar products or reduced use of sweeteners like aspartame.

Looking Ahead: Regulation and Policy Implications

Hanacek:
Zooming out, what does this mean for future regulation and public health strategy?

Rainer:
The new Dietary Guidelines themselves are relatively brief, only 10 pages long compared to more than 160 pages in the previous version. They were released alongside a new site, realfood.gov, which includes appendices and scientific rationale.

Those materials question FDA-approved additives, including some FDA has already moved to delist, like Red 3. Others are mentioned, but I don’t know of any clear safety concerns for them based on existing science.

I see this as a preview of future action. There’s interest from Secretary Kennedy in limiting self-determined generally recognized as safe (GRAS) positions. Some of what’s been released suggests even long-approved additives could be reconsidered.

If there’s an aggressive push to limit these substances, it could significantly affect how processed foods are formulated going forward.