2025 Dietary Guidelines Advisory Committee

The Beef Checkoff is a producer- and importer-funded marketing and research program, which includes a significant commitment to supporting nutrition research to better understand beef's role in healthy diets. We appreciate the opportunity to share the attached evidence overview for the 2025 DGAC to reconsider the use of triglycerides as a surrogate endpoint for cardiovascular disease, due to the lack of evidence supporting a cause-and-effect relationship and lack of acceptance as a valid surrogate marker by the Food and Drug Administration, the American Heart Association, the American College of Cardiology/American Heart Association Task Force on Clinical Practice Guidelines and the Canadian Cardiovascular Society.

The Beef Checkoff is a producer- and importer-funded marketing and research program, which includes a significant commitment to supporting nutrition research to better understand beef's role in healthy diets. The attached evidence overview aims to 1) highlight the propensity for misclassification of meat and, in particular, beef in ultra-processed food (UPF) scoring systems, as demonstrated in recent discussions during Meeting 5 of the 2025 Dietary Guidelines Advisory Committee (DGAC); and 2) reiterate the need to follow best practices for categorization of red meat, to avoid evidence bias caused by exposure misclassification.

The Beef Checkoff is a producer- and importer-funded marketing and research program, which includes a significant commitment to supporting nutrition research to better understand beef's role in healthy diets. During the fifth meeting of the 2025 Dietary Guidelines Advisory Committee (DGAC) it was identified that the Meat, Poultry, and Eggs (MPE) subgroup can be reduced by 4 ounces or more depending on life stage. The MPE subgroup has contributed high quality protein and bioavailable micronutrients to the Healthy U.S. Style (HUSS) dietary pattern for decades. Modifying the existing HUSS dietary pattern to reduce the contribution of MPE exacerbates existing nutrient gaps in the pattern and introduces additional shortfalls. While the HUSS pattern retains flexibility to make MPE choices based on preference, budget, and culture, the nutrient gaps resulting from reduced MPE amounts constrains this flexibility based on a necessity to compensate for new shortfalls and continued need to meet nutrient goals. This reduction therefore impacts a significant majority of Americans who consume meat regularly as part of a healthy, balanced diet that supports their family's health while staying within their budget constraints. Given that higher protein patterns can be modeled, and are sought after by many Americans, why has only a reduction in MPE been modeled by the 2025 Dietary Guidelines Advisory Committee?

The Beef Checkoff is a producer- and importer-funded marketing and research program, which includes a significant commitment to supporting nutrition research to better understand beef's role in healthy diets. During the recent Meeting 5 of the 2025 Dietary Guidelines Advisory Committee (DGAC), the contribution of the "burgers and sandwiches" category to specific food groups was discussed. Despite prior acknowledgement by the 2020 DGAC in their Scientific Report that "burgers and sandwiches" are "…an integral part of the American food context and culture" and as such, "…burgers and sandwiches could become a major way to increase the consumption of many food components and nutrients that are currently underconsumed", the current DGAC's discussion of this evidence was positioned as continuing the trend of an "unhealthy food environment". For many Americans, sandwiches, including burgers, represent a convenient and economical way to increase consumption of many underconsumed food groups and nutrients across life stages. The 2020 DGAC reported that "burgers and sandwiches" were a top source of total vegetable, protein, dairy and fortified soy, and total grains (including both refined and whole grains) intake. We appreciate the opportunity to share the attached evidence overview for the 2025 DGAC to consider recognizing the popularity of "sandwiches, including burgers" and the opportunity to use this popular food category to improve the nutrient intake of Americans. It is important to provide Americans with evidence-based guidance for how to practically improve the quality of sandwiches to enhance the positive role they can play in realistic, healthy diets.

The Beef Checkoff is a producer- and importer-funded marketing and research program, which invests in supporting nutrition research to better understand beef's role in healthy diets. The attached evidence overview assesses the eligibility criteria for systematic review protocols evaluating "Food Sources of Saturated Fat and Risk of Cardiovascular Disease" and the Dietary Pattern protocols (e.g. "Dietary Patterns and Risk of Cardiovascular Disease"). Eligibility criteria for systematic review protocols provide an objective, consistent, and transparent framework for determining which research studies will be included in the systematic review to ensure that the most relevant and appropriate body of evidence is identified for the systematic review question. However, our recent review of the noted systematic review protocols raised some questions on the eligibility criteria of the protocols, including lacking objectiveness in the intervention/exposure and comparator criteria, lack of consistency of criteria between the "Food Sources of Saturated Fat and Risk of Cardiovascular Disease" and the Dietary Pattern protocols, and lack of transparency of revisions to protocols that remove previously qualified studies from the evidence base without providing justification. We appreciate the opportunity to share the attached evidence overview on the eligibility criteria for cardiovascular disease related systematic review protocols.

The Beef Checkoff is a producer- and importer-funded marketing and research program, which includes a significant commitment to supporting nutrition research to better understand beef's role in healthy diets. The 2025 Dietary Guidelines Advisory Committee (2025 DGAC) shared several draft conclusion statements focused on growth, body composition, and risk of obesity either in the context of collective dietary patterns or as related to specific dietary pattern components, including milk, at Meeting 4. Based on the information shared via protocols and during Meeting 4, it appears that the 2025 DGAC has elected to consider milk as an independent dietary pattern component rather than an integrated dietary pattern component. While the rationale for this approach has not been provided, the 2020 Dietary Patterns Subcommittee previously noted that the consistency of evidence regarding dairy food components was of concern (i.e. exposure misclassification) with low-fat dairy, which subsequently can affect the strength of evidence for dairy as a specific component in dietary patterns. We also note that for the majority of 2025 DGAC systematic reviews regarding milk intake as an independent dietary pattern component in the dietary patterns across life stages conclusion statements and grades could not be assigned or were "limited" due to "substantial concerns" regarding directness, consistency, and risk of bias in the evidence base and "highly variable" "exposure and comparator definitions" in observational studies. It would be helpful if the 2025 DGAC can clarify the modification to their collective dietary pattern draft conclusion statement for growth, body composition, and risk of obesity for adults and older adults that omits "low-fat dairy". Given that red meat, including beef, has been similarly documented by past DGACs to be at high risk for misclassification, it will be informative if the 2025 DGAC provides insight as to why this method of evaluation for milk has been implemented. The attached comment provides an evidence overview of the lack of precision regarding meat in dietary pattern indices and scores, demonstrating the current use of the phrase "lower in meats (including red and processed meats)" in draft conclusions may not be accurate, thus lessening the strength of evidence. For example, the use of the term "red and processed" has the potential to overestimate total red meat consumption, underestimate total poultry consumption and does not distinguish fresh red meat or lean red meat. It will also be useful to know if the evaluation of all foods in dietary patterns at high risk of misclassification, such as beef, will also be evaluated as independent dietary pattern components by future DGACs.

The Beef Checkoff is a producer- and importer-funded marketing and research program, which includes a significant commitment to supporting nutrition research to better understand beef's role in healthy diets. During the public comment period regarding proposed scientific research questions for the 2025 Dietary Guidelines Advisory Committee, the Beef Checkoff provided evidence to USDA and HHS related to the question regarding the relationship between ultra-processed foods and health outcomes as "…the scientific evidence does not appear sufficient to answer the question" (https://www.regulations.gov/comment/HHS-OASH-2022-0005-0525). Specifically, such a review is limited by the lack of a consensus definition for ultra-processed foods, which increases confusion during the review of available evidence and increases the opportunity for misclassification of foods. We recently co-authored a letter to the editor published in the Journal of Nutrition (Van Elswyk ME, Gifford CL, McNeill SH. NOVA Classification: Another opportunity for misclassification of meat. J Nutr. 2024. doi: 10.1016/j.tjnut.2023.12.052. Open access available at https://authors.elsevier.com/a/1if-q54l%7ESZNG until April 17, 2024), specifically illustrating how the application of NOVA to meat provides an opportunity for misclassification of meat and complicates the interpretation of observational evidence regarding meat intake and disease risk. Clarification of nuances introduced by NOVA categorization when applied to foods consumed in the United States, particularly meat, and alignment of NOVA criteria with food and labeling regulation and processing guidance will be of critical importance if the 2025 Dietary Guidelines Advisory Committee moves forward with dietary guidelines for ultra-processed foods.

The Beef Checkoff is a producer- and importer-funded marketing and research program, which includes a significant commitment to supporting nutrition research to better understand beef's role in healthy diets across the lifespan. Adolescence is a time of transformative change with the onset of puberty, marked by a period of accelerated growth and development in height, weight, bone density, and brain function and structure. However, the gap between nutrient recommendations and actual intakes widens during adolescence and is largest for those ages 14-18 years-- putting adolescents at an increased risk of nutrient inadequacy. The 2020-2025 Dietary Guidelines for Americans notes that among adolescents, "[t]he potential for nutrient deficiencies existing alongside underconsumption of nutrients of public health concern for all Americans creates a concerning constellation of nutritional risks at a time of rapid growth and development along with the onset of puberty, menarche, and hormonal changes". Nutrient deficiencies during this life stage can lead to delayed physical development, poor academic performance, and depressed immune function, as well as have dire long-term consequences on overall health into adulthood. As the 2025 DGAC aims to build upon the current DGA and examine new scientific evidence, the Beef Checkoff offers evidence outlining the critical need to address nutrient deficiencies and dietary behaviors among adolescents.

The Beef Checkoff is a producer- and importer-funded marketing and research program, which includes a significant commitment to supporting nutrition research to better understand beef's role in healthy diets. We would like to congratulate Subcommittee 2 for completing the first of many systematic review protocols underway by the 2025 Dietary Guidelines Advisory Committee. We recognize the focus, dedication, and expertise required to conduct a systematic review and synthesize evidence while adhering to best practices. During Meeting 3, Subcommittee 2 presented draft conclusion statements and grades, justified by detailed information regarding the five NESR grading elements (i.e., consistency, precision, directness, generalizability, and risk of bias). The current NESR methodology manual indicates that, "The first level of screening is done using only the title of each article" rather than by the conventional first level screening approach of title and abstract (Ti+Ab). The Beef Checkoff is providing additional evidence relevant to the potential for eligible studies to be erroneously excluded during title-only (Ti/O) screening by highlighting a recently published case study that compared the relative screening performance of Ti/O versus Ti+Ab (Teo et al, 2023. Systematic Reviews). The authors concluded that based on this case study, Ti+Ab is a more reliable screening method compared to Ti/O. Failure to synthesize the totality of relevant evidence can result in evidence selection bias and potentially lead to inaccurate conclusions. Please see attached evidence overview for additional information a relevant to screening methodology best practices as the 2025 Dietary Guidelines Advisory Committee continues to conduct their systematic reviews.

The Beef Checkoff appreciates the opportunity to review and provide evidence relevant to the recently released food pattern modeling protocols intended for use by the 2025 Dietary Guidelines Advisory Committee (DGAC). The Beef Checkoff is a producer- and importer-funded marketing and research program, which includes a significant commitment to supporting nutrition research to better understand beef's role in healthy diets. In accordance with this commitment, we are providing additional evidence relevant to the rationale for the modification of the Protein Foods Groups and Subgroups (PFGS) in the Healthy U.S.-Style (HUSS) Dietary Pattern and Healthy Vegetarian (H-VEG) Dietary Pattern as outlined in the 2025 DGAC protein food pattern modeling protocol. The rationale provided in the protocol include: 2020 DGAC conclusions graded as "strong or moderate" that "dietary patterns relatively higher in red and/or processed meats" increase the risk of chronic disease; accommodation of cultural or religious norms, dietary preferences, budgetary considerations and other dietary restrictions; the growing popularity of "alternative dietary protein sources" among U.S. consumers; and to "expand and complement the work of the 2010 and 2020 Committees" to develop plant-based dietary patterns. In contrast, as detailed in the attachment, evidence regarding "red and processed meat" and association with disease risk from observational studies is weak, inconsistent, and challenging to interpret; evidence supports the need for dietary patterns higher in animal source foods (ASF) to decrease disease risk in vulnerable subpopulations; alternative dietary proteins are of limited popularity among U.S. consumers and, in fact, many across the socioeconomic spectrum strive to include, and prefer to consume beef in their usual diet; and all of the proposed PFGS plant-based dietary patterns aim to lower the contribution of ASF without compensation for decreased protein quality and micronutrient bioavailability, thus yielding marginally adequate diets rather than optimal dietary patterns.

The Beef Checkoff is a producer and importer funded marketing and research program, which includes a significant commitment to supporting nutrition research to better understand beef's role in healthy diets. The Beef Checkoff appreciates the opportunity to review the recent online posting of the majority of draft protocols to be used by the 2025 Dietary Guidelines Advisory Committee (DGAC) to answer the list of prioritized questions that focus on the relationship of diet and health across the lifespan. The 2025 DGAC will be supported by the USDA Nutrition Evidence Systematic Review (NESR) team's conducting of systematic reviews to examine the evidence. The NESR systematic review product is self-described as "a gold-standard evidence synthesis project that answers a nutrition question of public health importance using systematic, transparent, rigorous, and protocol-driven methods to search for, evaluate, synthesize, and grade the strength of the eligible body of evidence". One of the key tenets of the development of the Dietary Guidelines for Americans is representing the totality of the evidence. Regarding the systematic review to answer the scientific question, "What is the relationship between dietary patterns consumed and risk of cardiovascular disease (CVD)?", the published protocol notes that only studies with intervention length of 12 weeks or longer will be included. The exclusion of CVD related interventions that have a study duration of less than 12 weeks would ignore the high-quality evidence from controlled feeding trials, that are necessary to determine cause and-effect relationships between dietary intake and physiological or health outcomes, while minimizing potential confounding effects. Due to the nature of well-designed controlled feeding trials being challenging, expensive, resource and labor intensive to conduct, and substantial participant burden, the trials are usually shorter term, generally ranging from 4 to 12 weeks, especially when assessing CVD risk via intermediate markers of blood lipids (e.g. LDL cholesterol) and blood pressure. In fact, the FDA has stated for their evaluation of health claim petitions, that they consider 3 weeks to be the minimum duration for evaluating the effect of an intervention with various saturated fats on serum LDL cholesterol concentration. Making dietary recommendations that reflect the totality of evidence, to include responsiveness of intermediate markers of disease, is consistent with the goals of the DGAC. Presenting evidence that CVD health benefits can be achieved in one third the time (e.g., 4 weeks vs 12 weeks) could be meaningful for public health guidance. Please see attached evidence overview for more information about our request for consideration to revise the minimum 12-week study duration eligibility criteria for the evaluation of the relationship between dietary patterns consumed and risk of CVD.

The Beef Checkoff appreciates the opportunity to review the recent online posting of the majority of draft protocols to be used by the 2025 Dietary Guidelines Advisory Committee (DGAC) to answer the list of prioritized questions that focus on the relationship of diet and health across the lifespan. The Beef Checkoff is a producer- and importer-funded marketing and research program, which includes a significant commitment to supporting nutrition research to better understand beef's role in healthy diets. One of proposed Food Pattern Modeling protocols is designed to address whether changes should be made to the USDA Dietary Patterns and if additional dietary patterns should be developed to accommodate population norms, needs, preferences, and cultural foodways. This first publicly available protocol specifically explores the following question: "Should foods and beverages with lower nutrient density contribute to item clusters, representative foods, and therefore the nutrient profiles for each food group and subgroup used in modeling the USDA Dietary Patterns"? The protocol aims to identify lower nutrient dense foods in existing item clusters, eliminate their representative proportion from the item cluster composite, and further exclude their nutrient profile contribution from the overall weighted average nutrient profile used in food pattern modeling. Nutrient dense foods and beverage are defined as those providing "…vitamins, minerals, and other health-promoting components and have little added sugars, saturated fat, and sodium" in the 2020 Dietary Guidelines for Americans (DGA). While the protocol aims to identify foods "lower in nutrient density" and the DGA defines foods "high" in nutrients to limit, the protocol does not detail the specific criteria that will be used to identify a food "lower in nutrient density". Please see attached evidence overview for more information about our request for additional details of specific criteria used to identify a food "lower in nutrient density" in the currently available Food Pattern Modeling protocol.

The Beef Checkoff is a producer and importer funded marketing and research program, which includes a significant commitment to supporting nutrition research to better understand beef's role in healthy diets. The Beef Checkoff appreciates the opportunity to review the recent online posting of the majority of draft protocols developed with support from USDA Nutrition Evidence Systematic Review (NESR) to be used by the 2025 Dietary Guidelines Advisory Committee (DGAC) when answering the list of prioritized questions focused on the relationship of diet and health across the lifespan. The formatting and attention to detail in this initial posting of the DGAC protocols has made the process of reviewing more manageable and is much appreciated. In reviewing the protocols, it is noted that the full literature search will be "available upon request" and "fully documented in the final review". We understand that a "full literature search" involves several sequential steps including development of an electronic database search strategy, search results screening, and documentation of screening results to include the development of lists of included and excluded studies such that the "full literature search" cannot be made available until the review is complete. However, provision of at least one electronic search strategy at the outset of protocol registration is standard practice. Please see attached evidence overview for additional information about our request for unsolicited public posting of electronic database search strategies prior to the completion of DGAC systematic reviews protocols.

The Beef Checkoff is a producer and importer funded marketing and research program, which includes a significant commitment to supporting nutrition research to better understand beef's role in healthy diets. The Beef Checkoff appreciates the opportunity to review the recent online posting of the majority of draft protocols to be used by the 2025 Dietary Guidelines Advisory Committee (DGAC) to answer the list of prioritized questions that focus on the relationship of diet and health across the lifespan. The Departments of Health and Human Services (HHS) and Agriculture (USDA) have outlined specific criteria for the prioritization of scientific questions including relevance to the scope of the Dietary Guidelines for Americans (DGA), importance as regards to public health, potential impact to Federal programs; avoidance of duplication with existing or planned Federal guidance, and research availability. During Meeting 2 of the 2025 DGAC, it was noted that review of the relationship between dietary patterns and risk of sarcopenia will not be prioritized citing a "lack of research available to update the existing Nutrition Evidence Systematic Review (NESR) review" while a question regarding the role of dietary patterns in reducing the risk of depression would be prioritized noting federal and public stakeholder interest and research availability. Research availability is one of five 2025 DGAC research question prioritization criteria outlined by the Agencies. The existing NESR review from which the "lack of research availability" decision was made for risk of sarcopenia is based on a scaled down protocol implemented as a time saving measure by the 2020 DGAC, where intermediate functional outcomes were not included in the final protocol, and only disease endpoints of sarcopenia and severe sarcopenia were considered in their review of the evidence, reducing the amount and nature of the evidence used to answer the scientific question. The risk of sarcopenia is an important area of public health concern, estimated that 25–45% of U.S. older adults are living with sarcopenia, contributing to an increased risk of falls, reduced activities of daily living, and increased nursing home placement. The 2020 DGAC recognized the urgency around dietary recommendations to reduce sarcopenia risk noting that "Older adults may benefit from protein intakes above existing DRI recommendations given the high prevalence of sarcopenia and may have differential energy and nutrient needs based on presence of chronic disease, polypharmacy, changes in oral health and tooth loss, among a myriad of other potential factors that influence needs." In contrast, the prevalence of depression in the U.S. is estimated to be lower at 8 percent for the U.S. population ages 12 years and older in the NHANES 2007-2010 survey, 8.1% in those 20 and older in the NHANES 2013-2016 survey, reaching 14.4% during the COVID-19 pandemic. Previously, the 2015 DGAC were unable to draw strong conclusions regarding the role of dietary patterns and risk of depression due to evidence limitations, and the 2020 DGAC examined the association of reduced risk of depression and use of neurocognitive dietary supplements and also found either no or limited/insufficient evidence to support dietary recommendations. While depression is certainly an important public health issue, raising awareness that sarcopenia is as well requires a thorough and complete review of the evidence. With the 2025 DGAC solely relying on the evidence available from the existing abbreviated NESR sarcopenia systematic review as their justification to not prioritize the review of the association between dietary patterns and sarcopenia risk, the broader evidence base regarding this important public health challenge is disregarded and the Committee's deliberation limited to only one of five prioritization criteria. Given that the systematic review of dietary patterns and risk of sarcopenia was truncated in 2020, red…

The Beef Checkoff appreciates the opportunity to review the recent online posting of the majority of draft protocols to be used by the 2025 Dietary Guidelines Advisory Committee (DGAC) to answer the list of prioritized questions that focus on the relationship of diet and health across the lifespan. The Beef Checkoff is a producer- and importer-funded marketing and research program, which includes a significant commitment to supporting nutrition research to better understand beef's role in healthy diets. The protocol for the 2025 DGAC to evaluate the relationship between parental and caregiver feeding styles and practices during childhood and adolescence (<19 years of age) and the consumption of a dietary pattern better aligned with the Dietary Guidelines for Americans (DGA) was recently posted (https://nesr.usda.gov/sites/default/files/2023-05/2025-DGAC-Protocol-Parental-caregiver-feeding-practices-Diet-quality.pdf). The protocol outlines an analytic framework with outcomes that include the dietary intakes of selected specific foods groups: fruits, vegetables, whole grains and sugar sweetened beverages individually, in addition to being components of the Healthy Eating Index. During Meeting 2 of the 2025 DGAC, it was noted that these particular food groups were targeted because Subcommittee 2 recognized them as being under consumed by Americans and, in the case of sugar sweetened beverages, a source of overconsumed nutrients. As detailed in the attached evidence overview, based on this rationale of addressing under consumed food groups, the intake of the protein food group is also an appropriate outcome to explore independently during this life stage.

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Dietary Guidelines Advisory Committees (DGACs) consistently recognize the challenges associated with the interpretation and use of observational evidence to make and model dietary intake guidelines for meat. For example, the 2015 DGAC recognized "&hellip;lean meats were not consistently defined or handled similarly between studies&hellip;" The 2020 DGAC noted that "In identifying the dietary components, the Committee used the terminology in the papers evaluated and a limitation is that terms such as lean meat, red meat, processed meat were not always defined clearly or differentiated from each other. This type of specification is important for future work on dietary patterns." The 2020 DGAC went on to grade their conclusions regarding a dietary pattern characterized by "&hellip;lean meat or poultry&hellip;" yet "&hellip;relatively low in red and processed meat&hellip;" and all-cause mortality as "strong" despite acknowledging that "When information is limited or inconsistent, it is difficult to draw strong conclusions for what types and amounts of foods and beverages to consume or avoid, such as, "processed meat" vs "red and processed meat" vs "meat". More information would allow more detailed guidance to be developed." Lean meat, such as beef, is part of a healthy dietary pattern. A recently published analysis confirms that heterogeneity in meat food group terminology meaningfully alters U.S. population level intake estimates of red meat and poultry. In fact, misclassification of meat intake has been characterized as a degree sufficient to challenge reported associations between meat intake and chronic disease risk, particularly cancer and cardiovascular disease. Given limited and inconsistent evidence for meat food grouping noted above, coupled with the hypotheses that processed meat drives the positive association observed for "red and processed meat", clearly distinguishing individual meat types (e.g., not including red AND processed meat in the same category) in dietary patterns recommended by the Dietary Guidelines for Americans (DGA) reduces ambiguity recognized in current red meat advice. Distinguishing individual meat types is also important when DGA recommendations are intended to identify top food sources of key nutrients, such as iron, as not all lean meats are iron-rich. Efforts to clearly assess the quality of methods and specification of terminology used in the collection, analysis, and interpretation of evidence regarding meat food groups is consistent with the 2017 National Academy of Science and Engineering and Medicine Committee on Redesigning the Process for Establishing the DGA recommendations to ensure that dietary recommendations are robust and reliable. In accordance with these observations, the following study design and reporting elements are offered to support the formulation of high-quality, evidence-based dietary guidance, for meat types, including beef, in diets and dietary patterns: 1.Avoidance of Misclassification - Description of Meat Group Components and Related Nutrients 2.Dietary Assessment Methods that Reliably Measure Individual Meat Types 3.Detailed Scoring Information for Meat Components in Dietary Pattern Methodologies 4.Awareness that Processed Meat is not a Standardized Category in U.S. Food Data Reporting 5.Prioritization of Evidence from Randomized Controlled Study Designs Where Beef Types and Intakes are More Clearly Defined to Inform Recommendations for Meat