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HHSNonrulemakingHHS-OASH-2024-0017

Request for Public Comments on the Scientific Report of the 2025 Dietary Guidelines Advisory Committee

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National Cattlemen's Beef Association filings
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National Cattlemen's Beef Association filed 2 comments on this docket between Feb 24, 2025 and Feb 24, 2025. 86 other organizations filed here. The comment window closed 533d ago.

What National Cattlemen's Beef Association filed (2)

Feb 24, 2025· Comment from National Cattlemen's Beef Association, HHS-OASH-2024-0017, HHS-OASH-2024-0017-0001, 2024-29100· HHS-OASH-2024-0017-9142

Filed on regulations.gov — full text not in the inline record.

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Feb 24, 2025· Comment from National Cattlemen's Beef Association, a contractor to the Beef Checkoff, HHS-OASH-2024-0017, HHS-OASH-2024-0017-0001, 2024-29100· HHS-OASH-2024-0017-9060

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. Thank you for the opportunity to submit scientific evidence related to the translation of the Scientific Report of the 2025 Dietary Guidelines Advisory Committee (DGAC) into the 2025-2030 Dietary Guidelines for Americans (DGA). The 2025 DGAC has recommended that the 2025-2030 DGA provide only one dietary pattern, replacing all existing USDA Healthy Dietary Patterns for Americans 2 years and older, with a modified Healthy U.S.-Style Dietary Pattern referred to as the "Eat Healthy Your Way" pattern. • The "Eat Healthy Your Way" pattern replaces a portion of red meat at every calorie level, beginning at 2200 calories, regardless of age-sex group or life stage. • The rationale for this reduction is inconsistent with food and nutrient intake evidence as more Americans (43%) are below recommendations for Protein foods than are above (35%). Further, 52% of Americans are at or below recommendations for Meat, Poultry and Eggs. • In contrast, most Americans are underconsuming whole grains (98%), while overconsuming refined grains (77%) and added sugars (66%). Americans are further away from the recommended target for added sugar (~13% of energy vs target 10%) than for saturated fat intake (~11.5% of energy vs target 10%). • The DGAC recognized that bioavailability and bioaccessibility of nutrients will be compromised when food patterns substitute plant-based protein for meat and the nutrient profiles of beans, peas and lentils are not a calorically or nutritionally equivalent replacement for beef. Food pattern modeling evidence used to support substitution of beans, peas, and lentils for red meat focuses on absolute nutrient content, not accounting for nutrient bioavailability, and expands nutrient gaps of vulnerable age-sex and life stage groups that require caloric intake at or above 2200 calories. Reducing red meat while increasing plant-based protein puts our most vulnerable populations like women, infants and young children, teens and the aging at risk. • Beef helps nourish people at every life stage and advising Americans to cut back on meat, like beef, decreases intake of protein, essential amino acids, and several key nutrients including heme iron, which are insufficient in the diets of many Americans. • In concluding that red meat should be reduced in the "Eat Healthy Your Way" pattern, the 2025 DGAC did not include important red meat/beef studies, including randomized controlled trials, which are considered the gold standard in research, thus using an incomplete evidence base to make strong dietary intake recommendations that will impact the lives of countless Americans. The attached document provides scientific evidence and communication considerations addressing these challenges.

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Abstract

The Departments of Health and Human Services and Agriculture solicit written comments on the Scientific Report of the 2025 Dietary Guidelines Advisory Committee. Each edition of the Dietary Guidelines builds upon the preceding edition, with the scientific justification for revisions informed by the Scientific Report of the 2025 Dietary Guidelines Advisory Committee, Dietary Reference Intakes, existing Federal guidance and consideration of federal agency input and public comments. Once the final Scientific Report is published online, the public will have 60 days to provide written comments to HHS and USDA to inform the development of the next edition of the Dietary Guidelines for Americans. This public comment period closes on the 60th day at 11:59 p.m. ET.

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Co-filers (86)

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