This article appears in the March 2021 issue of Sugar Producer.

The Dietary Guidelines for Americans

Approximately every five years since 1980, the federal government has released the Dietary Guidelines for Americans (DGA). These guidelines, developed by the U.S. Departments of Agriculture (USDA) and Health and Human Services (HHS), are informed by a review of the available science on food and health by external (primarily academic) experts who make up the Dietary Guidelines Advisory Committee (DGAC).

The DGAs have a significant impact on U.S. food and agriculture, as they are the cornerstone of federal nutrition policy, including programs like school lunch, and serve as the authoritative dietary advice to the American public. Given their importance, it is critical they be derived using an objective and transparent approach to evaluate the strongest science. Yet this has not been the case for all the DGA recommendations over the course of their 40-year history — a history where controversy seems to arise, always questioning the strength of the science behind at least one of the recommendations.

Sugar Recommendations in Past DGAs

When it comes to sugar and added sugars, each version of the guidelines has included a general recommendation for Americans to moderate their consumption (i.e., “avoid too much sugar” in 1990; “reduce intake of calories from added sugars” in 2010). However, the 2015-20 DGAs were the first to quantify what moderation of intake of added sugars actually means, recommending Americans limit added sugars to no more than 10 percent of total calories per day (50 grams based on a 2,000-calorie diet). This recommendation was not based on any relationship between added sugars and health outcomes, but on food pattern modeling (a tool used to figure out how to meet all of your food group recommendations within calorie needs). Essentially, the premise for a 10 percent limit on calories from added sugars is that you only have so many calories to consume in a day, and once all of the calories to achieve your food group needs are accounted for, there are only so many calories left over. These “leftover” calories are how added sugars and fats recommendations are determined.

2020-25 Dietary Guidelines

Released Dec. 29, 2020, by USDA and HHS, the new guidelines emphasize that a healthy dietary pattern is not a rigid prescription, but rather a customizable framework of core elements. The 2020-25 DGAs suggest we “Make every bite count” by following these four guidelines:

1. Follow a healthy dietary pattern at every life stage
2. Customize and enjoy nutrient-dense food and beverage choices to reflect personal preferences, cultural traditions and budgetary considerations
3. Focus on meeting food group needs with nutrient-dense foods and beverages and stay within calorie limits
4. Limit foods and beverages higher in added sugars, saturated fat and sodium, and limit alcoholic beverages

Added Sugars Recommendation

Without completing its planned, comprehensive review of the scientific evidence, the 2020-25 DGAC recommended a reduction of the added sugars limit to 6 percent of total calories. This recommendation was based on the same food pattern modeling exercise employed in 2015, and not on new science related to any health outcomes — or any new science at all.

However, despite this strict and unprecedented (the lowest added sugars intake recorded in the U.S. is 11 percent in 1909) recommendation receiving a lot of noise over the summer, USDA and HHS sided with strong scientific evidence and maintained the recommendation of 10 percent. As stated by USDA and HHS in the press release announcing the new guidelines, “Dietary Guidelines for Americans, 2020-25, carried forward the committee’s emphasis on limiting these dietary components, but did not include changes to quantitative recommendations, as there was not a preponderance of evidence in the material the committee reviewed to support specific changes, as required by law.”

The 2020-25 DGAs give a little more context to the 10 percent recommendation, providing a visual representation of the food pattern modeling used to derive the added sugars limit: “Most of the calories a person needs to eat each day — around 85 percent — are needed to meet food group recommendations healthfully, in nutrient-dense forms. The remaining calories — around 15 percent— are calories available for other uses, including for added sugars or saturated fat beyond the small amounts found in nutrient-dense forms of food and beverages within the pattern, to consume more than the recommended amount of a food group, or for alcoholic beverages.” 

It is worth noting that added sugars consumption has declined significantly in the past two decades, falling more than 30 percent since 2000, while obesity rates increased more than 40 percent during the same period. The DGAC reported that average added sugars consumption is currently only 66 calories away from meeting the 10 percent recommendation.

Moving Forward

The flaws in the DGA process have weakened the credibility of the DGAs over time, damaging their ability to guide U.S. nutrition policy and reducing their value to the Americans who look to the DGA as the authoritative voice for healthy eating decisions. Concern over the credibility and trustworthiness of the process is evidenced by the 38,000 public comments on the Scientific Report of the DGAC, an increase of nearly 10,000 over the previous report.

While science prevailed this time in rejecting a more restrictive recommendation for added sugars that would have lacked scientific underpinning, it is apparent the DGA process lacks the consistency and scientific rigor that is expected and needed to ensure the federal government’s nutrition recommendations are based entirely and consistently on the use of credible science and strong scientific methodology.

We will continue to work with the federal agencies, nutrition experts and a wide array of stakeholders to seek meaningful reform of the DGA process, so that the recommendations are objective, transparent and reflective of the scientific evidence. Ultimately, this reform is necessary for the DGAs to be more trusted, more meaningful for consumers and more impactful toward achieving a healthy lifestyle for millions of Americans. Including the comments on the DGAC report, the Sugar Association submitted eight sets of public comments throughout the 2020-25 DGA process, as well as 11 studies for the DGAC to consider in their review. Ensuring science and facts about sugar are part of the policy and future conversations is essential to our mission.