Janet M. de Jesus, MS, RD
Office of Disease Prevention and Health Promotion
1101 Wootton Parkway, Suite 420
Rockville, MD 20852

VIA ELECTRONIC SUBMISSION

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

Dear Ms. de Jesus:

Consumer Federation of America appreciates the opportunity to submit these comments on the next iteration of the Dietary Guidelines for Americans. Established in 1968 to advance the consumer interest through research, advocacy, and education, CFA represents over 250 non-profit consumer organizations who participate in the federation and govern it through their representatives on the organization’s Board of Directors. The next Dietary Guidelines have the potential to greatly improve public health, in particular by correcting the current Guidelines’ misleading treatment of food processing and alcohol. We address alcohol in separate comments.[1] We write here to urge the Departments’ leadership to define ultra-processed foods (UPFs) consistent with the NOVA classification system, to acknowledge the evidence linking UPFs to disease, and to advise consumers to limit UPFs in their diets, starting with UPFs that contain high levels of salt, sugar and fat.

Background

Diet-related disease unites Americans like few other issues. With 40.3% of adults,[2] and a heartbreaking 1 in 5 children,[3] now living with obesity, [4] few of us are not personally affected. Between 1999 and 2018, the percentage of children’s calories from UPFs increased from 61.4% to 67.0%, while the percentage of calories from unprocessed or minimally processed foods decreased from 28.8% to 23.5%. As CFA explained in previous comments to the DGAC,[5] and in its recent report “Ultra-processed Foods: Why They Matter and What to Do About It,”[6] policymakers cannot let uncertainty regarding the mechanisms by which UPFs cause disease foreclose meaningful action to reduce these products’ harms. That action must include reforming how the Dietary Guidelines address food processing.

The current Dietary Guidelines all but ignore food processing.

The current Dietary Guidelines send the misleading message that only macronutrients matter. They caution against eating two types of processed foods: “processed meats,” and foods high in “added sugars.” They also emphasize certain unprocessed foods, like “whole fruits,” as part of a “core” healthy diet. For children under two, they go so far as to say that “most fruit intake should come from eating whole fruit.”[7] In general, however, the current Guidelines direct consumers to eat “nutrient dense foods and beverages,” i.e. any foods or food products that contain “vitamins, minerals, and other health-promoting components and have no or little added sugars, saturated fat, and sodium.”

By failing to acknowledge food processing, the current Dietary Guidelines implicitly endorse diets high in UPFs. As USDA researchers have shown, a diet “with 91 percent of the calories coming from ultra-processed foods (as classified using the NOVA scale),” can meet the current DGA recommendations.[8] USDA touted this finding with the headline: “Scientists Build a Healthy Dietary Pattern Using Ultra-Processed Foods.”[9] But a more accurate summary would be: “Scientists Reveal Critical Deficiency in How Dietary Guidelines Define ‘Healthy’ Dietary Pattern.” This is because “healthy” dietary patterns depend on more than simply nutrients. Put another way, a diet that derives 91% of calories from UPFs is almost certainly not “healthy.”

 

High UPF diets are associated with disease.

Observational studies examining millions of individual’s diets and health outcomes leave no doubt that high UPF diets cause disease. These studies present “convincing and highly suggestive evidence” that eating more UPFs leads to increased risk of an earlier death, cardiovascular disease, overweight and obesity, type 2 diabetes, and “common mental health disorders” like anxiety, depression and insomnia.[10] UPFs appear to cause dementia, with a recent review of 10 observational studies that analyzed nearly 1 million participants’ diets and neurological disease finding that “[h]igh UPF consumption is associated with dementia,” even after adjusting for potentially confounding variables, and concluding that “measures to reduce overconsumption of UPFs are imperative to reduce the burden of dementia.”[11] UPFs appear to cause cancer, with a longitudinal analysis of nearly 200,000 UK Biobank participants, over 15,000 of whom developed cancer during the study period, concluding that every 10% increment in UPF consumption corresponded with a 6% increase in overall cancer mortality risk, a 16% increase in breast cancer mortality risk, and a 30% increase in ovarian cancer mortality risk.[12] And UPFs appear to cause inflammatory bowel disease (IBD), with a dose-response meta-analysis of studies involving over 4 million participants indicating “[h]igh intake of UPFs was linked with an enhanced IBD risk.”[13]

The evidence does not support the current Dietary Guidelines’ implicit endorsement of a high UPF diet.

The Scientific Report of the Dietary Guidelines Advisory Committee (DGAC), consistent with several members’ remarks during the DGAC’s deliberations, suggests that the association between UPFs and illness may simply reflect higher “saturated fat, sodium, and added sugars” content.[14] But researchers have controlled for macronutrient content, and the association persists.[15] Indeed, perhaps the most famous research study on UPFs, from NIH researcher Kevin Hall, involved carefully matching the macronutrient content of a high UPF and “unprocessed” control diet.[16] As with the original study, Hall’s follow-up research offers further evidence that high UPF diets contribute to overeating and adiposity.[17]

The DGAC Report also blames “inconsistencies” in how researchers define “ultra-processed” for its failure to offer any actionable advice on UPFs. But as one of the peer reviewers on the DGAC’s systematic review process has pointed out, the Committee included “numerous studies that did not appropriately or adequately define or assess UPF,” and so its conclusion that it could not evaluate UPF’s health impacts because of an inconsistent or inadequate UPF definition “demonstrated a circular and dismaying reasoning.”[18]

In fact, critics greatly exaggerate ambiguity in the UPF definition. The growing body of research on UPFs implicitly adopts the NOVA classification scheme. Researchers have operationalized that scheme in different ways depending on the available data.[19] However, a consensus approach defines UPFs on the basis of a food’s ingredients.[20] The few “edge cases” where an ingredient’s status is uncertain—e.g. does paprika become a “cosmetic additive” when used as a colorant?—pose little challenge to the broader trends connecting UPFs to disease. Data limitations, such as the lack of ingredient information in NHANES,[21] may prevent researchers from estimating UPF content in subjects’ diets with perfect precision. However, comprehensive lists of “characteristic” UPF ingredients show little variation from study to study.[22]

The next Dietary Guidelines should include a definition of UPFs.

The Dietary Guidelines should reference the NOVA classification system and formally define a working UPF definition based on ingredients. Already, by defining the health impacts of “ultraprocessed foods” as a research objective to inform the next DGAs, federal regulators have taken an important step towards validating the NOVA classification scheme. Clarifying in the Dietary Guidelines how consumers should define UPFs will help to standardize research, address criticism that the UPF concept is “unscientific,” and discourage efforts to displace the NOVA scheme with alternative definitions of “processed,” or even “ultraprocessed” food, that some food industry sectors might find more accommodating.[23]

Under NOVA, “ultra-processed foods are formulations of ingredients, mostly of exclusive industrial use, that result from a series of industrial processes.” [24] The NOVA researchers advise consumers to consult “the ingredients labels that by law must be included on pre-packaged food and drink products,” and if that list “contains at least one item characteristic of the ultra-processed food group, which is to say, either food substances never or rarely used in kitchens, or classes of additives whose function is to make the final product palatable or more appealing (‘cosmetic additives’),” then the product is a UPF. Examples of these ingredients include “hydrolysed proteins, soya protein isolate, gluten, casein, whey protein, ‘mechanically separated meat’, fructose, high-fructose corn syrup, ‘fruit juice concentrate’, invert sugar, maltodextrin, dextrose, lactose, soluble or insoluble fibre, hydrogenated or interesterified oil . . . flavours, flavour enhancers, colours, emulsifiers, emulsifying salts, sweeteners, thickeners, and anti-foaming, bulking, carbonating, foaming, gelling and glazing agents.”[25]

By simply enumerating a list of these ingredients, the next Dietary Guidelines will help to build a shared vocabulary around the “ultraprocessing” concept, and greatly assist consumer understanding. Eliminating ambiguity around how UPFs are defined under the Dietary Guidelines will facilitate precise measurement of these products in school meals, federal food assistance, and other programs informed by the Dietary Guidelines. And specifying which ingredients determine what is “ultra-processed” will help to identify areas of true controversy, and create incentives for research to support ingredient safety.

The next Dietary Guidelines should caution against high UPF diets.

Ongoing research will continue to shed light on why UPFs cause disease, but the existing evidence supports a cautionary approach towards these foods. The Dietary Guidelines should acknowledge the uncertainty that surrounds UPFs and the mechanisms by which they harm health, or by which they harm health most significantly. By all accounts, UPFs harm health in a variety of ways. Their soft texture and low fiber content, hyperpalatable design, and suggestive marketing, all appear to contribute to overeating. Additives like emulsifiers appear to compromise the microbiome. Others appear to alter hormone function. Chemical flavoring may interfere with the body’s capacity to match foods with needed nutrients and satisfy hunger cravings.[26]

Discerning which of these mechanisms most contribute to the UPF disease burden should continue to attract intense scrutiny from researchers. In the meantime, however, the Dietary Guidelines should advise consumers to limit UPFs in their diets where possible, and explain why doing so may improve dietary quality, i.e. explain the leading theories as to why UPFs are associated with disease.

Such advice does not entail abandoning macronutrient recommendations, or hopelessly confusing consumers. Critics point out that the NOVA UPF definition captures a broad range of foods, many of which supply important nutrients to consumers. To be sure, some foods designated UPFs, e.g. organic plain yogurt thickened with pectin, appear unlikely to cause harms that outweigh their health benefits. Some members of the DGAC thus questioned why the Guidelines would seek to “demonize” these foods, and risk leading consumers toward a less processed, but less nutrient dense and perhaps less healthy diet. This argument underestimates consumers’ capacity to act on accurate information.

Ignoring the evidence linking UPFs to disease because some UPFs are healthier than others will inevitably promote an inadequate standard for healthy diets. Given the potential cumulative effects of UPF ingredients like emulsifiers, some consumers may rationally choose to avoid “healthy” products, like organic plain yogurt with pectin, to accommodate other dietary choices (e.g. ice cream with guar gum).[27] Consumers can walk and chew gum at the same time. The Dietary Guidelines should trust Americans to reconcile advice to avoid high UPF diets alongside advice to avoid diets lacking in essential nutrients.

The next Dietary Guidelines should emphasize the special risk associated with UPFs “high in” salt, sugar and fat.

In acknowledging the uncertainty surrounding why UPFs appear to cause disease, the Dietary Guidelines should point out that many UPFs also have high levels of salt, sugar and fat. Research indicates that these “high in” foods, independent of whether they are “ultraprocessed,” contribute significantly to diet-related disease, in part because they often employ “hyperpalatable” combinations of salt, sugar and fat that contribute to overeating.[28] According to one recent analysis, just 10% of “high in” products purchased by US households are not UPFs (as defined under NOVA), and just 16% of UPFs purchased were not “high in” salt, sugar or fat.[29] In recommending that consumers limit UPFs in their diet, the Dietary Guidelines should advise consumers to focus first on reducing UPFs with high levels of salt, sugar or fat. Finalizing FDA’s proposed rule to require front-of-pack labeling will reinforce this advice.

As we have written before, nearly a dozen other countries’ dietary guidelines recommend limiting UPFs or “highly processed” foods.[30] These guidelines tend to acknowledge that UPFs may deliver some beneficial nutrients, but emphasize that less processed options usually represent a healthier choice. In general, they counsel consumers to avoid UPFs where possible. Belgium’s guidelines, for example, define classes of “food groups to limit,” such as “beverages with added sugars” and “sugar-sweetened products,” in part based on “level of processing.” They provide the NOVA definition of UPFs, albeit without much detail, and explain that “[m]ost ultra-processed foods should by no means replace basic foods,” even though “some ultra-processed foods may have an acceptable nutritional quality or beneficial nutritional density.”[31] The U.S. Dietary Guidelines would do well to follow this approach.

Conclusion

Ultra-processed food has become a target for would-be food system reformers of all political stripes, and with good reason. Should the Dietary Guidelines persist in ignoring UPFs, consumer confidence in federal nutrition policy will suffer. For the foregoing reasons, the Guidelines should provide a comprehensive, authoritative definition of UPFs, advise consumers to limit UPF consumption while acknowledging the uncertainty around which UPFs cause the most harm and why, and emphasize that consumers should first seek to reduce UPFs that also contain high levels of salt, sugar and fat in their diets.

Thank you for your consideration of these comments.

Sincerely,

Thomas Gremillion

Director of Food Policy

Consumer Federation of America

[1] Request for Public Comments on Reports on Alcoholic Beverages and Health To Inform the Dietary Guidelines for Americans, 2025–2030, 90 Fed. Reg. 3883 (Jan. 15, 2025) https://www.regulations.gov/document/HHS-OASH-2024-0019-0001

[2] Emmerich SD, Fryar CD, Stierman B, Ogden CL. Obesity and severe obesity prevalence in adults: United States, August 2021–August 2023. NCHS Data Brief, no 508. Hyattsville, MD: National Center for Health Statistics. 2024. DOI: https://dx.doi.org/10.15620/cdc/159281.

[3] Childhood Obesity Facts. (2024, December 20). Centers for Disease Control. https://www.cdc.gov/obesity/childhood-obesity-facts/childhood-obesity-facts.html

[4] Emmerich et al supra note 2

[5] Letter to the 2025 Dietary Guidelines Advisory Committee from the Consumer Federation of America, (September 25, 2024). https://consumerfed.org/wp-content/uploads/2024/09/Consumer-Federation-of-America-Comments-to-DGAC-re-UPFs-9-24-24.pdf

[6] Gremillion, T., McCann, K. Ultra-processed Foods: Why They Matter and What to Do About It. (October, 2024). https://consumerfed.org/reports/ultra-processed-foods-why-they-matter-and-what-to-do-about-it/

[7] Dietary Guidelines for Americans, 2020-2025. U.S. Department of Agriculture. https://www.dietaryguidelines.gov/sites/default/files/2021-03/Dietary_Guidelines_for_Americans-2020-2025.pdf, p.62.

[8] Scientists Build a Healthy Dietary Pattern Using Ultra-Processed Foods. (July 11, 2023). U.S. Department of Agriculture. https://www.ars.usda.gov/news-events/news/research-news/2023/scientists-build-a-healthy-dietary-pattern-using-ultra-processed-foods/

[9] Id.

[10] Lane, M. M., et al. (2024). Ultra-processed food exposure and adverse health outcomes: Umbrella review of epidemiological meta-analyses. BMJ, 384, e077310. https://doi.org/10.1136/bmj-2023-077310

[11] Henney, A. E., Gillespie, C. S., Alam, U., Hydes, T. J., Mackay, C. E., & Cuthbertson, D. J. (2024). High intake of ultra-processed food is associated with dementia in adults: A systematic review and meta-analysis of observational studies. Journal of Neurology, 271(1), 198–210. https://doi.org/10.1007/s00415-023-12033-1

[12] Chang, K., Gunter, M. J., Rauber, F., Levy, R. B., Huybrechts, I., Kliemann, N., Millett, C., & Vamos, E. P. (2023). Ultra-processed food consumption, cancer risk and cancer mortality: A large-scale prospective analysis within the UK Biobank. eClinicalMedicine, 56. https://doi.org/10.1016/j.eclinm.2023.101840

[13] https://pubmed.ncbi.nlm.nih.gov/37632227/

[14] Dietary Guidelines for Americans, 2020-2025. U.S. Department of Agriculture. https://www.dietaryguidelines.gov/sites/default/files/2021-03/Dietary_Guidelines_for_Americans-2020-2025.pdf, p.19.

[15] Dicken, S.J.; Batterham, R.L. The Role of Diet Quality in Mediating the Association between Ultra-Processed Food Intake, Obesity and Health-Related Outcomes: A Review of Prospective Cohort Studies. Nutrients 2022, 14, 23. https://doi.org/10.3390/nu14010023

[16] Hall, K. D. (2019). Ultra-processed diets cause excess calorie intake and weight gain: A one-month inpatient randomized controlled trial of ad libitum food intake. https://doi.org/10.31232/osf.io/w3zh2

[17] https://insights.figlobal.com/ultra-processed-foods/losing-weight-on-a-upf-diet-new-research-unpacks-the-causes-of-overeating

[18] Mozaffarian, D. (2025). The Dietary Guidelines for Americans—Is the evidence bar too low or too high? The American Journal of Clinical Nutrition, 121(1), 3–4. https://doi.org/10.1016/j.ajcnut.2024.11.013

[19] See, e.g., Zancheta Ricardo, C., Duran, A. C., Grilo, M. F., Rebolledo, N., Díaz-Torrente, X., Reyes, M., & Corvalán, C. (2023). Impact of the use of food ingredients and additives on the estimation of ultra-processed foods and beverages. Frontiers in Nutrition, 9. https://doi.org/10.3389/fnut.2022.1046463

[20] Monteiro, C. A., et al (2019). Ultra-processed foods: What they are and how to identify them. Public Health Nutrition, 22(5), 936–941. https://doi.org/10.1017/S1368980018003762

[21] NHANES stands for the National Health and Nutrition Examination Survey, which collects data about the health of adults and children in the United States and what they eat, drink, and take as supplements. See https://www.cdc.gov/nchs/nhanes/index.html

[22] Compare Zancheta Ricardo, C., Duran, A. C., Grilo, M. F., Rebolledo, N., Díaz-Torrente, X., Reyes, M., & Corvalán, C. (2023). Impact of the use of food ingredients and additives on the estimation of ultra-processed foods and beverages. Frontiers in Nutrition, 9. https://doi.org/10.3389/fnut.2022.1046463 with Meadows, A.D.; Swanson, S.A.; Galligan, T.M.; Naidenko, O.V.; O’Connell, N.; Perrone-Gray, S.; Leiba, N.S. Packaged Foods Labeled as Organic Have a More Healthful Profile Than Their Conventional Counterparts, According to Analysis of Products Sold in the U.S. in 2019–2020. Nutrients 2021 https://doi.org/10.3390/nu13093020 and Popkin, B. M., Miles, D. R., Taillie, L. S., & Dunford, E. K. (2024). A policy approach to identifying food and beverage products that are ultra-processed and high in added salt, sugar and saturated fat in the United States: A cross-sectional analysis of packaged foods. The Lancet Regional Health – Americas, 32, 100713. https://doi.org/10.1016/j.lana.2024.100713.

[23] See, e.g. Gibney MJ. Ultra-processed foods in public health nutrition: the unanswered questions. British Journal of Nutrition. 2023;129(12):2191-2194. doi:10.1017/S0007114522002793. Defenders of the Nova classification have criticized Gibney and his co-researchers for failing to disclose funding from food corporations such as Nestlé. Joao Peres. “Big Food targets Brazilian researcher.” O joio e o trigo. (English translation), Dec. 19, 2017 https://ojoioeotrigo.com.br/2017/12/ultra-attack-brazilian-researcher-targets-transnational-food/

[24] Monteiro, C. A., Levy, R. B., Claro, R. M., Castro, I. R. R. de, & Cannon, G. (2010). A new classification of foods based on the extent and purpose of their processing. Cadernos de Saúde Pública, 26, 2039–2049. https://doi.org/10.1590/S0102-311X2010001100005

[25] Monteiro supra note 15.

[26] For a more comprehensive discussion of the research on these mechanisms, see Gremillion, T., McCann, K. Ultra-processed Foods: Why They Matter and What to Do About It. (October, 2024). https://consumerfed.org/reports/ultra-processed-foods-why-they-matter-and-what-to-do-about-it/

 

[27] Salame, C., et al. (2024). Food additive emulsifiers and the risk of type 2 diabetes: Analysis of data from the NutriNet-Santé prospective cohort study. The Lancet Diabetes & Endocrinology, 12(5), 339–349. https://doi.org/10.1016/S2213-8587(24)00086-X

[28] Fazzino, T. L., Rohde, K., & Sullivan, D. K. (2019). Hyper-Palatable Foods: Development of a Quantitative Definition and Application to the US Food System Database. Obesity (Silver Spring, Md.), 27(11), 1761–1768. https://doi.org/10.1002/oby.22639

[29] Popkin, B. M., Miles, D. R., Taillie, L. S., & Dunford, E. K. (2024). A policy approach to identifying food and beverage products that are ultra-processed and high in added salt, sugar and saturated fat in the United States: A cross-sectional analysis of packaged foods. The Lancet Regional Health – Americas, 32. https://doi.org/10.1016/j.lana.2024.100713

[30] Letter to the 2025 Dietary Guidelines Advisory Committee from the Consumer Federation of America, Appendix 1 [“CFA Letter”] (September 25, 2024). https://consumerfed.org/wp-content/uploads/2024/09/Consumer-Federation-of-America-Comments-to-DGAC-re-UPFs-9-24-24.pdf

[31] Dietary Guidelines for the Belgian Adult Population, (June 2019). Superior Health Council. https://www.health.belgium.be/sites/default/files/uploads/fields/fpshealth_theme_file/20190902_shc-9284_fbdg_vweb.pdf