Comment: 2025 Dietary Guidelines Advisory Committee Proposed Nutrient Density Conclusions

The Center for Science in the Public Interest and five other public health organizations submitted a comment to the Dietary Guidelines Advisory Committee asking for clarity on a change they proposed during DGAC Meeting 6. The Food Pattern Modeling and Data Analysis Subcommittee proposed a modification to the presentation of all Healthy U.S.-Style dietary patterns across all life stages starting at 2 years that would not include a “Limit on Calories for Other Uses.” As proposed, this modification would eliminate specific quantities (calories and percentages) of remaining daily calories for other uses when dietary pattern recommendations are presented across all life stages. It is unclear what the implications of this proposal are for final recommendations for daily limits on calories from saturated fat and added sugar in the DGA. If this change precludes quantitative limits on added sugar and saturated fat from being included in the final DGA, that would present issues for the many policies and federal nutrition assistance programs that are tied to these DGA limits (e.g. food labeling, school meals). This letter asks for clarity on the intention and impact of the change.