NCHR’s Public Comments on the Scientific Report of the 2020 Dietary Guidelines Advisory Committee

August 13, 2020.

National Center for Health Research’s Public Comments on the Scientific Report of the 2020 Dietary Guidelines Advisory Committee
[Docket FNS-2020-0015]

We are writing to express our views on the Scientific Report of the 2020 Dietary Guidelines Advisory Committee. The National Center for Health Research is a nonprofit think tank that conducts, analyzes, and scrutinizes research on a range of health issues. We do not accept funding from any agricultural or food manufacturing industries, and thus have no conflicts of interest in our assessment of the report.

We support many of the recommendations of the Dietary Guidelines Advisory Committee. However, we also have some concerns. 

Ultra-processed foods account for over half of the calories consumed per day by Americans[1], and have been associated with higher risks of cancer and other serious health issues[2], yet ultra-processed foods are mentioned only once in the entire 835 page report. This is a very serious omission that needs to be addressed.

The committee was given 80 questions to address in the report. However, these questions are limited in scope, failing to address topics known to be connected with health effects, such as red meat, processed foods, and sodium consumption. Failure to address these topics is another very serious omission and gives the clear impression that the report is biased. 

We strongly agree with the recommendation that sugar sweetened beverages should not be consumed by those under 2 years old. We also strongly support the recommended updates to daily sugar intake guidelines, lowering the recommended intake from no more than 10% of daily calories to no more than 6% of daily calories.

We also commend the efforts to assess nutritional considerations for different life stages, including ages 0-24 months, during pregnancy, and during lactation. It is particularly important to consider nutrition at these life stages due to the relationship between early life nutrition and health later in life, such as chronic diseases in adulthood.[3]

In addition, we agree with the committee’s assessments that those who do not currently drink alcohol should not begin drinking based on a misguided belief that drinking alcohol will make them healthier. For those who currently drink, the evidence indicates that drinking less is better for health than drinking more. We strongly agree with the committee’s suggestion that the recommended daily limit for alcohol should be 1 drink for both men and women. 

An overriding problem with the report is that many committee members have ties to industry, which calls into question whether the committee was truly objective in their recommendations, or if they were open to bias. For instance, some members of the subcommittee that assessed nutrition for those ages 0-24 months have ties to the baby food industry.[4] This source of bias seems to have limited the information included in the report and at the very least creates a strong appearance of conflicts of interest.

We urge the US Department of Agriculture and the US Department of Health and Human Services to address the shortcomings in the report regarding ultra-processed foods, red meat, and sodium consumption and follow the recommendations that are in the report in developing the 2020-2025 Dietary Guidelines for Americans.


  1.     Steele EM, Baraldi LG, da Costa Louzada ML, Moubarac JC, Mozaffarian D, Monteiro CA. Ultra-processed foods and added sugars in the US diet: evidence from a nationally representative cross-sectional study. BMJ Open. 2016; 6(3).
  2.     National Center for Health Research. Are Processed Red Meats More Unhealthy than Other Red Meats? What About Other Processed Foods?.
  3.     Hoffman DJ. Early nutrition and adult health: Perspectives for international and community nutrition programs and policies. Nutrition Research and Practice. 2010; 4(6):449-54.
  4.    Jacobs, A. Scientific Panel on New Dietary Guidelines Draws Criticism From Health Advocates. The New York Times. June 17, 2020.