The drafting of the 2020 Dietary Guidelines for Americans (DGA) has started….and it’s a good start. The U.S. Department of Agriculture (USDA) and U.S. Department of Health and Human Services (HHS) have announced that, for the first time, the departments will seek public comments on the proposed priority topics and supporting scientific questions that will guide the development of the upcoming 2020-2025 edition of the DGA. The public may submit comments through the Federal Register; the comment period will be open from Feb. 28, 2018, to March 30, 2018. The priority topics, along with supporting scientific questions and a link to submit public comments, will be available at

The 2020-2025 DGA topics proposed by USDA and HHS are based on four criteria:

  • Relevance – the topic is within the scope of the DGA and its focus on food-based recommendations, not clinical guidelines for medical treatment;
  • Importance – the topic has new, relevant data and represents an area of substantial public health concern, uncertainty, and/or knowledge gap;
  • Potential federal impact – there is a probability that guidance on the topic would inform federal food and nutrition policies and programs; and
  • Avoiding duplication – the topic is not currently addressed through existing evidence-based federal guidance (other than the Dietary Guidelines).

This criterion was crafted with the 2015 DGA process in mind. In preparation of the 2015 DGA, the Dietary Guidelines Advisory Committee went far afield and sought input, for example, on the environmental impact of the DGA.  This was seen by many as going far beyond the scope of the DGA, as outlined by Congress in the authorizing statute. 

The Dietary Guidelines for Americans, first published in 1980, was based on the 1977 publication “Dietary Goals for the United States” released by the Senate Select Committee on Nutrition. The DGA become the federal government’s most important statement on nutrition. It is updated every five years.  In releasing the 1977 Dietary Goals, Chairman George McGovern and Senator Bob Dole emphasized that dietary recommendations were intended to reduce diet as a risk factor in the etiology of disease and to promote nutritional health. Chairman McGovern said at the time: “We must acknowledge and recognize that the public is confused about what to eat to maximize health. If we, as Government, want to reduce health costs and maximize the quality of life for all Americans, we have an obligation to provide practical guides to the individual consumer, as well as to set national dietary goals for the country as a whole.”

The Dietary Goals was the first comprehensive statement by any branch of the Federal Government on dietary recommendations. However, that report – along with the Dietary Guidelines which followed – were never intended to address agriculture production procedures or environmental issues. 

The DGA is drafted by both USDA and HHS, but it is USDA that is in the lead for this edition. USDA and HHS are proposing a life stage approach for this edition, focusing on priority scientific questions from birth through older adulthood. The 2014 Farm Bill mandated that, starting with the 2020-2025 edition, the DGA must provide guidance for women who are pregnant, as well as infants and toddlers from birth to 24 months. In addition to a focus on life stages, the topics and supporting questions for public comment reflect a continued focus on patterns of what we eat and drink as a whole, on average and over time, rather than individual foods or food groups.

Close attention will be given to how the DGA handles breast feeding, which is an emotionally charged topic that frequently pits science against personal values. While USDA has in the past issued dietary guidance for the mothers participating in the Special Supplemental Feeding Program for Women, Infants and Children (the WIC program) and HHS has issued dietary advice, this may be the first time that both Departments will addresses infant nutrition together. Historically, they have not treated the subject of breast feeding in the same manner. 

USDA WIC guidance says that breast milk is best but “When breast milk is not available, iron‐fortified infant formula is an appropriate alternative for your infant’s first year of life.” HHS agrees that breast milk is best but has not addressed the question of what is second best. HHS has not offered any advice to mothers who refuse to breast feed, cannot, or should not because the mother has HIV/AIDS. As a result, there are some mothers who actually put soda in a bottle. And how USDA and HHS handle the issue of breast feeding may actually have global implications.   

So, this edition of the DGA will not address the environmental aspects of the diet but may have different issues that generate public attention. After finalizing the topics and supporting questions for the 2020 edition, USDA and HHS will post a public call for the Dietary Guidelines Advisory Committee nominations. The areas of expertise needed will be based on the final topics and supporting scientific questions, resulting in a coordinated and efficient scientific review.

About the Author: Matz specializes in food and nutrition issues at OFW Law in Washington, D.C. He served  as General Counsel to the Senate Select Committee on Nutrition and Human Needs when the Dietary Goals were drafted in 1977.