WASHINGTON — The need for critical definitions and strong support for a healthy equity lens are among the topics members of the Grain Chain would like to see the Department of Health and Human Services (HHS) and the US Department of Agriculture (USDA) take into consideration as they begin work on the 2025-2030 Dietary Guidelines for Americans.

The Grain Chain, which is a group of leading grain-based food organizations, commented on the proposed scientific questions to be examined as part of the review supporting the development of the new guidelines in a May 16 letter to the HHS. Specifically, the Grain Chain focused on the needs for critical definitions needed before the 2025 DGA review process starts; the value of processing for grain foods; support for a health equity lens through the review process; the need for consumption and physical activity balance approach and suggested Dietary Guidelines Advisory Committee (DGAC) critical nominee selection criteria.

“The agencies should clearly define the following terms: ‘nutrient dense,’ ‘non-dairy,’ ‘non-meat alternatives,’ ‘ultra-processed,’ ‘processed’ and ‘minimally processed,” the Grain Chain said in a May 16 letter to the HHS and USDA. “These definitions will be critical to the (Dietary Guidelines Advisory Committee’s) focus and interpretation applied to each scientific question.”

The Grain Chain also noted that the DGA must consider other ways to approach foods with varying degrees of processing, particularly those “processed” foods that have beneficial attributes and improve nutrient content with added dietary fiber, vitamins and minerals.

“For grains, whether wheat, rice, corn, or other grains, some form of processing is necessary to make the nutrients available and digestible,” the Grain Chain said. “In the case of enriched (refined) white bread, and enriched pasta, where nutrients are reduced or lost during processing, the nutrients are replaced as part of the enrichment process in amounts equal to or greater than those in whole grain breads or pastas.

“Enrichment and fortification of refined grains have made significant, long-lasting contributions to improve the health of Americans. Of grave concern is that these ground-breaking health achievements are currently at risk as some consumers turn away from grains in response to low-carbohydrate diets. In fact, to meet consumer demands for ‘clean labels,’ some food manufacturers consider foregoing enrichment and fortification of grain products, which could result in negative nutrition and public health implications.”

The HHS and USDA have said all scientific questions will be reviewed with a “health equity lens” to ensure the new guidelines are relevant to people with diverse racial, ethnic, socioeconomic and cultural backgrounds, an approach that was strongly supported by the Grain Chain. The Grain Chain has recommended that factors such as food cost, food availability and food accessibility be specified as part of each scientific question’s written framework for emphasis and to more formally incorporate them into the scientific review.

“While we believe these factors should be part of every DGA process, they are particularly relevant now when the administration’s key priorities include health equity, eliminating hunger, and nutrition security,” the Grain Chain said. “These goals are made all the more challenging when the US rate of inflation is at its highest point in decades and the food industry continues to struggle with significant and severe supply chain issues.”

Another issue of concern involves dietary patterns. While the HHS and USDA have indicated interest in weight loss and exploring dietary patterns that may contribute to obesity, the Grain Chain said it’s just as important to focus on physical activity and the need for balance.

“Obesity does not indicate nutritional adequacy,” the Grain Chain said. “In fact, it often indicates a nutrient poor diet, particularly when poverty is a factor. There should be a focus on nutritional value and balance, not calories alone. Furthermore, many grain foods can help improve diet quality by encouraging the consumption of healthy low-calorie, high-fiber foods and increasing fruit and vegetable intake. Thus, the DGA must consider the quality of the diet as a whole and not just the types of food to be included. The DGAC should also be sensitive to consumers with eating disorders regarding messages about body weight image and calories.”

The HHS and the USDA will consider all public comments in order to prioritize the scientific questions to be examined by the DGAC. The resulting report from the DGAC will be used to develop the Dietary Guidelines for Americans, 2025-2030. The members of the DGAC have not yet been selected.

The Grain Chain has been established for several cycles of the DGA review process to enable consensus-building on policy priorities and messaging to promote the health benefits of grain foods.  Members include the American Bakers Association, the Cereal and Grains Association, the Independent Bakers Association, the National Association of Wheat Growers, the National Pasta Association, the North American Millers’ Association, the Retail Bakers of America, USA Rice Federation, and the Wheat Foods Council.