Hunton Retail Law Resource

The updated 2025–2030 Dietary Guidelines for Americans (“DGA”) were released on January 7, 2026 by the U.S. Departments of Health and Human Services and Agriculture.  While the Guidelines do not carry the force of law, they exert substantial influence in shaping federal procurement standards (e.g., school meals and SNAP benefits), nutrition labeling and marketing regulations, and the factual baseline used in consumer product litigation.

This latest iteration delivers a simplified headline message – “eat real food” – and does so against the backdrop of the Administration’s Make America Healthy Again campaign.  Below are the key takeaways, and why they deserve close attention from companies operating in the food and beverage space.

The Big Picture

The 2025–2030 DGA are structured around eight core pillars: (1) eat the right amount for you; (2) prioritize protein foods at every meal; (3) consume dairy; (4) eat vegetables and fruits throughout the day; (5) incorporate healthy fats; (6) focus on whole grains; (7) limit highly processed foods, added sugars, and refined carbohydrates; and (8) limit alcohol consumption.

However, it is important to read the DGA alongside the accompanying Scientific Foundations for the Dietary Guidelines for Americans (“SFR”).The SFR marks a notable departure from the Biden administration’s Scientific Report of the Dietary Guidelines Advisory Committee, which emphasized plant-based proteins, the reduced consumption of red meat, and restrictive alcohol guidance.  According to the SFR, that earlier report suffered from methodological deficiencies – particularly its requirement that scientific evidence be evaluated through a health-equity lens.  The stated intent of the SFR is to present supplemental research to establish “clear, unbiased scientific guidance on the optimal diet for all Americans.”

One key methodological shift is the SFR’s emphasis on randomized controlled trials (“RCTs”) over observational or cohort studies.  The SFR states that earlier DGAs blurred the line between associative and causal evidence. 

Highly Processed Foods: Definition in Flux

A central issue for many stakeholders was whether the 2025–2030 DGA would address ultra-processed foods (“UPFs”).  This question has taken on heightened significance in light of the recent surge in UPF-related litigation against food and beverage manufacturers in both state and federal courts, as well as the growing body of state-level legislation seeking to define, regulate, or restrict UPFs. 

The DGA recommend limiting the consumption of highly processed foods.  Notably, the Guidelines employ the term “highly” rather than “ultra” processed, a distinction that has drawn considerable attention.  Although the SFR defines highly processed foods, the SFR concedes that this definition is provisional, pending a joint USDA–FDA effort to establish a uniform federal definition of UPFs.

For retailers and manufacturers, this ambiguity is a double-edged sword.  It limits immediate federal regulation, but leaves room for continued state action and private litigation.

Rethinking Healthy Fats

In a departure from past guidance, the DGA now encourage the consumption of healthy fats and expressly support whole-fat dairy products.  The SFR finds no credible evidence—from either RCTs or observational studies—linking whole-fat dairy consumption to adverse health outcomes in adults or children.  Likewise, it finds no clear cardiovascular or mortality benefit from reducing saturated fat intake below current averages.

Taken together, these findings mark a notable break from prior DGAs and may have downstream implications for “low-fat” and “reduced-fat” marketing claims, as well as future nutrition labeling standards built around earlier assumptions about fat.

Alcohol: Familiar Ground

Despite prior signals that alcohol guidance might become more restrictive, the DGA takes a restrained approach.  The Guidelines reiterate that Americans should “consume less alcohol for better health,” while recommending abstention only for specific populations.  Interestingly, while the SFR cites a study conducted by the National Academies of Sciences, Engineering, and Medicine, the DGA do not engage directly with that report’s findings, which linked moderate alcohol consumption to lower all-cause mortality. Taken together, this treatment of alcohol suggests a deliberate policy choice to preserve continuity and avoid more prescriptive or controversial regulatory positions.

Looking Ahead: What This Means for Retailers and Manufacturers

While the 2025–2030 DGA do not impose new obligations, they shape the regulatory and litigation environment in which food companies operate.  In short, the message to industry is familiar but evolving: watch the science, watch the regulators, and plan accordingly.  As the “eat real food” mantra gains traction, retailers and manufacturers would be well-advised to ensure that their product development, labeling, and marketing strategies are aligned not just with consumer trends, but with the scientific and policy framework that increasingly defines legal risk.