A. Dietary Guidelines

Federal dietary guidelines, updated by the U.S. Department of Agriculture (USDA) and the U.S. Department of Health and Human Services (HHS) every five years, are much more than the federal government’s recommendations regarding nutrition and diet.

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the Dietary Guidelines Advisory Committee⁴ tried to build on this brief nod to sustainability by recommending that the guidelines incorporate sustainability in their dietary recommendations.⁵ Secretary of Agriculture Tom Vilsack and Secretary of HHS Sylvia Burwell, who shared joint responsibility over the guidelines, responded with a letter stating that the inclusion of sustainability as a goal in the guidelines was beyond their statutory authority,⁶ and thus sustainability was not included as a guiding principle or goal. The 2020 dietary guidelines again did not incorporate any sustainability goal.⁷

Advocates have persuasively argued that this is an incorrect interpretation of the enabling legislation, which requires the guidelines to be “based on the preponderance of the [current] scientific and medical knowledge.”⁸ The statute also establishes a nutrition monitoring and related research program, which, according to the law, should include information about “food supply and demand determinations.”⁹ Because sustainability is crucial to the longterm viability of the country’s food supply, advocates argue, the statute gives USDA and HHS the authority to consider it as a factor in the guidelines.

Though the 2015 dietary guidelines did not incorporate sustainability in its recommendations, the Dietary Guidelines Advisory Committee’s 2015 report did emphasize the connection between environmental sustainability and healthy diets, defining “sustainable diets” as a “pattern of eating that

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promotes health and well-being and provides food security for the present population while sustaining human and natural resources for future generations.”¹¹ Among the issues the Committee recommended integrating into the guidelines were land and water use, soil fertility, biodiversity loss, and greenhouse gas emissions.¹² The Committee’s review of the literature on population-level dietary patterns and long-term food sustainability found “a moderate to strong evidence base” that increasing the consumption of healthy plant-based foods would reduce the environmental impact of the average U.S. diet. It is likely that the 2015 dietary guidelines would have recommended the reduced consumption of carbon-intensive meat as a result of these findings had the agencies found it to be within their authority to include sustainability as a factor. Brazil’s dietary guidelines, for example, encourage the use of minimally processed plant-based foods over animal products to reduce greenhouse gas emissions and deforestation.¹³ (Reduced consumption of red meat was recommended in 2015, but for health reasons, not for its impact on sustainability.)

Both USDA and HHS must acknowledge their legal authority to include sustainability as a factor in the guidelines.

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survey conducted in 2020 found that more than half of American consumers claim that food sustainability is important and a third say that sustainability has a “real impact” on their purchases but over “6 in 10 find it hard to know whether their food choices are environmentally sustainable.”¹⁵ The same survey shows that about 40% of consumers (and a higher portion of younger consumers) are familiar with the “MyPlate” graphic that embodies the U.S. dietary guidelines, suggesting that if the guidelines included and were clear about sustainability, they could have a significant impact on food consumption patterns. These sustainability goals could also be advanced by addressing health concerns, as the same survey shows that most American consumers are seeking to eat more fruits and vegetables for health reasons, which generally have a much lower climate impact than conventionally produced animal products. Thus, further revision to the dietary guidelines to incorporate a focus on sustainability would help Americans learn about the environmental consequences of their food choices while immediately affecting what millions of Americans eat each day, encouraging healthy and climate-friendly options.