The Vegetarian Resource Group sent in these comments to the 2020 Dietary Guidelines Advisory committee, c/o USDA Food and Nutrition Service, Center for Nutrition Policy and Promotion

Thank you for the opportunity to submit comments for the 2020 edition of Dietary Guidelines for Americans.

Dietary Guidelines for Americans 2015-2020 endorsed “a healthy vegetarian eating pattern” as one of three “healthy eating patterns that can be adapted based on cultural and personal preferences.” This healthy vegetarian eating pattern could encompass lacto-ovo/lacto vegetarian and vegan patterns. The inclusion of both vegetarian and vegan food patterns provided needed guidance for Americans who choose to eat vegetarian or vegan meals, whether this is done occasionally or every day. The text of the Guidelines made a clear and compelling case for a rapid shift in the American diet to one that is more plant-based. The evidence-based approach used throughout the report allowed readers to understand the basis for the recommendations that are made. We hope that the next edition of Dietary Guidelines for Americans will provide similar or stronger support for vegetarian/vegan diets.

We respectfully submit comments and suggestions for the revision of Dietary Guidelines for Americans. 

Continue to include detailed, specific information about vegetarian and vegan diets.

Since the Dietary Guidelines were last updated, many papers have been published on vegetarian diets. Information from this body of research should be used when updating the sections on vegetarian diets. Examples of relevant information to include:

• In adults, vegetarian diets are associated with a 40% lower risk of coronary heart disease events and a 29% reduction in cerebral vascular disease events compared to nonvegetarian diets.¹
• A recent meta-analysis reported a 25% lower risk of incidence and/or mortality from ischemic heart disease and an 8% lower incidence of cancer in vegetarians overall (15% lower incidence in vegans) compared to nonvegetarians.²
• Vegetarians have a lower mean BMI than nonvegetarians (Vegetarians: -1.48 kg/m²; vegans: -1.72 kg/m²).²
• A meta-analysis determined that vegetarians had a 27% lower risk of developing diabetes than did nonvegetarians. This reduced risk was seen in vegans and in lacto-ovo, lacto, and ovo vegetarians.³
• Vegetarians have lower total cholesterol (Vegetarian: -28.16 mg/dL; vegans: -31.02 mg/dL) and LDL cholesterol (Vegetarians: -21.27 mg/dL; Vegans: -22.87 mg/dL) than nonvegetarians.²
• Vegetarian diets, especially vegan diets, effectively promote weight reduction.⁴
• Changing from a nonvegetarian to a vegetarian or vegan diet is associated with a mean decrease in blood cholesterol concentration of 14 mg/dL and a mean decrease in LDL concentration of 13 mg/dL. Reductions of this scale correspond to an estimated 9 to 10.6% decrease in risk of heart disease.⁵
• Vegan-vegetarian diets are safe in pregnancy.^6,7
• Breast milk of well-nourished vegan and vegetarian women is nutritionally equivalent to the breast milk of well-nourished nonvegetarian women.⁸
• An average 2000 calorie diet with 3.5 or more ounces of meat per day has 2.5 times more greenhouse gas emissions compared to an average 2000 calorie vegan diet. Moving from a meat-containing diet to a vegan diet would reduce an individual’s carbon footprint by 1560 kg of carbon dioxide equivalents per year.⁹
• Modeling studies comparing a nonvegetarian diet based on global dietary guidelines (at least 5 servings of fruits and vegetables, no more than 1.5 ounces of red meat), a lacto-ovo vegetarian diet, and a vegan diet found adoption of the healthier non-vegetarian diet could result in 5.1 million fewer deaths per year. A lacto-ovo vegetarian diet would reduce deaths by 7.3 million per year and a vegan diet by 8.1 million per year. Worldwide use of a vegan diet would reduce food-related greenhouse gas emissions by 70% compared to what is projected for 2050. A lacto-ovo vegetarian diet would reduce these emissions by 63% and a healthier nonvegetarian diet would reduce projected emissions by 29%. Healthcare cost savings could be as much as $1 trillion per year with worldwide use of vegan diets, $973 billion with lacto-ovo vegetarian diets, and $735 billion with healthier nonvegetarian diets.¹⁰

Incorporate tools and information to educate about use of vegan and vegetarian diets and reduction of meat consumption.

Other countries have recently issued dietary advice that promotes lower meat consumption. These materials provide ideas for ways that this information could be incorporated in Dietary Guidelines for Americans.

For example, the Netherlands’ Wheel of Fire graphic, which is similar to the United States’ MyPlate, recommends eating red meat twice a week at most, and using beans and nuts as primary protein sources on at least two days a week. Red meat is limited due to its being high in saturated fats and its negative effects on the environment. Fish is limited to one serving a week due to sustainability concerns. Fortified plant milks can be used to replace dairy products.¹¹

The UK’s Eatwell Guide has a food group “Beans, Pulses, Fish, Eggs, Meat, and Other Products” suggesting that beans and pulses (another word for legumes) are given top priority.  Instead of the traditional “Dairy Group,” this guide calls it the “Dairy and Alternatives Group” and a carton of soymilk is included in the graphics for this group.¹²

Canada’s Food Guide has no dairy group. Dairy products are included under the general heading of Protein Foods where plant proteins are featured prominently. The Food Guide states, “Protein foods, including plant-based protein foods, are an important part of healthy eating. Include foods such as beans, lentils, nuts, seeds, lean meats and poultry, fish, shellfish, eggs, lower fat milk and lower fat dairy products.” Canadians are urged to plan a couple of meatless meals a week and example meals are vegan. The image of an ideal plate suggests that the recommended diet consists of 50% fruits and vegetables, 25% grains, and 25% protein foods.¹³

We encourage the Committee to continue to stress the benefits of vegan and vegetarian diets, to expand the discussion of benefits of these diets, and to continue to identify these diets as healthy eating patterns.

Sincerely,

Reed Mangels, PhD, RD

Nutrition Advisor, The Vegetarian Resource Group

References
1.  Kwok CS, Umar S, Myint PK, Mamas MA, Loke YK. Vegetarian diet, Seventh Day Adventists and risk of cardiovascular mortality: A systematic review and meta-analysis. Int J Cardiol. 2014;176: 680–686.
2. Dinu M, Abbate R, Gensini GF, Casini A, Sofi F. Vegetarian, vegan diets and multiple health outcomes: a systematic review with meta-analysis of observational studies. Crit Rev Food Sci Nutr. 2017;57:3640-3649.
3. Lee Y, Park K. Adherence to a vegetarian diet and diabetes risk: a systematic review and meta-analysis of observational studies. Nutrients. 2017 Jun 14;9(6). pii: E603.
4. Huang RY, Huang CC, Hu FB, Chavarro JE. Vegetarian diets and weight reduction: a meta-analysis of randomized controlled trials.  J Gen Intern Med. 2016;31(1):109‐116.
5. Wang F, Zheng J, Yang B, Jiang J, Fu Y, Li D. Effects of vegetarian diets on blood lipids: A systematic review and meta-analysis of randomized controlled trials. J Am Heart Assoc. 2015;4(10):e002408.
6. Piccoli GB, Clari R, Vigotti FN, et al. Vegan-vegetarian diets in pregnancy: danger or panacea? A systematic narrative review. BJOG. 2015;122(5):623‐633.
7. Melina V, Craig W, Levin S. Position of the Academy of Nutrition and Dietetics: Vegetarian Diets. J Acad Nutr Diet. 2016;116(12):1970‐1980.
8. Karcz K, Królak-Olejnik B. Vegan or vegetarian diet and breast milk composition – a systematic review. Crit Rev Food Sci Nutr. 2020 Apr 22:1-18. doi: 10.1080/10408398.2020.1753650. [Epub ahead of print]
9. Scarborough P, Appleby PN, Mizdrak A, et al. Dietary greenhouse gas emissions of meat-eaters, fish-eaters, vegetarians and vegans in the UK. Climatic Change. 2014;125:179–92.
10. Springmann M, Godfray HC, Rayner M, Scarborough P. Analysis and valuation of the health and climate change cobenefits of dietary change. Proc Natl Acad Sci USA. 2016;113(15):4146‐4151.
11.  Netherlands Nutrition Center. How much and what can I eat each day? (Translated). http://www.voedingscentrum.nl/nl/gezond-eten-met-de-schijf-van-vijf/hoeveel-en-wat-kan-ik-per-dag-eten-.aspx
12. Public Health England. Eatwell Guide 2016. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/528193/Eatwell_guide_colour.pdf
13. Government of Canada. 2019. Canada’s Food Guide. https://food-guide.canada.ca/en/