February 10, 2025

Thank you for the opportunity to submit comments on the Scientific Report of the 2025 Dietary Guidelines Advisory Committee.

The Vegetarian Resource Group (VRG) is an independent non-profit organization dedicated to educating the public on vegetarianism and the interrelated issues of health, nutrition, environment, ethics, and world hunger. Our health professionals, activists, and educators work with businesses and individuals to bring about healthy changes in schools, workplaces, and the community. Registered dietitians and physicians aid in the development of nutrition-related publications and answer questions about the vegetarian and vegan diet. For the past 31 years, we have commissioned polls exploring vegetarian-related issues, results of which are often used by researchers, the food industry, and the media. Financial support comes primarily from memberships and contributions.

We commend the Committee for their work and appreciate their attempts to promote more plant sources of protein as well as their commitment to having guidance be relevant to people with different needs.

Our comments will focus primarily on the vegetarian, including vegan, population of the United States and those who frequently opt to eat vegan/vegetarian meals.

The most recent polls commissioned by The Vegetarian Resource Group indicate that 6% of the adult and 5% of the child/adolescent U.S. population “never eats meat, fish, seafood, or poultry” and thus would be classified as vegetarian.^1,2 Approximately half of these adult vegetarians and 40% of the child/adolescent vegetarians “never eat meat, fish, seafood, poultry, dairy products, or eggs” and thus would be classified as vegan.^1,2 Table 1 provides details about the percentages of vegetarians and vegans in our most recent surveys.

Our polls also indicate that a substantial proportion of U.S. adults eat vegetarian, including vegan meals. Approximately 63% of U.S. adults always, usually, or sometimes eat vegetarian (including vegan) meals; 29% always, usually, or sometimes eat vegan meals.¹ Table 2 provides details about eating behaviors of U.S. adults.

As an organization that serves as a resource for those choosing vegetarian or vegan diets, we have often referred to the Healthy Vegetarian Dietary Pattern that was introduced in the 2015 Dietary Guidelines and was updated in the 2020 Dietary Guidelines to include patterns for ages 1 year and older. It is disconcerting to see that this pattern no longer appears to be a part of the most recent Scientific Report except for ages 12 through 23 months (Table E.1.3).

Vegan and vegetarian dietary patterns are associated with numerous health and environmental benefits.^3-6 Although the Scientific Report promotes use of more plant-based meal and dietary recommendation options, guidance seems to be lacking for those who wish to exclusively use plant sources of foods (vegan dietary pattern) or who want to eliminate meat, fish, poultry, and seafood (lacto-ovo, lacto, or ovo vegetarians).

While the Eat Healthy Your Way pattern is described as “a single, inclusive dietary pattern that offers flexibilities to support individual needs and preferences,” it is unclear to us how this pattern meets the needs and preferences of those who choose to avoid animal products or even those who do not wish to eat between 9.5 and 29.5 ounce equivalents of meat, poultry, and eggs on a weekly basis (Table E.1.2). The report alludes to “Dietary Pattern Flexibilities” in Box D.10.1 where flexibilities are described as “narrative advice around options for meeting nutrient needs outside of quantitative pattern recommendations.” We are hopeful that this narrative advice will include information about vegetarian and vegan eating patterns but are concerned about the vagueness of the explanation of Dietary Pattern Flexibilities. In addition, many users rely on tables, such as Table E.1.2 and will not be aware of any narrative advice in Dietary Guidelines 2025 related to vegan and vegetarian dietary patterns. We propose that Dietary Guidelines 2025 retains the Healthy Vegetarian Dietary Pattern that appeared in the 2015 and 2020 Dietary Guidelines.

A number of peer-reviewed studies have been published using food pattern modeling that demonstrate that various vegetarian, vegan, and near-vegetarian dietary patterns can be nutritionally adequate during different stages of the life-cycle.^7-11 These studies provide needed information about the adequacy of vegan and vegetarian dietary patterns but unfortunately do not appear to have been included in or considered for the Scientific Report.

The Scientific Report repeatedly indicated that there was insufficient data to allow the development of a vegan dietary pattern (Box D.10.2). This perceived lack of information should be addressed with support for research to be conducted on the food choices of vegans (no meat, fish, poultry, dairy products, eggs) in the United States. These results should be used to inform meal patterns in the future. Similarly, the Committee reported encountering challenges in acquiring data for newer plant-based alternatives.¹² Updating information in the database used to develop dietary patterns to incorporate additional foods commonly eaten by vegetarians, including vegans, especially fortified foods and replacements for animal-derived products should be a priority to support the work of future Scientific Committees.

We support the Committee’s recommendation to move the Beans, Peas, and Lentils Subgroup from the Vegetables Food Group to the Protein Foods Group to align with evidence to include more plant-based protein foods. We also support the Committee’s recommendation to reorder the Protein Foods Subgroups to list Beans, Peas, and Lentils first, followed by Nuts, Seeds, and Soy Products with Meats, Poultry, and Eggs listed last. This reordering communicates the importance of a greater focus on plant-based foods due to their health benefits. Educational materials developed in support of the 2025 Dietary Guidelines should promote greater use of plant-based protein sources.

While the Scientific Report discusses an increase in the quantity of Beans, Peas, and Lentils in the Eat Healthy Your Way pattern, the increase is relatively small as indicated in Table 3. We note that the highest increase is about 4/7 of an ounce equivalent (or about 2 tablespoons) more per day. We support a larger increase in the number of servings of beans, peas, and lentils because of the known health benefits of this food group. Users of the 2025 Dietary Guidelines should be provided with information on ways to reduce or eliminate meat, poultry, and eggs while increasing servings of beans, peas, and lentils and nuts and soy foods.

As educational materials are developed, we encourage the inclusion of more options to help consumers meet their needs for those nutrients that have been identified as public health concerns due to underconsumption. For example, although fortified soy milk is included in the dairy group, many consumers will not use 3 cups of fortified soy milk daily. We encourage providing other options including increased use of leafy green vegetables, calcium-set tofu, and calcium-fortified foods in addition to soy milk, such as other plant milks and orange juice, as sources of bioavailable calcium.

We support the Committee’s recommendation that future Committees consider examining the association of ultra-processed foods with risk of obesity, type 2 diabetes, cardiovascular disease, cancer, and cognitive decline. Additionally, we urge future Committees to develop and use a more rigorous definition of ultra-processed foods. We are concerned that foods that may be eaten by vegetarians such as plant milks and commercial veggie burgers are being classified as ultra-processed foods.^13,14 Ultra-processed foods are thought of as being high in calories, salt, sugar, and fat and are often associated with being the foods we crave, despite having little to recommend them in terms of nutrition. This hardly seems like the correct category for foods such as plant milks or some brands of veggie burgers. One study of ultra-processed foods found that the entire category of “meat alternatives” which included veggie sausages and burgers, tofu, tempeh, and TVP supplied 0.2% of total calories.¹⁵ With this small representation, it is impossible to reach conclusions about the health effects of these foods compared to other foods commonly classified as ultra-processed.

Sincerely,

Reed Mangels, PhD, RD

Nutrition Advisor, The Vegetarian Resource Group

Charles Stahler                                                                     Debra Wasserman

Co-Director, The Vegetarian Resource Group               Co-Director, The Vegetarian Resource Group

References

1. Stahler C, Mangels R. How many vegetarians and vegans are there? Vegetarian Resource Group. https://www.vrg.org/nutshell/CulturedMeatYouGov2022.pdf. 2022.
2. Stahler C, Mangels R. How many youth in the U.S. are vegan? Vegetarian Resource Group. https://www.vrg.org/nutshell/Yougov2021youthteenwriteup.pdf. 2021.
3. Craig WJ, Mangels AR, Fresán U, et al. The Safe and Effective Use of Plant-Based Diets with Guidelines for Health Professionals. Nutrients. 2021;13(11):4144. Published 2021 Nov 19. doi:10.3390/nu13114144
4. Springmann M. A multicriteria analysis of meat and milk alternatives from nutritional, health, environmental, and cost perspectives. Proc Natl Acad Sci U S A. 2024;121(50):e2319010121.
5. Gibbs J, Cappuccio FP. Plant-Based Dietary Patterns for Human and Planetary Health. Nutrients. 2022;14(8).
6. Raj S, Guest NS, Landry MJ, Mangels AR, Pawlak R, Rozga M. Vegetarian Dietary Patterns for Adults: A Position of the Academy of Nutrition and Dietetics. J Acad Nutr Diet. Published online February 7, 2025. doi:10.1016/j.jand.2025.02.002.
7. Hess JM, Comeau ME, Smith JL, Swanson K, Anderson CM. Vegetarian Diets During Pregnancy: With Supplementation, Ovo-Vegetarian, Lacto-Vegetarian, Vegan, and Pescatarian Adaptations of US Department of Agriculture Food Patterns Can Be Nutritionally Adequate. J Acad Nutr Diet. 2025;125(2):204-216.e17. doi:10.1016/j.jand.2024.08.001
8. Hess JM, Comeau ME, Swanson K, Burbank M. Modeling Ovo-vegetarian, Lacto-vegetarian, Pescatarian, and Vegan USDA Food Patterns and Assessing Nutrient Adequacy for Lactation among Adult Females. Curr Dev Nutr. 2023;7(12):102034. Published 2023 Nov 20. doi:10.1016/j.cdnut.2023.102034
9. Hess JM, Comeau ME. Modeling lacto-vegetarian, pescatarian, and “pescavegan” USDA food patterns and assessing nutrient adequacy for healthy non-pregnant, non-lactating adults. Front Nutr. 2023;10:1113792. Published 2023 Feb 7. doi:10.3389/fnut.2023.1113792
10. Hess JM, Comeau ME. Application of dairy-free vegetarian and vegan USDA food pattern models for non-pregnant, non-lactating healthy adults. J Food Sci. 2022;87(10):4703-4713. doi:10.1111/1750-3841.16314
11. Hess JM. Modeling Dairy-Free Vegetarian and Vegan USDA Food Patterns for Nonpregnant, Nonlactating Adults. J Nutr. 2022;152(9):2097-2108. doi:10.1093/jn/nxac100
12. Taylor CA, Talegawkar SA, Fung T, et al. What are the implications for nutrient intakes when modifying the Protein Foods group and subgroup quantities within the Healthy U.S.-Style Dietary Pattern or Healthy Vegetarian Dietary Pattern? Food Pattern Modeling Report. U.S. Department of Agriculture, Food and Nutrition Service, Center for Nutrition Policy and Promotion, Nutrition and Economic Analysis Branch; 2024. doi:https:/doi.org/10.52570/DGAC2025.FPM03.
13. Orlich MJ, Sabaté J, Mashchak A, et al. Ultra-processed food intake and animal-based food intake and mortality in the Adventist Health Study-2. Am J Clin Nutr. 2022;115(6):1589-1601. doi:10.1093/ajcn/nqac043
14. Gehring J, Touvier M, Baudry J, et al. Consumption of ultra-processed foods by pesco-vegetarians, vegetarians, and vegans: associations with duration and age at diet initiation. J Nutr. 2021;151(1):120-131.
15. Rauber F, Laura da Costa Louzada M, Chang K, et al. Implications of food ultra-processing on cardiovascular risk considering plant origin foods: an analysis of the UK Biobank cohort. Lancet Reg Health Eur. 2024;43:100948. Published 2024 Jun 10. doi:10.1016/j.lanepe.2024.100948

Table 1. Recent Poll Results –Percentage of Adults, Children, and Teens in the U.S. who are Vegetarian or Vegan

^*Vegetarian defined as “never eat meat, fish, seafood, poultry”; vegan defined as “never eat meat, fish, seafood, poultry, dairy products, eggs.”

These surveys were conducted online within the United States by YouGov on behalf of The Vegetarian Resource Group among 2,889 U.S. adults and among 1,002 U.S. 8-17-year-olds.

Table 2. Recent Poll Results –Percentage of Adults in the U.S. who Usually, Sometimes or Always Eat Vegetarian or Vegan Meals ¹

This survey was conducted online within the United States by YouGov on behalf of The Vegetarian Resource Group among 2,889 U.S. adults.

Table 3. Amounts of Beans, Peas and Lentils Recommended in the 2020 Healthy U.S.-Style Dietary Pattern (HUSS) Compared to the 2025 Eat Healthy Your Way Dietary Pattern