New USDA Dietary Guidelines with a Focus on Food Packaging

Changes in focus in the new Dietary Guidelines are the inclusion of food packaging and its connection to highly processed foods.

The U.S. Department of Agriculture (USDA) released its latest edition of the Dietary Guidelines for Americans, 2025–2030 [1] on January 7, 2026. In the introduction to the new Guidelines, USDA Secretary Brooke Rollins and U.S. Department of Health and Human Services (HHS) Secretary Robert F. Kennedy Jr. refer to them as "the most significant reset of federal nutrition policy in our nation's history." Changes in focus in the new Dietary Guidelines are the inclusion of food packaging, its connection to highly processed/ultra-processed foods, and the possible health issues for which such foods are alleged to be responsible.

The focus on food packaging and highly/ultra-processed foods as well as some other subjects, such as "Generally Recognized as Safe" (GRAS) substances, reflect the current Administration's Make America Healthy Again (MAHA) policies. As pointed out in a previous article, one of Secretary Kennedy's stated goals is to minimize exposure to perceived harmful substances in food and food packaging. [2]  

By way of background, the Dietary Guidelines for Americans were first released in February 1980, [3] and a new edition has been released every five years since that time. [4] The Dietary Guidelines for Americans, 2020–2025 point out, "As stipulated by law, USDA and HHS must update the Dietary Guidelines at least every 5 years. The Guidelines must be grounded in the body of scientific and medical knowledge available at that time, not in individual studies or individual expert opinion." [5]

"Scientific Foundation" for Guidelines

The current Guidelines are accompanied by an addendum, "The Scientific Foundation for the Dietary Guidelines for Americans." [6] The addendum seems to take on as one of its primary objectives distinguishing itself from the "Scientific Report of the 2025 Dietary Guidelines Advisory Committee (DGAC Report)," prepared during the preceding Biden Administration, which "The Scientific Foundation" addendum suggests "framed its analysis through a health equity lens."

The Scientific Foundation addendum begins with a list of what was and was not retained in the Biden Advisory Committee report, which includes the rejection of a suggestion to consider strategies "to decrease packaging chemical exposures and increase sustainability." [6] To be clear, though, the only real objection appears to be the inclusion of the term "sustainability," as the latest Guidelines include the comment that "emerging evidence indicates that chemicals derived from food packaging materials can accumulate in human tissues," which a "limited body of evidence links … to adverse health consequences." [6]

A separate, 440-plus-page supplement to The Scientific Foundation addendum includes 15 appendices, the first of which concerns "Chemical Additives and Food Packaging Contaminants in the U.S. Food Supply." [7] The preface to Appendix 1 indicates that it is intended to provide a non-exhaustive list of major classes of food additives and "food packaging contaminants" that "[h]ighly processed foods and beverages often contain."

Although the title of the appendix would seem to imply that the listed substances are disfavored in food, the text of the appendix includes disclaimers such as "[i]nclusion … does not imply adverse effects." However, the appendix then undermines the Guidelines' acceptance of U.S. Food and Drug Administration (FDA) regulatory clearance by noting that the designation of affirmed GRAS status (or otherwise permitted for intended use under existing U.S. regulatory pathways) "is not equivalent to proof of long-term safety for chronic, combined exposures across the full life course, especially at modern intake levels." [8]

The preface then goes on to define the limitations of the database by which these substances were determined to be safe and sums it up by calling for research in the following areas:

1. Direct quantitation of additives and packaging contaminants in commonly consumed U.S. foods, particularly highly processed foods with complex ingredient lists and foods packaged in plastic
2. Improved quantification of human exposure using biomarker confirmation, where feasible
3. Development of exposure biomarkers … for additives that are not readily measured in blood or urine
4. Long-term, randomized studies that test whether meaningful exposure reduction (versus habitual intake) improves prespecified metabolic or clinical outcomes. 

The table included in Appendix 1 (Table A1) lists the various "chemical additives" and food packaging contaminants of interest, along with the food types in which they are found and their regulatory status. Unfortunately, this table undermines confidence in the way in which the list was produced and the author's understanding of the regulatory system used to assess the safety of additives in food. For example, the third column of the table is titled "GRAS Status," even though many of the substances listed were cleared by way of a food or color additive regulation and not based upon a self-determined GRAS position.

Moreover, several of the substances listed as "affirmed" as GRAS, in fact, are the subject of color or food additive regulations. These substances and their associated regulations include:

• FD&C Blue No. 1 (21 C.F.R. 74.101)
• Aspartame (21 C.F.R. 172.804)
• Sucralose (21 C.F.R. 172.83). 

Color additives, by law, cannot be the subject of a GRAS determination, and macro additives used in food such as artificial sweeteners are rarely, if ever, used on the basis of a GRAS determination. Many other substances are listed in Table A1 which are also inaccurately labeled.

The food packaging contaminants listed in the table cover three categories: microplastics, phthalates, and per- and polyfluoroalkyl substances (PFAS). Frankly, it is surprising that the list is limited to only three given the purpose of the table. However, focusing on just these three, again, the table fails to get it right.

First, plastics are ubiquitous throughout the world. The presence of microplastics, however they may be defined, could be generated from the breakdown of plastics coming from a multitude of products, including toys, household appliances, automotive parts, textiles, and building and construction materials. The amount of plastics used in food-contact applications is a vanishingly small fraction of the total amount of plastics annually produced. As FDA has concluded:

Microplastics and nanoplastics may be present in food, primarily from environmental contamination where foods are grown or raised. There is not sufficient scientific evidence to show that microplastics and nanoplastics from plastic food packaging migrate into foods and beverages. People may be exposed to microplastics and nanoplastics through the air, food, and absorption through the skin from the use of personal care products. [9]

The notion that microplastics are entering the human body by way of ingestion of microplastics migrating from packaging to food does not comport with FDA's understanding that only oligomeric materials transfer from plastic packaging to food and only the extremely low-molecular-weight fraction of these materials (less than 1,000 Daltons; i.e., 1,000 g/mol) can pass through the gut wall. By contrast, a micron of polyethylene powder has a molecular weight of 3–6 million g/mol. In other words, migration from plastics in contact with food occurs at a molecular level, if at all.  

Second, the table wrongly indicates that phthalates have no regulatory clearance as food additives. In fact, while no phthalates have a recognized use based on a known GRAS determination, there are currently eight phthalates cleared by FDA for use in food packaging as plasticizers and one for use as a monomer. [10] No phthalates are authorized for direct addition to food.

At one time, there were several additional phthalates cleared by FDA for use in packaging applications. However, a petition filed by an industry group in 2018 showing that the use of 23 phthalates (and two other plasticizers) had been abandoned by the industry led to FDA revoking the clearances for those substances in food packaging. [11] The remaining eight are under FDA review and possible regulatory action if justified by the data. In the meantime, FDA has noted that its field studies indicate that "the use of phthalates in food contact applications is limited, and consumer exposure to phthalates from food contact uses is decreasing." [12] Some might say that although still a work in progress—like many other chemical substance safety assessments—the use of phthalates in food packaging is well under control.

Finally, the table includes a notation that PFAS are no longer sold for food-contact use as of 2024. This is partially correct. PFAS products are no longer cleared for use by FDA as grease-proofing agents for use on paper and paperboard. This includes several products that were the subject of negotiated, voluntary market phase-outs and 35 other products subject to Food Contact Notifications (FCNs) that FDA announced were no longer effective based on industry abandonment of these uses. [13] However, FDA authorizations for the safe use of PFAS in O-rings and gaskets in food processing equipment, as manufacturing aids added to other food contact polymers, and in non-stick applications for pots and pans remain in place. [14]

Dietary Exposure

Another area of concern mentioned in the 2025–2030 Guidelines relates to dietary exposure (i.e., dietary intake). Under the Appendix 1 subhead, "Exposure Measurement is a Major Evidence Limitation," the Guidelines suggest that human data on the amount of exposure to chemical additives and food packaging contaminants "is typically based on rough estimates using food frequency questionnaires rather than quantitative analytical measurements with validation of intake through biomarker assessments." [7]

The "rough estimates using food frequency questionnaires" mentioned above refers to the National Health and Nutrition Examination Survey (NHANES), which was first launched in the early 1960s. NHANES involves interviewing approximately 5,000 adults and children each year about their health; diet (i.e., identification and frequency of food, beverage, and supplement consumption); and personal, social, and economic characteristics. In addition, participants undergo dental exams and blood tests. Having been conducted for over 60 years, the survey provides a statistical basis for determining food intake patterns in the U.S. that amounts to more than just "rough estimates using food frequency questionnaires."

Also related to dietary exposure, one of the research priorities listed in Appendix 1 is the need for "direct quantitation of additives and packaging contaminants in commonly consumed U.S. foods." At present, FDA monitors the food supply for chemical contaminants through a variety of programs and acts when the level of a contaminant may raise safety concerns. [15] The Agency also reviews new scientific information and research on contaminants in foods that can enter the food supply through the growing and processing environments, in addition to partnering with other U.S. and international regulatory agencies on monitoring and regulatory activities for contaminants.

One of FDA's programs for monitoring chemical contaminants and nutrients in foods is the Total Diet Study (TDS), which systematically collects, prepares, and analyzes chemical contaminants and nutrients in foods representing the average U.S. consumer's diet. On January 27, 2026, FDA announced the release of the TDS Interface (TDSi), an interactive, web-based tool that provides access to findings from FDA's TDS. In making the announcement, FDA stated in a press release, "The TDSi release underscores the FDA's commitment to transparency and continuous improvement in its food chemical safety programs and aligns with Make America Healthy Again goals." [16]

For food packaging and other materials that may be used in contact with food, FDA assures safety by requiring detailed information on the oligomeric materials and additives used in packaging through the FCN clearance process. FDA requires manufacturers of packaging and other food-contact products to establish safety by providing data on:

• The quantity and identity of substances likely to migrate to food from the packaging material under the intended use conditions, including known impurities that result from residual starting reactants, breakdown, or byproducts
• An estimate of the concentration of these substances in the daily diet only and as added to the estimated daily intake from other uses of the same packaging material
• Toxicity data as needed to assess the safety of the intake level.

Highly Processed Foods

One notable aspect of the new Dietary Guidelines is the focus on "highly processed foods" rather than "ultra-processed foods" (UPFs). The Make America Healthy Again (MAHA) Report titled, Make Our Children Healthy Again: Assessment, [17] cites the consumption of UPFs as part of the reason for the rising rates of childhood chronic diseases. The report points out that there is no single, universally accepted definition of UPFs but describes them as "a category of industrially manufactured food products that undergo multiple physical and chemical processing steps and contain ingredients not commonly found in home kitchens."

On July 25, 2025, FDA and USDA issued a formal Request for Information (RFI) to help develop a uniform definition for UPFs. [18] The RFI suggests that a uniform definition for UPFs "would allow for consistency in research and policy to pave the way for addressing health concerns associated with the consumption of UPFs." Comments and responses to the RFI were due in October 2025. FDA has not yet issued a follow-up to the received comments and responses.  

Although UPFs are mentioned in the Dietary Guidelines, the focus is on "highly processed foods," while stating that the definition for the term as used in the report may be considered provisional. Regardless of how processed foods are described, Chapter 3 in The Scientific Foundation for the Dietary Guidelines for Americans, titled "Highly Processed Foods," seeks to implicate packaging used to hold such products as at least partially to blame for the health issues associated with such foods:

Many processed convenience foods are packaged or heated in plastic packaging, films, and coatings that can migrate into foods prior to ingestion. Emerging evidence indicates that chemicals derived from food packaging materials can accumulate in human tissues, including atherosclerotic lesions, reproductive tissues, and brains. Additionally, an emerging but limited body of evidence links the accumulation of these compounds to adverse health consequences. [6]

Finishing the connection, among the research priorities listed at the end of Chapter 3 are the need for "harmonized definitions of processed foods and a more accurate classification system that includes food ingredients, added sugars, refined oils, and refined starches under the umbrella of highly processed foods" and studies "to determine whether consumption of minimally processed foods and diets can reduce levels of food packaging contaminants (e.g., microplastics, phthalates) that have been shown to accumulate in human blood and tissues." [6]

The debate over whether to use the term "highly processed foods" rather than UPFs is mostly chimerical, as it is clear that whichever term is chosen will be designed to cover commonly consumed food products that "tend to have … refined grains, added sugars, refined oils, [and] long, complicated ingredient lists including chemical additives." [6] Another common characteristic of these foods is that they come packaged in plastics, films, and coatings. 

Conclusion

In the words of USDA, "For the first time in 25 years, the guidelines provide advice directly to consumers, while continuing to serve as the cornerstone of federal nutrition programs and policies. The message of this edition is simple: Eat real food. The guidance prioritizes whole, healthy, and nutritious foods and limits highly processed foods, added sugars, and refined carbohydrates." [1]

This is clearly a worthy goal, and one in which FDA has a part to play. It is also necessary to understand that it is not FDA's job—or the job of anyone else in the federal government—to dictate the manner in which food products are developed and marketed in the U.S., as long as the food meets FDA's and the Federal Food, Drug, and Cosmetic Act's requirements for safety and accurately labeled ingredient and nutritional content.

In a country as large as the U.S., it is also necessary for FDA to consider how food is made available to roughly 350 million people every day. Industry must be provided with the tools and materials it needs to manufacture, pack, package, transport, hold, and move food products from factories and farms to the kitchen table while ensuring that those products remain safe. While there may always be room for improvement, FDA does amazingly well in achieving this outcome under its current authority and available resources.

This article is reprinted with the permission of Food Safety magazine. It first appeared in the April/May 2026 issue.

[1] U.S. Department of Agriculture (USDA). Dietary Guidelines for Americans, 2025–2030. January 7, 2026. https://cdn.realfood.gov/DGA.pdf. 

[2] Misko, G.G. "The Views of Robert F. Kennedy Jr. on Food and Food Packaging Safety." Food Safety Magazine August/September 2025. https://www.food-safety.com/articles/10626-the-views-of-robert-f-kennedy-jr-on-food-and-food-packaging-safety. 

[3] USDA. Dietary Guidelines for Americans, 1980. 1st Edition. February 1980. https://www.dietaryguidelines.gov/sites/default/files/2019-05/1980%20DGA.pdf. 

[4] United States Code. "7 U.S.C. 5341—Establishment of dietary guidelines." https://www.govinfo.gov/app/details/USCODE-2021-title7/USCODE-2021-title7-chap84-subchapIII-sec5341. 

[5] USDA. Dietary Guidelines for Americans, 2025–2030. Page 7. January 7, 2026. https://cdn.realfood.gov/DGA.pdf.

[6] USDA. "The Scientific Foundation for the Dietary Guidelines for Americans, 2025–2030." https://cdn.realfood.gov/Scientific%20Report.pdf.  

[7] USDA. "The Scientific Foundation for the Dietary Guidelines for Americans, 2025–2030: Appendices." https://cdn.realfood.gov/Scientific%20Report%20Appendices.pdf. 

[8] USDA. "The Scientific Foundation for the Dietary Guidelines for Americans, 2025–2030: Appendix 1." https://cdn.realfood.gov/Scientific%20Report%20Appendices.pdf.

[9] U.S. Food and Drug Administration (FDA). "Microplastics and Nanoplastics in Foods." Content current as of July 24, 2024. https://www.fda.gov/food/environmental-contaminants-food/microplastics-and-nanoplastics-foods. 

[10] Code of Federal Regulations. "Plasticizers in Polymeric Substances." 21 CFR § 178.3740. https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-178/subpart-D/section-178.3740. 

[11] Code of Federal Regulations. "Indirect Food Additives: Adhesives and Components of Coatings; Paper and Paperboard Components; Polymers; Adjuvants, Production Aids, and Sanitizers." 21 CFR § 175, 176, 177, and 178. May 20, 2022. https://www.federalregister.gov/documents/2022/05/20/2022-10531/indirect-food-additives-adhesives-and-components-of-coatings-paper-and-paperboard-components. 

[12] FDA. "Phthalates in Food Packaging and Food Contact Applications." Content current as of October 29, 2024. https://www.fda.gov/food/food-additives-and-gras-ingredients-information-consumers/phthalates-food-packaging-and-food-contact-applications. 

[13] FDA. "FDA Announces PFAS Used in Grease-Proofing Agents for Food Packaging No Longer Being Sold in the U.S." Constituent Update. February 28, 2024. https://www.fda.gov/food/hfp-constituent-updates/fda-announces-pfas-used-grease-proofing-agents-food-packaging-no-longer-being-sold-us. 

[14] FDA. "Authorized Uses of PFAS in Food Contact Applications." Content current as of January 3, 2025. https://www.fda.gov/food/process-contaminants-food/authorized-uses-pfas-food-contact-applications. 

[15] FDA. "Food Chemical Safety." Content current as of February 5, 2026. https://www.fda.gov/food/food-ingredients-packaging/food-chemical-safety. 

[16] FDA. "FDA Releases New Interactive Tool for Total Diet Study (TDS) Results and New Data." Constituent Update. January 27, 2026. https://www.fda.gov/food/hfp-constituent-updates/fda-releases-new-interactive-tool-total-diet-study-tds-results-and-new-data. 

[17] The White House. "The MAHA Report: Assessment." May 2025. https://www.whitehouse.gov/wp-content/uploads/2025/05/MAHA-Report-The-White-House.pdf. 

[18] USDA and FDA. "Ultra-Processed Foods; Request for Information." Federal Register. July 25, 2025. https://www.federalregister.gov/documents/2025/07/25/2025-14089/ultra-processed-foods-request-for-information.