The U.S. Department of Agriculture (USDA) released its Dietary Guidelines for Americans, 2025-2030 on January 7, 2026. The two Cabinet officers responsible for their preparation and release, U.S. Department of Health and Human Services Secretary Robert F. Kennedy, Jr. and USDA Secretary Brooke Rollins, referred to the updated Guidelines as “the most significant reset of federal nutrition policy in our nation’s history.” Secretary Kennedy positioned the new Guidelines as prioritizing whole, nutrient-dense foods, specifically identifying the importance of protein, dairy, vegetables, fruits, healthy fats, and whole grains in the diet, as well as the need to sharply reduce consumption of highly processed foods. Reflecting Make America Healthy Again (MAHA) policies, the Guidelines are presented with the claim of combatting chronic disease associated with diet and lifestyle in the United States. 

The new Guidelines indicate that American households should significantly limit their consumption of highly processed foods containing chemical additives, and foods and beverages that include artificial flavors, petroleum-based dyes, artificial preservatives, and low-calorie non-nutritive sweeteners. Accompanying the Guidelines is an addendum, The Scientific Foundation for the Dietary Guidelines for Americans, which notably includes 15 appendices, the first of which, Appendix 1, concerns “Chemical Additives and Food Packaging Contaminants in the U.S. Food Supply.” 

This Appendix is intended to provide a non-exhaustive list of major classes of food additives and what the Appendix describes as “food packaging contaminants,” which specifically lists microplastics, phthalates, and PFAS (per- and polyfluoroalkyl substances). The Appendix also sets out various chemical additives which are described based on their function in food, the foods in which they may be found, and their “Generally Recognized as Safe (GRAS) status.” 

The Appendix also indicates that there are gaps and limits in human evidence available for these substances to assess long-term health effects and risks due to dietary exposure. Further, the Appendix provides a series of high-impact research priorities, including “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.”

The formatting and content of Table A1 portrays an incomplete – and in several cases, inaccurate – picture of the current U.S. Food and Drug Administration (FDA) regulatory status of those substances included in the Table. In the “GRAS Status” column, many substances are designated as “Affirmed” with a corresponding year, which implies that the substances have been affirmed by FDA as GRAS (such GRAS-affirmed substances are listed in 21 CFR Parts 184 or 186 of FDA’s food additive regulations, which were promulgated following input from the public through notice and comment rulemaking).  

The substances identified as GRAS “affirmed” include five FD&C colors, aspartame, and sucralose, which notably are not GRAS affirmed substances in Parts 184 or 186 of FDA’s regulations. Rather, these substances are regulated food or color additives that FDA has evaluated in response to a food additive or color additive petition, and which FDA has concluded to be safe for the conditions of use specified in the authorizing regulations, e.g., 21 CFR 74.101 (FD&C Blue No. 1); 21 CFR 172.804 (“Aspartame”); and 21 CFR 172.831 (“Sucralose”).  

The Appendix 1 overview also asserts that the purported “GRAS status” designation in Table A1 is “not equivalent to proof of long-term safety for chronic, combined exposures across the full life course.” However, the clearances for the noted substances, which are not cleared as GRAS but on the basis of an FDA promulgated food additive or color additive regulation reflect precisely FDA’s determinations of safety for the uses prescribed in the authorizing food or color additive regulations. [1]   

Likewise, in the food packaging contaminants section PFAS is described as “no longer sold for food contact use (2024).” While FDA has announced market withdrawals and abandonment of authorizations for uses of certain PFAS as grease proofing agents in food-contact paper, FDA recognizes the continued safe use of numerous authorized PFAS in other food-contact applications, such as in rubber O-rings and gaskets in food processing equipment, manufacturing aids added to other food contact polymers, and non-stick applications on pots and pans.

[1] Section 409(c)(3)(A) of the Federal Food, Drug, and Cosmetic Act states that “no such regulation shall issue if a fair evaluation of the data before the Secretary fails to establish that the proposed use of the food additive, under the conditions of use to be specified in the regulation, will be safe.”  

Section 409(c)(5) of the Act mandates that FDA “shall consider” in determining whether a food additive is safe both the “probable consumption of the additive” and the “cumulative effect of such additive in the diet of man or animals.”