The Need for USDA Low-Carb Dietary Guidelines

Despite skyrocketing rates of obesity, type 2 diabetes, and other chronic metabolic conditions, the United States Department of Agriculture’s (USDA’s) Dietary Guidelines continue to push an outdated, universal policy that prioritizes carbohydrate-heavy eating patterns proven not to serve the needs of millions of Americans. For those struggling with metabolic conditions, following these conventional recommendations significantly perpetuates the problem. 

 

It’s time for a change.

 

A compelling, growing body of evidence, along with a rapidly expanding number of personal success stories, point to the power of low-carb nutrition in supporting weight loss, improving blood sugar regulation, and addressing the root causes of metabolic dysfunction. Yet, the current USDA Guidelines offer no formal low-carb option, leaving patients and practitioners without an official framework to support individualized healing.

 

This article is in collaboration with Nina Teicholz, scientific journalist, author, and founder of The Nutrition Coalition, Unsettled Science, and the best-selling book The Big Fat Surprise. We’ll explore why the inclusion of a low-carb dietary guideline is long overdue and essential. Let’s take a closer look at how low-carb guidelines support foundational wellness, why they’re especially crucial for Americans facing modern health epidemics, and what it would mean to shift our national nutrition policy toward metabolic flexibility and real food healing.

 

Our Main Argument: The USDA Dietary Guidelines Are Meant to Serve the General Public

 

 

When the USDA released its first Dietary Guidelines in 1980, most Americans were relatively healthy. At that time, 13.4% of US adults were obese, and less than 3% had type 2 diabetes. Chronic disease in children was rare at under 4%, and metabolic dysfunction was not the national crisis it is today. The Guidelines were developed during a period when the majority of the population was metabolically resilient, and therefore, generalized nutrition advice could still arguably serve most Americans.

 

Fast forward to today, and the landscape is dramatically different.

 

 

According to the CDC, over 40% of US adults are obese, and about one in 10 Americans has diabetes, the vast majority of which is type 2. According to a widely cited 2018 study published in Metabolic Syndrome and Related Disorders, only 12% of American adults were considered metabolically healthy, meaning that 88% had at least one marker of metabolic dysfunction. More recent analyses suggest that as many as 93% of US adults are now metabolically unhealthy.

 

The statistics for children are just as concerning. About one in five children in the US is obese, and rates of type 2 diabetes, fatty liver disease, autoimmune disorders, and other chronic conditions in youth have considerably risen to more than 40% of school-aged children in recent years. The American Academy of Pediatrics has called it a public health emergency.

 

Yet, despite this seismic shift in the health of the general public, the USDA Dietary Guidelines have barely evolved to reflect these changes. The core recommendations continue to promote a high-carb, grain-focused diet, with limited accommodation for individuals struggling with insulin resistance, obesity, or chronic illness.

 

 

This disconnect is a violation of the USDA’s own mission. The statute that governs the Dietary Guidelines for Americans (the National Nutrition Monitoring and Related Research Act of 1990) explicitly states that the Guidelines are meant to “promote health, help prevent diet-related chronic diseases, and meet nutritional needs.”

 

By failing to offer dietary guidance tailored to the metabolic realities now faced by the majority of Americans, the USDA Guidelines are no longer fulfilling their mandate. What once may have served a healthy population now puts many at greater risk. Without a meaningful, science-based low-carb option, the Guidelines ignore the needs of millions and fall short of their public health responsibility.

 

The Evident Disconnect Between USDA Dietary Guidelines and American Health Status

 

The growing disconnect between the USDA Dietary Guidelines and the health status of the American public hasn’t gone unnoticed. In fact, Congress itself recognized the urgency of this issue and mandated a review by the National Academies of Sciences, Engineering, and Medicine (NASEM).

 

In their 2017 report, NASEM delivered a clear and powerful warning:

 

“Given the prevalence of chronic disease and risk for chronic disease in the population, this National Academies committee believes it will also be essential for the DGA Policy Report to include all Americans whose health can benefit by improving their diet based on the scientific evidence. Without these changes, present and future dietary guidance will not be applicable to a large majority of the general population.”

 

NASEM acknowledged that the current Guidelines exclude most Americans, simply because they do not offer appropriate recommendations for people already suffering from chronic illness or at risk of developing it. In a nation where six out of 10 adults live with at least one chronic disease, and four in 10 live with two or more, this is a glaring omission.

 

 

Even more concerning, the USDA and United States Department of Health and Human Services (HHS),  the two agencies jointly responsible for developing the Guidelines, have given conflicting and confusing public statements about who the Guidelines are really for.

 

For years, USDA and HHS officials have repeatedly claimed that the Dietary Guidelines are designed for “all Americans ages two and up”, suggesting that their recommendations are broad, inclusive, and universally applicable. 

 

However, in a striking contradiction, during a 2023 stakeholder meeting as part of the ongoing revision process for the Dietary Guidelines for Americans (DGA), USDA-HHS officials made it clear that the DGA is not intended for people with chronic diseases, which now represent the majority of the US population.

 

One Dietary Guidelines committee member even stated the following during a 2020 Dietary Guidelines Advisory Committee Public Meeting, “But if you excluded such people [with a particular disease condition]… that would not actually be representative of who lives in this country.” 

 

Exactly. 

 

These conflicting messages leave the public and healthcare professionals in a state of confusion. On one hand, Americans are told to “follow the science” and trust the Dietary Guidelines as the national standard. On the other hand, they are implicitly, and sometimes explicitly, told that these very guidelines were never meant for those with the most urgent dietary needs.

 

This double-speak has eroded trust and delayed meaningful progress in shaping dietary policy that actually serves public health. If the Dietary Guidelines are truly meant to be a tool for disease prevention and health promotion, they must evolve to reflect the scientific evidence on nutrition for chronic illness, especially when a low-carb approach has shown tremendous efficacy in reversing markers of metabolic dysfunction.

 

A Call for Inclusion, Not Mandates

 

 

It’s important to be clear: we’re advocating for a low-carb dietary guideline option. Just as we wouldn’t ask every American to follow a ketogenic diet protocol (even though frankly, it would be ideal for their overall health), we’re not suggesting the USDA eliminate other dietary models. 

 

What we are calling for is the inclusion of a science-backed, low-carb option within the existing Guidelines for those who would benefit from it most.

 

Is that asking too much?

 

The Dietary Guidelines already recognize that America is not a monolith. In recent years, they’ve introduced culturally tailored dietary patterns for different racial and ethnic groups, acknowledging that food preferences and nutritional needs vary widely. 

 

That same logic must now extend to metabolic health. Americans are metabolically diverse. A one-size-fits-all high-carb diet no longer serves a population where the majority is living with or at risk for chronic illness.

 

Including a low-carb option in the Guidelines would give individuals, families, and healthcare providers a legitimate, research-supported tool for addressing obesity, type 2 diabetes, insulin resistance, and other diet-related conditions. It’s a matter of equity, access, and scientific integrity.

 

To truly serve the American public, the USDA Dietary Guidelines must evolve to reflect our diverse states of health.

 

Now that we’ve discussed our main argument, here are some other reasons for the need for USDA Low-Carb Dietary Guidelines.

 

Effective Care Demands Real Choice

A second reason to have a low-carb option is that effective care demands real choice.

 

The reality is that USDA-HHS Dietary Guidelines dictate the foundation of nearly every aspect of national nutrition policy. These Guidelines serve as the master template that shapes institutional protocols, insurance coverage, nutrition education, food assistance programs, and clinical recommendations. In other words, they set the standard for what is considered “safe,” “appropriate,” and “medically accepted” nutrition care.

 

Without formal recognition of low-carb approaches in these Guidelines, doctors, patients, and healthcare systems are effectively denied a powerful, evidence-based option for treating metabolic disease.

 

This top-down policy influence creates a cascade of institutional barriers. Major organizations, such as the American Diabetes Association (ADA) and the American Heart Association (AHA), are unlikely to adopt low-carb models without full support from the USDA-HHS. These organizations face liability concerns, funding dependencies, and deep-rooted inertia. Without federal guidance acknowledging the validity of low-carb approaches, professional organizations won’t risk updating their own protocols, even when the science is compelling.

 

This leaves clinicians in a difficult, and often dangerous, position. A physician who recommends a low-carb diet as a therapeutic tool for type 2 diabetes or metabolic syndrome is technically stepping outside the bounds of the accepted standard of care. This exposes them to malpractice risk and professional scrutiny, even when those risks are lower than continuing the standard high-carb diet for metabolically compromised patients.

 

Additionally, insurers won’t cover nutrition counseling or ongoing support for dietary strategies not formally endorsed by major medical authorities. This both limits patient access and deters providers from incorporating nutrition into their care. 

 

Medical schools and dietetic programs also closely follow the USDA-HHS framework, although most students receive fewer than 20 hours of nutrition training, which primarily focuses on macronutrient basics. 

 

To make things worse, if the Guidelines don’t endorse it, students don’t learn it. As a result, a new generation of healthcare professionals continues to graduate with little to no exposure to low-carb dietary strategies, even though these strategies have reversed type 2 diabetes in clinical trials and thousands of real-world cases.

 

The unfortunate result is a locked system with a massive feedback loop, in which even strong, peer-reviewed evidence for low-carb efficacy can’t make its way into widespread clinical practice. Individual doctors are often isolated, forced to choose between doing what is best for their patients and risking professional consequences.

 

And the truth is, most healthcare professionals, especially doctors, begin their careers hundreds of thousands of dollars in debt and years behind their peers, making it a serious personal and financial risk to support a “controversial” dietary approach.

 

A federal policy change can help break this cycle. 

 

The inclusion of a well-defined, evidence-based low-carb option in the USDA Dietary Guidelines creates true clinical freedom. Doctors would gain legal and professional backing to personalize care. Patients would finally have access to a broader range of nutrition therapies tailored to their health needs and biology.

 

We’re asking for low-carb guidelines to be a legitimate option. It’s time to give doctors and patients the real choice of tools and the freedom they need to pursue healing that works.

 

The USDA Ignores Low-Carb Science

The third reason why a low-carb option needs to be included in the USDA Guidelines lies in the governing agency’s dismissal of scientific data.

 

 

Perhaps the most troubling aspect of this debate is the USDA’s long-standing pattern of ignoring, downplaying, or outright suppressing the science on low-carb diets. Despite a growing body of high-quality, peer-reviewed studies showing the benefits of low-carb protocols for weight loss, type 2 diabetes reversal, cardiovascular markers, and metabolic health, the USDA has consistently failed to incorporate this evidence into the Dietary Guidelines.

 

The suppression can be traced back at least to 2015, when the Dietary Guidelines Advisory Committee (DGAC) reviewed more than 40 studies on low-carb diets. These studies showed significant and clinically meaningful outcomes. 

 

Yet when the expert report was published, none of this research was featured or highlighted. In internal emails obtained by Nina Teicholz via FOIA (Freedom of Information Act) requests, Harvard nutrition professor Frank Hu, who was a member of the DGAC, wrote:

 

“I was wondering if we should have a separate section on low-carb diets rather than burying it.”

 

And that’s precisely what they did. They buried it.

 

By the time the 2020 Guidelines were being developed, the USDA went even further: they conducted a review of low-carb diets but somehow claimed they could not find a single eligible study. This included none of the 40+ studies they had previously acknowledged just five years earlier. 

 

The absence of these studies was due to the USDA’s manipulation of the inclusion criteria, which systematically filtered out any evidence that supported a low-carb pattern.

 

 

In an even more baffling move during the 2025 Guidelines process, rather than reviewing the growing body of real-world clinical data on low-carb diets, the USDA turned to computer modeling. They simulated what a low-carb diet might look like by removing the standard 50–60% of calories from carbs, but failed to replace those calories with anything else. 

 

The predictable result? 

 

They declared the diet “nutritionally deficient.” Of course it was. Any diet is deficient if you remove half the calories and don’t replace them with nutrient-dense alternatives like animal proteins and healthy fats.

 

This pattern reveals a troubling bias. Rather than evaluating the actual evidence, including long-term randomized controlled trials and real-world clinical success, the USDA continues to manipulate its process to exclude low-carb diets from consideration. This is frankly public health malpractice.

 

Low-carb diets are clinically backed protocols that are now recommended in international guidelines, used by forward-thinking clinicians across the US, and supported by numerous randomized controlled trials. Ignoring this science only keeps it out of the hands of the very people who need it most: patients, families, and practitioners seeking safe, effective strategies to reverse chronic disease.

 

It’s time the USDA stopped burying the science and started facing it. Americans deserve guidelines grounded in comprehensive, transparent, and unbiased science.

 

Proposing the Keto Food Pyramid

 

 

To help fill the gap left by the USDA’s current Guidelines, we propose an evidence-based Keto Food Pyramid —a visual, practical framework designed specifically for individuals with metabolic diseases. Unlike the traditional food pyramid, which places carb-rich grains at its foundation, this pyramid is built around foods that support blood sugar balance, reduce insulin resistance, and promote metabolic healing. 

 

The Keto Food Pyramid is from the study Myths and Facts Regarding Low-Carbohydrate Diets, which concludes that low-carb and keto diets are supported by a large body of clinical trial research demonstrating both safety and efficacy. The study also reports that there are no harmful side effects, no increase risk of heart disease or mortality, and these diets can be sustainable and nutritionally complete.

 

While a general low-carb diet typically allows up to 130 grams of carbs per day, a keto diet restricts carbs to 50 grams or below daily. This level of carbohydrate restriction leads to a shift in metabolism, away from glucose dependence and toward fat burning, known as ketosis. This change can deliver faster, more profound therapeutic benefits for those struggling with obesity, type 2 diabetes, fatty liver, PCOS, and other metabolic conditions.

 

The Keto Food Pyramid is built on a foundation of nutrient-dense, metabolically stabilizing foods:

 

Base/Foundation:

 

• Animal proteins like beef, lamb, poultry, seafood, and eggs
• Whole-fat dairy such as raw cheese, butter, and heavy cream (for those who tolerate dairy)
• Healthy fats and oils, including animal fats (tallow, lard) and plant-based options like avocado, coconut, and olive oils

 

These foods should be prioritized as they provide the essential building blocks for hormone production, satiety, and blood sugar regulation, precisely what the metabolically unwell need to heal.

 

Middle Tier:

 

• Low-carb vegetables such as leafy greens, cucumbers, zucchini, asparagus, and cauliflower
• Low-carb fruits like avocados and tomatoes

 

These foods should be consumed in moderation to ensure they don’t exceed the 50-gram carb limit.

 

Top of the Pyramid:

 

• Starchy vegetables like sweet potatoes, beets, and carrots
• Low-sugar fruits such as berries
• Nuts and seeds, including almonds, peanuts, and sunflower seeds 

 

These foods should be limited due to their sugar, starch, and anti-nutrient content. 

 

High-carb foods, including bread, pasta, grains, legumes, and sugary snacks, should be avoided entirely, as they quickly push individuals out of ketosis and can worsen insulin resistance.

 

This pyramid offers precision nutrition designed to target the root causes of metabolic disease and certain chronic conditions. By reducing blood sugar spikes and lowering insulin levels, a keto approach can help reverse the trajectory of metabolic dysfunction far more effectively than a standard high-carb diet.

 

Including keto-specific guidelines in the USDA framework would provide Americans, especially those living with chronic illness, with a scientifically sound and accessible path to healing. If we are serious about tackling the metabolic crisis in this country, we must start by providing people with the tools and dietary guidance that actually work.

 

Closing Thoughts On USDA Low-Carb Dietary Guidelines

 

 

In our private functional medicine practice, we’ve had the honor of working with thousands of clients navigating complex, chronic illnesses, many of whom came to us after conventional dietary advice failed them. 

 

Through personalized low-carb, keto, and Carnivore approaches, we’ve seen firsthand just how powerful nutritional therapy can be in restoring health, reversing metabolic dysfunction, and supporting true root-cause healing.

 

While many in our community require additional protocols beyond diet alone, foundational nutrition remains the starting point. A properly formulated, nutrient-dense diet is what makes deeper healing possible. For those living with insulin resistance, obesity, or chronic inflammation, keto-based protocols can be life-changing.

 

Our nation is in the midst of a health crisis, with millions of Americans suffering from preventable, diet-related diseases. Offering a science-backed keto dietary option within the USDA Guidelines would be a monumental step forward that could save lives, ease suffering, and finally give patients and practitioners the tools they need to succeed.

 

We’re hopeful that this change is coming. We would like to express our deepest gratitude to Nina Teicholz, the Nutrition Coalition, and the MAHA movement for their courageous advocacy for the inclusion of low-carb options in national nutrition policy. Their tireless efforts are paving the way for a more inclusive, compassionate, and evidence-based perspective for public health.

 

It’s time our dietary guidelines reflect the reality of America’s health status and offer real solutions for healing. With continued advocacy and a growing wave of support, we believe this vision is possible and within reach.

 

A Personal Note From Judy Cho

The path forward is clear. The science is evident. The stories of transformation are countless, and the need for change has never been greater. Having a low-carb option in the USDA Dietary Guidelines aligns national policy with the current health realities of the American people. This low-carb option offers Americans, particularly those with metabolic issues, a viable opportunity to regain their health through a proven dietary approach. 

 

Frankly, I never intended to start Nutrition with Judy or start a private functional medicine practice, Empower Functional Health. I had a successful career in management consulting, but when I became seriously ill, everything changed. I hit rock bottom, and the conventional system had no answers for me beyond antidepressants, antipsychotics, and vague advice like “try intuitive eating” and “everything in moderation” from registered dietitians. 

 

Out of pure necessity, I had to find another way. I had been plant-based and high-carb for over a decade, and it nearly cost me my life. At my lowest point, I was hospitalized in a mental health facility, against my will. You can read the full journey here.

 

It was through trying a strict low-carb, Carnivore diet that I got a second chance at life. I began to heal mentally and physically, and now I serve because no one should go through what I went through. 

 

The truth is that my story is not isolated. 

 

Conventional medical care focuses on managing symptoms with short-term fixes. Too many people are suffering from unnecessary (chronic) illnesses, stuck in a system that doesn’t offer root-cause answers. And so many people silently suffer and are where I once was: desperate, unwell, and running out of options.

 

No one wants to spend extra money on healthcare or constantly worry about what they eat or wish they had more energy. People want to trust the dietary guidelines and labels on food packages. People wish to (and should have) health as a fundamental right. People should have the ability to live the life they are meant to live.

 

Until our policies change, until the medical system advocates for root-cause healing, we will continue to advocate. Until a low-carb, meat-based diet becomes a foundational part of our nutritional guidelines, we will continue to serve. 

 

My real hope is that one day, conventional health recommendations will reflect what truly works: a low-carb, nutrient-dense, primarily animal-based diet that recognizes and embraces the health-value of saturated fats.

 

Until then, we will keep going. We will keep sharing the truth.

 

Because sadly, here’s the truth about the state of our health in America:

 

• Obesity and Overweight in the US: In 2021, an estimated 15.1 million children between ages 5–14 and 21.4 million adolescents aged 15–24 in the United States were considered overweight or obese. Among adults 25 years and older, 172 million were living with overweight or obesity (Health Data).
• Rising Childhood Obesity Rates: Childhood obesity has steadily increased over the last 20 years, now affecting 14.7 million youth ages 2–19. Prevalence differs by age group: 12.7% in children 2–5 years, 20.7% in those 6–11 years, and 22.2% in adolescents 12–19 years (CDC).
• Type 2 Diabetes: Among adults, 90–95% of all diabetes diagnoses are type 2 diabetes. Alarmingly, around 5,300 children and teens are newly diagnosed every year. Once called “adult-onset diabetes,” this condition now increasingly affects younger populations, though it can often be managed through nutrition and lifestyle strategies (CDC).
• Prediabetes Prevalence: By 2021, about 97.6 million U.S. adults aged 18 and over—38% of the adult population—were living with prediabetes (CDC).
• Autoimmune Conditions: Nearly 1 in 10 Americans are affected by an autoimmune disease.
• Chronic Illness in Children: Over 40% of school-aged kids and adolescents have at least one ongoing health condition (CDC).
• Chronic Disease in Adults: In the adult population, 60% live with at least one chronic disease, while 40% manage two or more (CDC).
• Prescription Medication Use: In 2023, U.S. spending on prescription medications reached $449.7 billion, reflecting an 11.4% increase from 2022. That equals roughly $1,564 per person, the highest per-capita rate among developed nations (Statista; CMS). More than two-thirds of American adults (66%) use prescription drugs, with rates especially high in older populations and those with chronic health problems (HPI Georgetown).
• Medical Costs of Childhood Obesity: In 2019 dollars, obesity-related medical costs for U.S. children were estimated at $1.3 billion annually. On average, children with obesity had $116 higher healthcare expenses per year compared to children at a healthy weight (CDC).

 

DISCLAIMER: This content is for educational purposes only. While we are board-certified in holistic nutrition and are functional practitioners, we are not providing medical advice. Whenever you start a new diet or protocol, always consult with your trusted practitioner first.