When Project 2025 began making headlines this summer, it was largely for the ways the conservative “wish list” of policies for a future Trump administration would restructure the entire federal bureaucracy, deepen abortion restrictions and eliminate the Department of Education.
But the document – a proposed mandate for the next Republican president authored by the Heritage Foundation, a conservative thinktank – also outlines steps that would radically transform food and farming, curtailing recent progress to address the excess of ultra-processed foods in the United States. Among those: weakening the Supplemental Nutrition Assistance Program (Snap), ending policies that consider the effects of climate change – and eliminating the US dietary guidelines.
“This is a deregulatory agenda,” said Marion Nestle, a professor of nutrition and food policy at New York University. “And what we know historically from deregulation is that it’s really bad for consumers, it’s bad for workers, it’s bad for the environment.”
Project 2025 proposes changes to the country’s food assistance programs, like Snap and the Women, Infants and Children supplemental nutrition program (Wic), that Nestle believes are intended to dismantle such programs. It also calls for ending support for school meals.
But one of the most notable of its proposals is calling on the next Republican president to eliminate or reform the dietary guidelines. Those guidelines form the basis for all federal food policies, from school meals to Snap, Wic and other programs.
“There is no shortage of private-sector dietary advice for the public, and nutrition and dietary choices are best left to individuals to address their personal needs,” the document reads.
The food industry has long pushed the idea that chronic, diet-related health conditions, like diabetes and obesity, are the result of individual choices – like not exercising enough. Today, nearly 42% of adults in the US are obese and about 12% have diabetes. But nutritionists emphasize that those conditions are not the result of a moral failing, but rather conditions caused by the ingredients and policies (like aggressively advertising to children) pushed by food companies.
Nestle sees that as one of many pro-business policies outlined in Project 2025’s agricultural provisions that trusts companies to prioritize public health over profit.
“There’s twice as many calories available in the food supply as the country needs on average. So the food industry is enormously competitive in selling calories,” she said. “Republicans want to deregulate, and give those food businesses every opportunity to make as much money as they possibly can, regardless of the effects on health and the environment.”
Experts also fear the way Project 2025 could undermine the work being done by the Food and Drug Administration and the Department of Agriculture to limit the flow of ultra-processed foods in the US food supply.
Today, ultra-processed foods make up 73% of the US food supply, according to Northeastern University, and provide the average US adult with more than 60% of their daily calories. While the science is still emerging, researchers are increasingly linking UPFs to a range of health conditions including diabetes, obesity, depression and certain cancers.
At the FDA, work is currently under way to develop a front-of-package label that corporations would be required to print on the fronts of products indicating when an item is high in sugar, fats, sodium or calories (the exact label has not yet been made public). Although the label wouldn’t specifically indicate when a food is ultra-processed, it would likely apply to a high percentage of UPFs in the food system because many contain large quantities of those nutrients.
And at the USDA, members of the US dietary guidelines advisory committee are currently meeting and will give their recommendations for the 2025-30 dietary guidelines later this year. As it considers the advice it will issue to the USDA and the Department of Health and Human Services, the committee has been tasked with also evaluating research related to UPFs. It’s unclear what they’ll recommend - and whether that advice will make it into the 2025 dietary guidelines - but it’s a significant development for the committee to even consider ultra processing.
But while Project 2025 makes no specific references to front-of-package nutritional labels like those currently under consideration at the FDA, Lindsey Smith Taillie, a professor of nutrition and co-director of the Global Food Research Program at the University of North Carolina, Chapel Hill, says that eliminating the dietary guidelines will inevitably affect those.
“It’s almost like they’re removing scientific evidence from federal food policy,” she said.
Even if Trump isn’t elected next month, Philip Kahn-Pauli, director of legislative affairs at the Center for Science in the Public Interest, says he is “already seeing the impact of the policy proposals in Project 2025 in Congress today”.
While approving funding for government agencies in 2025, the Republican-controlled House considered a bill that would “fundamentally change” the dietary guidelines process, he said in an emailed statement. The budgetary bill would have, among other things, nullified the currently in-process 2025 dietary guidelines. Although that bill was abandoned in favor of a continuing resolution to fund the government, Kahn-Pauli said, “the fact that there was such a partisan attack” on the dietary guidelines “signals a new focus on undercutting evidence-based policy”. He expects to see more attacks on the guidelines in the new year.
Across the food system, Nestle says, Project 2025 would promote industry over climate, public health or welfare concerns: “The basic principle here is: don’t do anything that’s going to reduce industry profits.”
