Lactose Misinformation is Intolerable

Dairy’s opponents have a new bad-faith argument — that because of lactose intolerance, dairy is inappropriate for diverse communities. It’s a bogus case, but it seems to be seeping into public policy discussion. Before regretful decisions start to be made to the detriment of public health, let’s make it clear: Dairy is a socially inclusive, equitable solution that can benefit all communities.

By the standards of contemporary misinformation, it’s easy to see how lactose-intolerance arguments have gained traction. They include a fact — that some populations have difficulty digesting lactose, a natural sugar found most commonly in milk — and turn it into a myth: that because of this intolerance, dairy should be de-emphasized as a source of nutrition.

But what suits the need of an activist group that may or may not be focused on nutrition doesn’t suit the public interest. A closer look at what dairy provides, and how it can be provided in a way that respects people’s lived dietary experiences and nutritional needs, shows just how misguided, and potentially damaging, an anti-dairy message cloaked in equity rhetoric can be.

A few points to ponder:

  • Dairy is an important source of 13 essential nutrients, including three of the four identified as of public health concern among Americans in the 2020 Dietary Guidelines for Americans. Overall, 89 percent of Americans under-consume dairy, according to that guidelines committee’s report.
  • Dairy beverage substitutes, such as plant-based beverages, are not nutritionally equivalent to dairy and are in fact inferior in significant ways. Even fortified soy drinks, currently recommended as a substitute for dairy under the U.S. dietary guidelines, are chemically dissimilar and may interact with human bodies differently.
  • At the same time, a lactose-free substitute for traditional milk is available that offers true nutritional equivalence. That substitute is called… lactose-free milk, and it solves tolerance issues for most people. It’s hard to imagine a more equitable nutritional solution than giving everyone the same beverage, tailored to their needs — unless, of course, you’re either misinformed or not truly concerned about equity.
  • Beyond milk, lactose is far from predominant in dairy products, giving lactose-intolerant consumers even more options. Butter, for example, has only trace amounts of lactose. Yogurt has much less lactose than milk, and many varieties of cheese, including Cheddar, Colby, Monterey Jack, mozzarella and Swiss, are also low-lactose. Kefir, a thicker, creamier beverage, is lower-lactose than milk, and includes probiotics that help with lactose digestion. These options provide abundant nutrition within healthy dietary patterns, even for many who experience varying levels of lactose intolerance. Here is a helpful guide to lactose in dairy and how to consume dairy with confidence.
  • Awareness of lactose-free options is low in diverse populations, which shows a need for education, not deprivation. According to research done last year by the International Food and Information Council, more than half of members of U.S. racial and ethnic minority groups have never tried lactose-free milk, despite having higher reported percentages of lactose intolerance than White Americans.
  • With increasing sales and newer production practices, the traditional price premium between traditional and lactose-free milk is showing signs of fading, with store brands now offering lactose-free milk.

Nutrition science is challenging, and nutrition policy even more so, as different interest groups try to mold eating habits in ways that sometimes are meant to achieve goals other than effective nutrition. In the end, federal food policy is meant to help people nourish themselves — and for the highest quality nourishment, dairy still provides an unparalleled package, for everyone.

It’s a fact: A healthy, rich-in-dairy diet can be low in lactose or lactose-free. Be wary of arguments that are truth-free instead.

 

 

Dairy Deserves Prominence in the Dietary Guidelines

The federal government is pressing ahead in crafting a new iteration of the Dietary Guidelines for Americans, the twice-a-decade guide to science-based advice on what to eat and drink for health and well-being. The guidelines also inform federal nutrition programs, such as school meals and food assistance.

Dairy, to no one’s surprise, is critical to the discussion. For the sake of our nation’s health, this discussion has to be done right, with proper deliberation and dairy maintaining its role as a central component of healthy eating.

A committee of experts is reviewing the latest evidence and preparing recommendations for the next iteration of the guidelines, due next year. As we said in the comments we submitted to that committee: Dairy foods are essential for optimal nutrition and health. Foods such as milk, cheese and yogurt provide a unique package of nutrients American often lack, such as calcium, vitamin D, potassium, protein and iodine. Dairy also reduces chronic disease risk, lowers blood pressure, improves blood sugar control, and protects bone health. And dairy is especially important for children, who need adequate calcium and protein for growth and development.

When the government released its current guidelines in 2020, it noted that dairy is under-consumed by 89 percent of the population. Dairy’s role as a critical nutrient provider, and its underconsumption, is why dairy needs to continue as its own food group, with three recommended servings per day, in the 2025 guidelines. That standard is consistent with current practice, reflected in the nutrition guidance of many other countries and health organizations, and supported by decades of scientific research. Guidelines that don’t give dairy its due simply would not be credible – not when the science, the general public and the mainstream nutrition community all recognize that, without dairy, health outcomes suffer and families, especially families with children, don’t get the nourishment they need.

Maintaining dairy’s place at the bedrock of proper nutrition is of paramount importance as the guidelines are under review. NMPF is fighting for dairy’s necessary pride of place through our public comments, our meetings at all levels of decision-making, our partnerships with allied organizations, and our daily fight against anti-dairy misinformation in media interviews and outreach. Because, as is inevitable in Washington, the guidelines are the subject of intense advocacy efforts, often by groups that have goals in mind other than better nutrition.

For example, some vegan and environmental activists are pushing for replacing some dairy foods with plant-based alternatives in the guidelines, all in the name of reducing greenhouse gas emissions. Even setting aside the flawed sustainability arguments, the answer to that is no. Plant-based products are not nutritionally equivalent to dairy foods and do not have the same health effects. In fact, most plant-based alternatives are low in protein and have added sugars, oils, and synthetic nutrients that are in no way nutritionally equivalent to dairy in terms of human health.

Children who consume plant-based alternatives instead of dairy may be at risk of nutritional deficiencies, growth impairment, and bone fractures. Pregnant women who avoid dairy may not get enough iodine, which is essential for fetal brain development. Three of the four nutrients identified in 2020 as issues of public concern because of their widespread under-consumption — specifically vitamin D, calcium and potassium — are abundant in dairy, but not so much in plant-based products. And low-income consumers who choose plant-based alternatives may face higher food costs and lower nutrient density.

And when we talk about low-income consumers, inevitably we need to talk about equity. Dairy foods are widely available, affordable, and culturally acceptable for most Americans. They’re also a major component of federal nutrition programs, such as school meals and WIC, which serve millions of low-income and vulnerable Americans and help ensure that children and families have access to nutritious foods that support their health and learning.

Dairy is an excellent nutritional option for populations who face disproportionate rates of chronic diseases, such as hypertension, diabetes, and osteoporosis. And dairy foods can accommodate different preferences and needs, such as lactose intolerance, vegetarianism, or environmental concerns.

Contrary to the claims of misguided social-justice activists that dairy products can’t possibly serve diverse populations because of intolerance, the reality is that lactose-free and low-lactose dairy products, such as lactose-free milk, yogurt, and hard cheeses, can provide the same nutrients and benefits as regular dairy. For all these reasons and more, dairy needs to maintain its prominence in American diets, in federal programs, and in the Dietary Guidelines for Americans.

The guidelines also need to be the product of thoughtful, science-based, and careful deliberations. Another threat facing dairy is that, as election-year politics combine with activist agendas, a devil’s brew of flawed science and ill intentions could result in hastily released guidelines that do a disservice to American health and destroy the very legitimacy of the guidelines. This is the worst possible outcome of all – and it’s one we’re guarding against as we work on this issue through the fall.

Dairy foods are essential for optimal nutrition and health. They provide a unique package of nutrients, they’re an equitable option for health and wellness, and they’re widely available, affordable, and culturally acceptable for most Americans. They deserve thoughtful consideration and a prominent place in the dietary guidelines, as well as in our plates and cups.


Gregg Doud

President & CEO, NMPF

 

NMPF Touts Dairy’s Importance in Dietary Guidelines Comments

NMPF underscored dairy’s important role in American diets in comments submitted July 26 to the Dietary Guidelines Advisory Committee (DGAC). Milk supplies 13 essential nutrients and dairy is a good or excellent source of nutrients that continue to be identified as nutrients of public health concern—calcium, vitamin D and potassium.

NMPF stated in its comments that dairy should remain a distinct food group, with at least three servings recommended for older children and adults, and corresponding amounts for younger children in the next Dietary Guidelines for Americans (DGA). NMPF also argued against suggestions that plant-based alternatives be included as allowable substitutes for dairy beyond fortified soy, noting that little to no science supports the nutritional equivalence of plant-based alternatives.

“Dairy foods have been well-studied over decades, and the evidence for the benefits of the dairy food matrix, including nutrient bioavailability and impacts on health outcomes, is well-established,” the comments state. “We are aware of few if any studies that have similarly tracked and identified health outcomes for highly-processed plant-based dairy alternatives. These products vary tremendously in their nutrient content, and in contrast to dairy foods, FDA has not established Standards of Identity for any of the alternatives, so there is no requirement that they meet any particular nutrient content.”

NMPF also encourages the DGAC to review the growing body of science that shows dairy foods have beneficial or neutral effects on chronic disease risk at all fat levels.  “The scientific evidence supports removing low-fat and fat-free limitations on dairy recommendations, although consumers should certainly be able to choose these varieties if they enjoy them or they need to limit caloric intake,” NMPF said.

The Dietary Guidelines for Americans has significant impacts on nutrition in the United States because it forms the basis of federal nutrition policy and programs; it also helps guide health promotion and disease prevention initiatives at the federal, state and local levels. The Dietary Guidelines Advisory Committee is expected to release its scientific report with recommendations to USDA and HHS for updating the DGA in the fall.

NMPF Submits Comments on Dietary Guidelines Protocols

NMPF submitted comments on Nov. 17 on recently released Dietary Guidelines for Americans (DGA) protocols that emphasize the need to include the newer science on dairy fats in their review and to shorten the duration of time required for randomized controlled trial studies.

NMPF comments focused on protocols for two scientific questions: What is the relationship between food sources of saturated fat consumed and risk of cardiovascular disease, and what is the relationship between dietary patterns consumed and risk of cardiovascular disease?

On the first question, NMPF pointed to the complexity of dairy fat and the growing body of evidence that supports dairy consumption, regardless of fat content, does not increase cardiovascular disease. On the latter question, NMPF pushed for a shorter duration to be used for randomized controlled trials. Changes in blood lipid levels in randomized controlled trials can be seen in 3 weeks which is much shorter than the 12 proposed by the committee in this protocol.

These protocols will, when final, inform the conduct of systematic reviews and food pattern modeling that will form the science base of the 2025 Dietary Guidelines for Americans. The committee has released the protocols in waves as they are developed. The full comments can be found here.

Regulatory Affairs: Helping Good Ideas Advance While Fighting the Bad Ones

Highlights

  • Developed strategies to maximize benefits of sustainability provisions included in the Inflation Reduction Act, a key accelerator towards meeting the dairy industry’s 2050 sustainability goals
  • Helped shape the upcoming FDA antibiotic residue sampling assignment to ensure farmer and cooperative needs are being met
  • Advanced development of the FARM Biosecurity module, bringing in on-farm elements from the Secure Milk Supply Plan for continuity of business as herd-threatening diseases make headlines around the world
  • Seized a once-in-a-generation opportunity, collaborating with USDEC and Dairy Management Inc., to host the International Dairy Federation World Dairy Summit in 2023
  • Prepared NMPF’s response to an expected FDA guidance on the use of dairy terms in plant-based beverages while arguing the need for labeling integrity before the agency.

Regulatory work often focused on building upon past successes and slowly erasing regulatory mistakes. NMPF regulatory staff’s wide breadth of issues in 2022 including monitoring the development of the new WOTUS rule and the evolving PFAS regulations to expanding NMPF’s nutrition presence through the Dietary Guidelines for Americans and Women, Infant and Children supplemental nutrition program.

Critical support to the organization ran across the full scope of regulatory efforts. The Inflation Reduction Act passed in August includes numerous provisions that may benefit dairy farmers, but only if their revenue and carbon-reduction possibilities are maximized. NMPF regulatory staff are working with dairy farmers and stakeholders across the industry to enhance opportunities.

NMPF collaborated with FDA, state officials and industry to develop a new antibiotic residue sampling program being administered by FDA. NMPF sits on the NCIMS Appendix N committee to ensure dairy farmer needs are being met during the development of such programs.

Herd-threatening diseases continue to pop up around the world from high pathogenic avian influenza in the United States to foot and mouth disease threatening to enter Australia. NMPF through the National Dairy FARM Program is continuing to expand the suite of biosecurity resources available for dairy farmers to work to protect their herd and employees from a potential outbreak.

The United States is set to host the 2023 International Dairy Federation World Summit in Chicago, Illinois. NMPF, working with USDEC and DMI, is a key player in developing the agenda for the conference which is set to highlight the United States dairy industry.

In light of the draft guidance “Labeling of Plant-based Milk Alternatives and Voluntary Nutrient Statements; Draft Guidance for Industry “being sent to the Office of Management and March for review before its potential release, NMPF continues to argue the need for labeling enforcement and transparency  by FDA. While what the guidance outlines is unknown, NMPF continues to emphasize to FDA that any guidance which does not align with the standards of identity regulations is in violation of the Administrative Procedures Act.

Government Relations: NMPF Advances Nutrition and Ag Labor Reform Priorities

Highlights

  • Maintained protection of 1% flavored milk in school meal programs
  • Led eleven national agricultural, anti-hunger, nutrition, and medical groups in a virtual listening session urging the White House to prioritize access to affordable, diverse and nutritious foods
  • Helped organize a message from 446 agricultural stakeholders calling on the Senate to pass ag labor reform this year
  • Urged President Biden to grant dairy access to the H-2A agricultural guestworker visa program

NMPF has made significant progress in advancing policy on behalf of its members in 2022, despite the slowing pace of legislation typical to an election year.

NMPF’s work on federal nutrition programs made significant inroads. Ensuring students access to healthy milk has long been a dairy priority, with NMPF leading efforts to safeguard schools’ ability to choose the milk varieties they serve. USDA in February issued a final rule protecting the allowance of 1% flavored milk in school meal programs through the 2023-24 school year, and the House Committee on Education and Labor in July approved a child nutrition reauthorization bill which bars USDA from preventing schools from offering milk varieties that are consistent with the Dietary Guidelines for Americans (DGA). The House bill, if enacted, would protect 1% flavored milk and all varieties consistent with the DGA as options for schools. Equally important, it signals to USDA and other policy makers that protecting milk varieties consistent with the DGA is a House priority.

NMPF is also advocating for increased access to affordable, diverse, and nutritious food in all federal nutrition programs. This summer’s focus has been on the White House as it crafts its nutrition strategy to be released at its Conference on Hunger, Nutrition, and Health later this month. In June, NMPF led 11 national agricultural, anti-hunger, nutrition, and medical groups in a virtual listening session urging the White House to prioritize increased access to food and providing in federal programs food options that allow for cultural influences, nutritional needs, and taste preferences.

NMPF also has led focused efforts on agricultural labor reform. Senators Mike Crapo, R-ID, and Michael Bennet, D-CO, continued their negotiations on an ag labor reform measure in 2022, working on improvements to the bipartisan House-passed Farm Workforce Modernization Act that will provide the changes vital for agricultural producers and maintain protections for farm workers. NMPF has been assisting this delicate process, informing Senate offices of dairy’s specific workforce needs and building broader support for passing ag labor reform. In addition to meeting with key Senate offices, NMPF helped organize a message to all senators and leadership in August from 446 agricultural stakeholders calling on the Senate to pass agricultural workforce reform this Congress, citing rising food costs and the current labor market crisis as adding to the dire need for reform.

Outside Congress, NMPF continues to explore more immediate relief for dairy farmers, urging the Biden Administration to allow dairy access to the H-2A agricultural guestworker visa program. NMPF president and CEO Jim Mulhern wrote President Biden in May, imploring him to issue an executive order to exempt dairy worker positions from H-2A’s seasonality requirement. This would allow dairy farmers access to the guestworker program. Given dairy’s worsening workforce situation, the nation’s inflation challenges, and the administration’s interest in immigration reform, this has been the right time for NMPF to renew its relevant and increasingly urgent request.

2025-2030 Dietary Guidelines Kick Offs, NMPF Submits Comments

NMPF submitted comments on the proposed scientific questions for the 2025-2030 Dietary Guidelines for Americans (DGAs) May 16, emphasizing NMPF’s shared priority with USDA and HHS of ensuring all Americans have access to nutrient-dense, healthy foods. NMPF also requested the opportunity for stakeholders to comment on the inclusion and exclusion criteria that will apply to the systematic review as this has led to some dairy-focused studies not making the cut in the past. The full, detailed comments can be found here.

The Dietary Guidelines are important as they form the basis of federal nutrition policy and programs including the National School Breakfast and Lunch programs. The development of the new version can be lengthy, with the next steps including selection of the Scientific Advisory committee and their review of the evidence.

The 2020-2025 guidelines retained dairy as a separate group and continued to recommend 3 servings of low-fat and non-fat dairy products in the Healthy U.S.-Style Dietary Pattern. NMPF will continue to monitor and advocate for dairy in the DGAs throughout the entire process.

NMPF Submits Joint Comments to USDA School Lunch and Breakfast Program

NMPF submitted joint comments March 24 with the International Dairy Foods Association to the USDA Food and Nutrition Service urging the agency to improve nutrition security by updating school meal nutrition standards to encourage increased consumption of dairy. Doing so would be in keeping with recommendations made in the 2020-2025 Dietary Guidelines for Americans (DGA) report and by leading health organizations.

USDA announced transitional school meal nutrition standards for the next two school years that will allow schools to continue to serve low-fat flavored milk consistent with DGA recommendations while pausing overly stringent sodium reduction targets that threaten the ability of school meals professionals to serve nutrient-rich cheeses. USDA intends to craft more permanent standards for school year 2024/2025 to pave the way for healthy and nutritious school meals.

Highlighted in the comments are the nutritional benefits that the low-fat flavored milk provides students- the same 13 essential nutrients which unflavored offers. NMPF and IDFA also point out that the Dietary Guidelines for Americans say modest amounts added sugars can be added to nutrient-dense foods – including low-fat or fat-free milk – to help meet food group recommendations.

The comments also emphasize the need to work with industry before implementing further sodium reduction targets, the importance of lactose-free and reduced-lactose options for schools and dairy products at a variety of fat levels.