When Project 2025 began making headlines this summer, it was largely because of the ways in which 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, written by the Heritage Foundation, a conservative think tank - also outlines steps that would radically transform the food and agriculture sectors, extending recent progress in tackling the glut of ultra-processed food in the United States would be curtailed. These include weakening the Supplemental Nutrition Assistance Program (Snap), ending policies that take into account the impacts of climate change - and abolishing 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 about deregulation is that it's very bad for consumers, it's bad for workers and it's bad for the environment."
Project 2025 proposes changes to the country's food assistance programs, such as Snap and the Supplemental Nutrition Program for Women, Infants and Children (Wic), which Nestle believes are intended to dismantle such programs. There are also calls for an end to support for school meals.
But one of the most notable proposals is the call for the next Republican president to abolish or reform the dietary guidelines. These guidelines form the basis for all federal food policies, from school meals to Snap, Wic and other programs.
A worker arranges chips at an Albertsons Safeway supermarket in Scottsdale, Arizona, US, on January 3, 2024. Photo: Ash Ponders/Bloomberg via Getty Images
"There is no shortage of private sector nutrition advice for the public, and diet and food choices are best left to individuals to meet their personal needs," the document said.
The food industry has long promoted the idea that chronic, diet-related health problems, such as diabetes and obesity, are the result of individual choices - such as not getting enough exercise. Today, nearly 42% of adults in the US are obese and about 12% have diabetes. But nutritionists insist that these conditions are not the result of a moral failure, but rather conditions caused by the ingredients and policies (such as aggressive advertising to children) pushed by food companies.
Nestlé sees this as one of many policies that benefit business, as outlined in the Project 2025 agricultural provisions, where companies are trusted to prioritize public health over profit.
"There are twice as many calories available in the food supply as the country needs on average. So the food industry is extremely competitive in selling calories," she said. "Republicans want to deregulate and give those food companies every opportunity to make as much money as possible, regardless of the health and environmental impact."
Experts also fear how Project 2025 could undermine the work of the Food and Drug Administration and the Department of Agriculture to limit the flow of ultra-processed foods into the U.S. food supply.
According to Northeastern University, ultra-processed foods today comprise 73% of the U.S. food supply and provide the average American adult with more than 60% of their daily calories. Although the science is still emerging, researchers are increasingly linking UPFs to a range of health problems, including diabetes, obesity, depression and certain cancers.
The FDA is currently developing a front-of-pack label that companies would have to print on the front of products to indicate when an item is high in sugar, fat, sodium, or calories (the exact label has not been specified ). not yet made public). Although the label does not specifically indicate when a food is ultra-processed, it would likely apply to a high percentage of UPFs in the food system, as many contain high amounts of those nutrients.
Bags of chips, with warnings about calories and sodium content, at a street stall in Santiago de Chile, Chile, on October 16, 2019. Photo: Alberto Valdés/EPA
And at the USDA, members of the U.S. Dietary Guidelines Advisory Committee are currently meeting. They will make their recommendations for the dietary guidelines for 2025-2030 later this year. In considering the advice it will provide to the USDA and the Department of Health and Human Services, the committee has been charged with also reviewing research related to UPFs. It's unclear what they will recommend - and whether that advice will be included in the 2025 dietary guidelines - but it is an important development for the committee to even consider ultra-processing.
But while Project 2025 doesn't make specific references to front-of-pack nutrition labels like those currently being considered by the FDA, said Lindsey Smith Taillie, professor of nutrition and co-director of the Global Food Research Program at the University of North Carolina, Chapel Hill says eliminating the dietary guidelines will inevitably impact that.
"It's almost like they're removing scientific evidence from federal food policy," she said.
Even if Trump is not elected next month, Philip Kahn-Pauli, director of legislative affairs at the Center for Science in the Public Interest, said he "sees the impact of the policy proposals in Project 2025 in Congress today."
As the Republican-controlled House approved funding for government agencies in 2025, it was considering a bill that would "fundamentally change" the dietary guidelines process, he said in an emailed statement. The budget bill would, among other things, have nullified the 2025 dietary guidelines currently under consideration. 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 undermining evidence-based policy" . He expects more attacks on the guidelines in the new year.
Nestle says Project 2025 would promote industry across the food system over climate, public health or welfare concerns: "The basic principle here is: don't do anything that will reduce industry profits."