Manifestation of Nupens/USP on the Technical Note 42/2020 of the Ministry of Agriculture with unreasonable attacks on the Food Guide for the Brazilian Population
This past Wednesday, September 16th 2020, the Center for Epidemiological Research in Health and Nutrition at the University of São Paulo (Nupens/USP) learned of an official document sent by the Minister of Agriculture, Livestock and Supply (MAPA), Tereza Cristina Corrêa da Costa Dias, to the Minister of Health, Eduardo Pazuello, requesting an urgent review of the Brazilian Dietary Guidelines, an official Ministry of Health publication from November 5th, 2014.
As noted in the preamble to the publication by the General Coordination of Food and Nutrition of the Ministry of Health (CGAN), “…the Brazilian Dietary Guidelines is an instrument to support and encourage healthy eating practices for individuals and the population, and also support policies, programs, and actions whose purpose is to encourage, protect and promote the good health and food and nutrition security of the Brazilian population.”
A Technical Note (nº 42/2020) to justify the need to review the publication accompanies MAPA’s official document.
The justifications included in the Technical Note focus on criticisms regarding the classification of foods used by the Dietary Guidelines and on the recommendation to avoid the consumption of ultra-processed foods; however, such criticism boils down to statements that are not supported by any scientific evidence.
For example, regarding the NOVA classification, the official MAPA Technical Note states that:
“The NOVA classification is confusing, incoherent, and hinders the implementation of guidelines that promote adequate and healthy eating for the Brazilian population. The NOVA classification considers the degree of processing of food and food products, which does not contribute to a food-based dietary guide representing the position of the Federal Government. The NOVA classification is arbitrary and confuses the level of processing with the quantity and types of ingredients used in the formulation of industrialized foods (REGO, 2014)1.’’ Surprisingly, the reference offered to support this statement at no time refers to the NOVA classification.
To counteract the Dietary Guidelines recommendation to avoid the consumption of ultra-processed foods, the Technical Note states that “(…) there are processed foods that provide a wide variety of nutrients at all levels of processing (EICHER-MILLER et al., 2012. p. 49-79).”2 However, in addition to ignoring that the Dietary Guidelines highlights the various benefits of food processing – as extending its shelf life and contributing to a diverse diet – and the fact that it recommends that only ultra-processed foods should be avoided, the study by EICHER-MILLER et al., 2012 does not consider a category of ultra-processed foods in their assessment.
Besides supporting all their statements about the alleged inconsistency of the NOVA classification and the alleged harmlessness of ultra-processed foods using two references that do not refer to the NOVA classification or evaluate ultra-processed foods, the Technical Note omits a vast national and international scientific research published since 2009 when the classification and concept of ultra-processed foods were first proposed by Nupens/USP.
The Technical Note omits more than 400 scientific studies indexed in the PubMed database that used the NOVA classification or the concept of ultra-processed foods.
It omits the five systematic reviews, in addition to a narrative review, which demonstrated the unequivocal association of the consumption of these foods with the risk of chronic diseases of great epidemiological importance in Brazil and in most countries, such as obesity, diabetes, cardiovascular diseases, and strokes, including the most recent one published by Pagliai et al3 in the British Journal of Nutrition.
It also omits the first randomized controlled clinical trial on ultra-processed diets, carried out by Hall et al4 at the largest health research center in the world (National Institute of Health) and published in Cell Metabolism. This trial has confirmed the causal relationship between consumption of ultra-processed diets and marked increase in calorie intake and body fat gain.
Again, without evidence MAPA’s Technical Note goes so far as to state: “…currently the Brazilian Guidelines are considered one of the worst ones [on the planet]”.
This is not what the United Nations organisms such as FAO, WHO and UNICEF believe though. They consider the Brazilian Dietary Guidelines as an example to be followed. This is not what the Ministries of Health of Canada, France, Uruguay, Peru, and Ecuador believe either, which have based their food-based guidelines guides and their food and nutrition policies on the Brazilian model. Finally, it is not what the authors of a rigorous study published in 2019 by the journal Frontiers in Sustainable Food Systems think. They considered the Brazilian Dietary Guidelines to be the best food-based guidelines because it met the criteria of the promotion of human health, environment, economy, and political and socio-cultural life (Ahmed et al., 2019)5.
In view of the groundless and inconsistent arguments presented in MAPA’s Technical Note and the absurd and disrespectful evaluation of the Brazilian Dietary Guidelines, we trust that the Ministry of Health and the Brazilian society shall know how to respond to what is configured as an unreasonable attack on health and food and nutritional security of our people.