Re: Guideline 1 “Eat a wide variety of nutritious foods from these five groups every day: …milk, yoghurt, cheese and/or their alternatives, mostly reduced fat (reduced fat milks are not suitable for children under the age of 2 years)” The recommendation that reduced fat milk products should be chosen on most occasions is inconsistent with Evidence Statements, and is based on modelling that was inappropriate for informing this recommendation. The Evidence Report addresses 16 questions regarding the relationship between diary and health, and “unless otherwise specified, dairy consumption is defined as the total consumption of cheese, milk, and yoghurt”. Positive associations were found between dairy and 8 beneficial health outcomes (5.1 improved bone mineral density, 5.3 reduced risk of heart disease, 5.4 reduced risk of stroke, 5.5 reduced risk of hypertension, 5.6 reduced risk of type 2 diabetes, 5.7 reduced risk of metabolic syndrome, 5.11, reduced risk of colorectal cancer, 5.12 reduced risk of rectal cancer). Only one positive association was observed for low fat dairy (5.5 reduced risk of hypertension). This evidence does not support the preferential selection of reduced fat dairy foods. Section 2.5.1 of the draft guidelines cites: “The proportion of total fat and saturated fat content in some milk, cheese and yoghurts has led to the recommendation that reduced fat varieties should be chosen on most occasions [10].” This recommendation arises from the model developed for the Review by Byron et al. However, this model was designed to generate whole diet food consumption patterns that are consistent with nutrient reference values; it was not designed to nor able to compare the relative health benefits of wholeversus reduced-fat dairy foods. The authors incorporated an unspecified limit for saturated fat content, which does not account for either the complexity of dairy fats (milk fats are the most complex naturally occurring fats known to science (1)), or the actions of other components of dairy upon digestion or metabolism of fats (e.g. the effects of calcium fat excretion and blood lipid profile (2)). The model does not take into account evidence that is beginning to emerge about the potential role of dairy fats in promoting health; such as provided by a recent Australian study which reports considerably lower risk of cardiovascular death in participants who consumed more full-fat dairy, but no association between risk and low-fat dairy consumption (3). Not all saturated fats are the same. Simple models based solely on saturated fat intake will always predict worse outcomes with higher levels of dairy fat, but the evidence consistently refutes this hypothesis. The recommendation to mostly consume dairy that has had one of its principal nutritional components removed, risks reducing the expected health benefits for Australians. 1. Månsson HL. Fatty acids in bovine milk fat. Food Nutr Res. 2008;52. 2. Lorenzen JK, Astrup A. Dairy calcium intake modifies responsiveness of fat metabolism and blood lipids to a high-fat diet. British Journal of Nutrition. 2011;105(12):1823-31. 3. Bonthuis M, Hughes MCB, Ibiebele TI, Green AC, van der Pols JC. Dairy consumption and patterns of mortality of Australian adults. Eur J Clin Nutr. 2010;64(6):569-77. Acknowledgements: This submission was drafted in collaboration with Mr James Doidge, Research Associate, Health Economics and Social Policy Group, University of South Australia.