Can personal trainers and nutrition coaches offer nutrition counseling?

Offering nutrition coaching is a great way to support your clients to reach their health and fitness goals, and also to add an additional revenue stream to your business. 

In this article, we’ll do a deep dive into who is allowed to offer nutrition coaching (hint: almost anyone, with a few caveats), and we’ll explore the scope of practice for Nutrition Coaches vs. Registered Dietitians (RDs), as well as provide some guidance around the legality of offering different types of nutrition advice, such as habits-based behavior change nutrition coaching vs. prescribing meal plans, macros, supplements, and other targeted approaches.

We’ll also explore the question of who is legally responsible if harm occurs to the client – is it the original source of the information or meal plan (i.e. an RD, a website), or the person sharing that information with the nutrition client (i.e. the health coach)?

Let’s start off with a quick overview of the RD title.

RD stands for Registered Dietitian (or Registered Dietician), and is a legal healthcare designation that allows them to talk to people about nutrition, healthy living, supplementation, medical conditions, and the interconnection between those factors. 

As a minimum, they’ve completed: 

• a four-year university degree specializing in Human Nutrition (although many have gone on to also complete a Masters degree)
• have logged usually more than 1000 hours in a rigorous dietetic internship, getting hands-on training in a variety of healthcare settings, working with specialized populations (e.g. pediatric, cardiovascular, diabetes management, community health, etc.) under the supervision and guidance of many different RD mentors who evaluate their performance and skill development
• have written and passed a certifying board exam to obtain their RD licence post-internship
• must renew their RD licence with a governing body specific to their geographical location (i.e. within their local province or state)
• must have liability insurance in place to practice as an RD
• generally keep up with continuing education and professional development to stay current with the changing science of human nutrition and behavior change

That’s a lot of hard work, studying, and money to obtain the RD credential, but once licensed as a Registered Dietitian, it allows them full-access to work with the general public and specialized populations that have medical conditions, in order to coach people to eat better, manage various diseases, write meal plans, prescribe macros, recommend supplements, and anything else where nutrition can play a positive role in someone’s overall health.

But are Registered Dietitians the only professionals who are allowed to talk to clients about healthy eating habits? What about personal trainers, or health coaches, or nutritionists, or people with an undergrad, Masters or even PhD degree in nutrition? 

What if you fall into one of these categories – are you allowed to coach people to eat better, or is that out of your scope of practice?

In this article, we’re going to clarify some of the confusion around nutrition coaching, and what you can and can’t do, if you don’t hold the “RD” title.

Let’s start off with an obvious truth. 

If you’re in the fitness industry, people are going to ask you questions about healthy eating, or losing weight, building muscle, or about something they’ve read on the internet, or the latest documentary floating around on Netflix that they just watched.

Are you really expected to just shake your head and answer, “I’m not an RD and that’s not within my scope of practice to talk about that with you.”

Coming from an RD writing this article, I hope not, because we need as many allies as we can get to help us fight the battle against chronic disease, help people improve their relationship with food, and live a healthier lifestyle overall. And the more teammates we have on the nutrition frontlines helping to educate others about healthy eating, the better our overall chances of really making a BIG impact on the health of our family members, our friends, and in our communities. WE NEED MORE HELP, and that’s where you can really come in and shine!

I’m working from the assumption that you got into fitness and health promotion because you care about people, because you care about fitness, and because you care about helping others live their best lives. And if you truly are a great coach, you most likely coach the whole person, where you not only care about what they’re doing while they’re with you in the gym, but you also help them problem-solve through many common obstacles to wellness: stressful jobs, low energy levels, lack of sleep, hectic schedules, busy family life, varying levels of motivation, and competing priorities.

Stating a less obvious truth – the general public often doesn’t even know the difference between a Registered Dietitian, Nutritionist, or nutrition coach, and often expect that nutrition advice is part of the package when working with a personal trainer. They’re paying you to get results, and nutrition and training need to work together if the client is going to see any progress long-term.

Still, it’s easy for even the most knowledgeable fitness professional to feel a little uncertain about what they can say (and not say) about food. You might have even heard that you’re not qualified to talk about food with your clients, and that you’re treading on dangerous territory because it might be illegal if you don’t have the RD title.

Here’s the truth – personal trainers, nutritionists, and health coaches can in fact talk to their clients about what they eat, but there are a few limits in place to protect YOU and to protect YOUR CLIENTS if you aren’t a Registered Dietitian.

Let’s start with what you CAN DO, working with otherwise healthy clients that aren’t coming to you for the medical management of a specific disease.

The Green Zone (Generally Speaking)

• You’re allowed to make general suggestions about specific foods and patterns of healthy eating that support your clients’ goals
• Educating your clients to eat better following principles of good nutrition fundamentals is also ok. Examples include helping your clients:
  • Eat more vegetables
  • Include sources of lean protein with their meals and snacks, and giving them food examples (or recipes) to help guide their choices
  • Learn about different types of healthy fats, and options they can pick from
  • Drink more water
  • Increase their intake of dietary fiber
  • Find healthier alternatives for mid-day snacking
  • Brainstorm better breakfast ideas
  • Plan ahead to make healthy eating easier, such as batch cooking, packing a healthy lunch, chopping up vegetables, keep healthy snacks on hand, etc.
• Sharing healthy recipes and meal/snack ideas is totally fine
• Connecting them with resources produced by recognized, credible, nutrition organizations
• Making nutrition and healthy eating easy-to-understand, actionable, and broken down into behavior-change steps for your clients
• Generally, lifestyle and habits-based behavior change coaching almost always falls into the “green light” category for a non-RD nutrition coach to talk about with their clients

From the list shared above, you can see that it’s all about helping your nutrition clients eat better for the long-run, coming at things from a behavior-change coaching perspective. In this “green light’ category of nutrition coaching, you’re not prescribing any specific meal plans, calculating calories or macros, diagnosing or treating health problems, or giving clients specific nutrition interventions to manage or treat a specific health condition.

The Grey Zone

Next, we’ll move into the “grey zone”. Depending on where in the world you live and work, you may or may not be permitted to do the following as a non-RD nutrition coach. We call this the “grey zone”, and you’ll need to know your local regulations really well if you offer these types of services to your nutrition clients.

• Writing up meal plans for individual clients
• Calculating specific numbers for your clients, such as calories, macro splits, or micronutrient requirements

Who is Legally Responsible: the RD Who Wrote the Plan, or the Nutrition Coach Giving the Advice?
One important caveat to note about the grey zone – the person giving the advice (i.e. the nutrition/health coach) is the one who is personally and legally liable if the nutrition advice they offer does any long-term damage or causes harm to the client. It doesn’t matter if the advice, or meal plan, or macro split being shared originally comes from a Registered Dietitian or a credible nutrition organization; the responsibility ultimately falls on the shoulders of the person prescribing the nutrition plan to the client. 

It becomes an even darker shade of grey, and in some locations, “red zone”, for non-RD nutrition coaches to make individual adjustments to calorie- and macro- plans (even if those plans originated from a credible source like an RD), so again, we advise sticking to habit-based behavior change coaching, similar to what’s offered in the Precision Nutrition Level 1 Certification, and also in our Two-Brain Coaching Nutrition Coaching Course. 

Think of it this way. Just because a Nurse Practitioner can prescribe medications to a patient, doesn’t mean they can just lend out their healthcare designation so anyone can prescribe drugs on their behalf, and they take on all of the legal liability. Or to put it another way, if another personal trainer took your programming and gave it to one of their clients, it’s that personal trainer who is on the hook if anything happened to their client, not you, just because you happen to also be a personal trainer who wrote out some programming. Your training, certifications, and liability insurance cover YOU to work with YOUR OWN clients, and the other personal trainer’s background training, certifications, and liability insurance cover them to work with THEIR OWN clients.

It’s also really important that you take the time to know the rules and regulations of where you live. Admittedly, these state and provincial rules around “individualized nutrition therapy” are often poorly enforced unless a complaint or lawsuit comes forward, but we want to encourage you to always be on the right side of the line.

If you’re going to offer nutrition counseling at your facility, it really is worth taking the time to educate yourself on what’s permitted based on where you work with clients, because there’s no one-size-fits-all approach and the rules really do change from place-to-place. Things can also change over the years based on where you live, so it’s also important to stay current with what you can talk about, what you can’t do, and to seek legal counsel when appropriate to help you decipher the laws in your local area.

As a starting point, this map helps to generalize complex state laws in the United States when it comes to nutrition counseling.

For follow-up reading, there’s a great article put out by Precision Nutrition called: Can personal trainers and health coaches give nutrition advice?

The Red Zone

Lastly, we want to give some basic advice about what you CAN’T DO if you don’t hold the designation of Registered Dietitian, or another healthcare professional title that’s qualified to give personalized nutrition advice, especially when it comes to the nutritional management of a medical disease, called Medical Nutrition Therapy (MNT).

• You CANNOT prescribe specific diets or supplements to treat medical and clinical conditions
• You CANNOT prescribe specific diets to treat symptoms of medical and clinical conditions
• You CANNOT diagnose medical conditions

For example, all of these would be considered off-limits with the language and approach taken:

• Prescribing a calorie-specific meal plan to treat someone who has metabolic syndrome (a person who presents with obesity, high blood pressure, insulin resistance, etc.)
• Diagnosing someone with Type 2 Diabetes, and putting them on a very low carbohydrate diet to mange their high blood sugars
• Recommending a specific amount of omega-3 supplementation to a client after they have had a heart attack
• Treating someone for the recovery of a serious eating disorder

Unless you are licensed, like a Registered Dietitian (RD) or Medical Doctor (MD), or otherwise certified to do so, you CANNOT offer dietary advice in the form of medical nutrition therapy (MNT), such as prescribing nutrition to manage health conditions like the following:

• Post-surgery recovery
• Diabetes
• Cancer
• Cardiovascular disease
• Hormone imbalances
• Liver disease
• Kidney disease or kidney stones
• Clinical eating disorders (anorexia, bulimia, binge eating disorder)
• Digestive disorders (Crohn’s, colitis, celiac)

Check out: Nutrition Coaching “Red Zones”.

In the Two-Brain Coaching Nutrition Coaching Course, Module 3 covers Scope of Practice for non-RD nutrition coaches in great detail, including what you CAN DO to always stay in the green zone:

• You can actively listen, and empathize with the client’s health struggles
• You can provide accountability and support, and help them implement the nutrition care plan provided by their medical team
• You can help them advocate for themselves with their medical team, to bring up questions and concerns about their nutrition plan
• You can share reputable and helpful resources for them to discuss with their medical team
• You can usually provide behavior-based coaching to help develop fundamental nutrition, movement, and lifestyle skills and practices that don’t contradict their medical advice
• You can link them up with a Registered Dietitian in your circle of care, to help them get additional nutrition support if the management of their health condition is truly out of your scope of practice

So, hopefully you can see that there is so much that you CAN DO to be allies and teammates when it comes to offering nutrition coaching to your clients and helping to coach positive behavior change. And hopefully you can also see why Two-Brain Coaching, similar to the Precision Nutrition Level 1 certification, takes a habits-based and motivational interviewing approach in our Nutrition Coaching Course. Not only is it more favorable from a client-centered approach to help your clients get better results than logging their calories in an online app or following a macros-based meal plan, but it also helps non-RD nutrition coaches and gym owners stay in the green zone when it comes to the liability side of nutrition coaching. 

Because ultimately, we want to help build more world-class nutrition coaches where you feel confident, capable, highly knowledgeable, and supported by our team of RD-lead Nutrition Coaching Mentors to help you lead your own nutrition clients to better health and overall wellness.

Interested in becoming a world-class nutrition coach? Learn more here: