MAHA Commission Releases Make Our Children Healthy Again Assessment

After first importantly acknowledging that there “is no single, universally accepted definition of [ultra-processed foods],” the Assessment identifies “poor diet” marked by high consumption of so-called ultra-processed foods² (“UPFs”) as one of the “potential drivers” of the rise in childhood chronic disease. Although the Assessment identifies “UPFs” as “detrimental” to children’s health, in part due to the inclusion of food additives, it also notes that there is a “critical need” for more “extensive research” into “UPFs” to examine the health impacts of reduced-“UPF” diets.

In addition to poor diet, the Assessment identifies “the aggregation of environmental chemicals,” “lack of physical activity and chronic stress,” and “overmedicalization” as the other potential drivers of chronic childhood disease. As explained in more detail below, the Assessment concludes with a list of next steps that primarily focus on conducting more research ahead of developing a “comprehensive strategy.” 

As brief background, Executive Order (“EO”) 14212,³ which established the MAHA Commission, requires the Commission to submit this Assessment to the President by May 24, 2025. The MAHA Commission is chaired by Department of Human and Health Services (“HHS”) Secretary Robert F. Kennedy, Jr. Its members include U.S. Food and Drug Administration (“FDA”) Commissioner Dr. Martin Makary, U.S. Department of Agriculture Secretary Brooke Rollins, and other senior executive officials, as well as “other members of the Trump Administration invited to participate, at the discretion of the HHS Secretary and the [MAHA Commission’s] Executive Director.” The EO also requires the Commission to submit to the President by August 12, 2025, a “Make Our Children Healthy Again Strategy” to address “appropriately restructuring the Federal Government’s response to the childhood chronic disease crisis.” This Assessment is intended to inform the Strategy. 

More details regarding the Assessment’s discussion of food follow.

The Assessment’s Findings on “UPFs”

After recognizing the definitions of “UPFs” vary, the Assessment explains that for purposes of the Assessment, “UPFs” “refer broadly to packaged and ready-to-consume products that are formulated for shelf life and/or palatability but are typically high in added sugars, refined grains, unhealthy fats, and sodium and low in fiber and essential nutrients.” Although the Assessment acknowledges that “UPFs” are “built into the fabric of the post-World War II American society and economy” and use “shelf-stable processing techniques” developed by the U.S. to “feed the world,” it claims that “today’s over-reliance on UPFs is damaging the health of American children.” The Assessment identifies three key reasons why so-called “UPFs” are “detrimental” to children’s health:

• Nutrient Depletion:The Assessment claims that ultra-processing of grains, sugars, and fats “displaces nutrient-dense whole foods, resulting in a reduction of essential vitamins, minerals, fiber, and phytonutrients needed for optimal biological function.” Specifically, the Assessment discusses health risks that may be associated with:
  • “grains processed by removing the bran and germ;” 
  • “high fructose corn syrup and other added sugars;” and
  • the shift from “minimally processed animal-based sources of fat such as butter and lard—rich in fat soluble vitamins A, D, and E, supporting brain and immune health” to refined seed oils such as “soybean, corn, safflower, sunflower, cottonseed, and canola,” alleging that industrial refining reduces micronutrients and contributes to an imbalanced omega 3/omega 6 ratio, which is “a topic of ongoing research for its potential role in inflammation.” 
• Increased Caloric Intake: The Assessment asserts that “processing inherent in UPF production” could “interfere with brain reward pathways and satiety hormones, promote faster eating, and compromise gut fullness signals,” leading to weight gain.
• Inclusion of Food Additives: The Assessment asserts that “certain food additives” are “linked” “to increased risks of mental disorders, attention deficit hyperactivity disorder (ADHD), cardiovascular disease, metabolic syndromes and even carcinogenic effects.” The Assessment highlights varying purported health risks with the following ingredients commonly added to food:
  • Certain food colorings such as red 40;
  • Titanium dioxide;
  • Propylparaben;
  • Butylated hydroxytoluene (BHT); and
  • Artificial sweeteners like aspartame, sucralose, and saccharin. 

The Assessment identifies purported links to these food ingredients and adverse health outcomes, provides citations to studies, and in many instances fails to capture the qualifications in the underlying cited study or the preponderance of evidence on a particular topic. The Assessment touts the benefits of diets centered on whole foods and asserts such diets are consistently linked to “lower rates of obesity, type 2 diabetes, heart disease, certain cancers, and mental illness.” The Assessment identifies examples of the type of whole foods that are linked to these benefits as:

• Leafy greens;
• Salmon;
• Legumes;
• Nuts;
• Beef; and
• Whole milk and other dairy products.

The Assessment does not adopt provisions that have been in the Dietary Guidelines for Americans (“DGA”) for years that express concerns about the link between excessive saturated fat intake and increased risk of heart disease and that recommend lower fat dairy and lean meats. The identification of the health benefits of butter and lard suggests MAHA is less concerned about the levels of saturated fat when they are sourced from minimally processed or “whole foods.”

The Assessment identifies a need for more “extensive research” into reduced-“UPF” diets, noting that current randomized control trials on “UPFs” have “typically lasted only two weeks,” whereas “reduced-carbohydrate diets have been studied in several two-year trials.”

The Assessment criticizes the DGA for not explicitly addressing “UPFs,” noting the 2025 Dietary Guidelines Advisory Committee’s finding of only “limited evidence” of an association between “UPFs” and greater risk of obesity and/or being overweight. Additionally, the Assessment takes issue with the DGA for “maintaining problematic reductionists recommendations” such as advising people to reduce saturated fat or limit sodium or treating all calories similarly rather than focusing on minimizing the consumption of “UPFs.” The Assessment further critiques the DGA for making “little distinction between industrially processed foods and home-cooked or whole foods if their nutrient profiles look similar.” The Assessment also makes the unsubstantiated claim that the DGA have a history of being “unduly influenced by corporate interests.” 

Finally, the Assessment criticizes the National School Lunch Program for not excluding “UPFs” and suggests that other countries use more local foods in their school meals programs. 

Additional Notable Findings

Below we summarize additional findings from the Assessment that are relevant to the food industry:

Environmental Chemicals

The Assessment finds that children are exposed to “numerous chemicals,” including heavy metals, PFAS, microplastics, fluoride, phthalates, bisphenols, and crop protection chemicals such as glyphosate, and asserts children may be “particularly vulnerable to potential adverse health effects from these cumulative exposures.” For example, the Assessment claims that exposure to PFAS chemicals may be associated with health risks, “including immune suppression and changes in cholesterol in children,” and that microplastics “often carry endocrine-disrupting chemicals” that can “potentially trigger early puberty” and "heighten the risks of obesity, infertility, and hormone-related cancers.” However, the Assessment also notes that “[t]he cumulative effect of multiple chemical exposures and impact on children over time is not fully understood.” Additionally, the Assessment finds that there is not enough human research on health outcomes linked to crop protection tools but also recognizes that American farmers rely on crop protection tools, that they are “critical partners in the success of the [MAHA] agenda,” and that all “involved agencies” are “committed” to the “prosperity of American Farmers.” The Assessment concludes that “[t]he federal government will continue to regularly review the safety of these important crop protection tools.”

Corporate Funding of Research

The Assessment criticizes lobbying expenditures associated with the chemical-manufacturing and pharmaceutical industries and notes that a significant portion of environmental toxicology, epidemiology, nutrition, and chronic childhood disease studies are conducted by private food, pharmaceutical, and chemical corporations as well as “special interest [NGOs] and professional associations.” It also makes the unsubstantiated claim that “[l]imited comparisons between industry-funded research versus non-industry studies have raised concerns over potential biases in industry-funded research.”

The Assessment’s Recommendations

The Assessment concludes with ten next steps that are primarily focused on closing “critical research gaps” to “guide efforts to better combat childhood chronic disease.” Among other things, the next steps include:

• “Addressing the Replication Crisis” by creating a “coordinated initiative,” led by the National Institutes of Health, that invests in “reproducibility efforts to improve trust and reliability in basic science and interventions for childhood chronic disease.”
• Expanding an existing autism data initiative into a “broader, secure system” that would link “claims, [electronic health records], and environmental inputs to study childhood chronic diseases;”
• Creating a task force to apply “[artificial intelligence] and machine learning to federal health and nutrition datasets for early detection of harmful exposures and childhood chronic disease trends;”
• Funding “independent studies evaluating the health impact of self-affirmed [generally recognized as safe] food ingredients” that will “prioritiz[e] risks to children” and inform “transparent FDA rulemaking;”
• Funding long-term nutrition trials that compare “whole-food, reduced-carb, and low-UPF diets in children to assess effects on obesity and insulin resistance;”
• Coordinating a “national lifestyle-medicine initiative” that studies “integrated interventions in movement, diet, light exposure, and sleep timing;” and
• Launching a national toxicology initiative that maps “gene-environment interactions affecting childhood disease risk, especially for pollutants, endocrine disruptors, and pharmaceuticals.”

Next Steps

The Assessment provides critical insight into the priorities for the forthcoming Make Our Children Healthy Again Strategy. Given the short timeline for the Commission’s work, interested stakeholders should quickly evaluate the assertions made throughout the report and be prepared to identify the instances in which the totality of the science do not support the statements made. The MAHA Commission will proceed with the next phase, which is the development of recommendations the administration should implement to address the issues identified in the Assessment. It is unlikely the MAHA Commission will deviate from its prior practices and solicit comments from interested parties. Stakeholders, nonetheless, should look for opportunities to make certain the MAHA Commission has access to the totality of the evidence regarding these issues. 

We will continue to closely monitor and keep you updated on similar developments that impact the food industry. 

Authored by Martin Hahn, Elizabeth Fawell, Maile Gradison, Veronica Colas, and Chigozie Akah.