On May 22, 2025, President Trump’s Make America Healthy Again (“MAHA”) Commission released a report titled “Make Our Children Healthy Again: Assessment” (the “Assessment”). The President’s February Executive Order establishing the MAHA Commission directed the Commission to issue this Assessment to, among many things, identify and describe childhood chronic disease in America compared to other countries; assess the potential over-utilization of medication, certain food ingredients and chemicals and the prevalence of and threat posed by the prescription of serotonin reuptake inhibitors, antipsychotics, mood stabilizers, stimulants, and weight-loss drugs; identify best practices for preventing childhood health issues including on proper nutrition; eliminate undue industry influence on science; and establish a framework for transparency and ethics review in industry-funded projects.
The Assessment is framed as a “call to action” aimed at addressing the chronic disease crisis affecting children in the U.S. It seeks to unpack the potential dietary, behavioral, medical, and environmental drivers behind this issue and establish “a clear, evidence-based foundation for the policy interventions, institutional reforms, and societal shifts needed to reverse course.” The Assessment begins with data and statistics on rising levels of childhood obesity, diabetes, neurodevelopmental disorders, childhood cancer, mental health issues, and autoimmune disorders, and identifies four potential drivers behind this rise in childhood chronic diseases: (1) poor diet, (2) aggregation of environmental chemicals, (3) lack of physical activity and chronic stress, and (4) overmedicalization.
Poor Diet: The Assessment states that children’s diets are primarily ultra-processed foods (“UPFs”) which contain high levels of added sugars, chemical additives, and saturated fats. Specifically, the Commission asserts that “[n]early 70% of an American child’s calories today comes from ultra-processed foods (increased from zero 100 years ago), many of which are designed to override satiety mechanisms and increase caloric intake.” The Commission notes that there is “no single, universally accepted definition” for UPFs but adopts the following definition: “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.”
The Commission concludes that UPFs are detrimental to children’s health because of:
- Nutrient depletion. Ultra-processed grains, sugars, and fats have displaced nutrient-dense whole foods and these ingredients have dominated children’s diets.
- Increased caloric intake. The Commission believes that production changes to fiber, protein, caloric density, and digestibility in UPFs have led to interference with the brain’s reward pathways and feelings of satiety, which could cause spikes in blood sugar and insulin levels and damage the gut microbiome. The Assessment highlights the benefits of whole foods, in particular those from U.S. farmers.
- Inclusion of food additives. According to the Assessment, certain food additives such as emulsifiers, binders, sweeteners, colorings, and preservatives have been linked to increased risks of various diseases and disorders. The Assessment specifically highlights food colorings such as red 40 and titanium dioxide, propylparaben, butylated hydroxytoluene (BHT), and artificial sweeteners such as aspartame, sucralose, and saccharin. The Assessment also notes, without providing further detail, that some parents prefer European infant formula brands due to concerns around food additives in U.S.-manufactured infant formula.
Aggregation of Environmental Chemicals: The Assessment states that the cumulative effect of exposure to thousands of synthetic chemicals through food, water, and air may have long-term health effects. This includes exposure to thousands of chemicals and other contaminants such as heavy metals, PFAS, pesticides, phthalates, microplastics, fluoride, and bisphenols.
Lack of Physical Activity and Chronic Stress: The Assessment cites children’s pervasive use of technology, increased screen time, reduced physical activity, and psychosocial stressors such as loneliness, chronic stress, and sleep deprivation as contributing to the chronic disease epidemic.
Overmedicalization: The Assessment also avers that increased use of prescription drugs as a response to childhood chronic disease has had negative effects on health.
The Assessment recommends ten research initiatives to support a comprehensive strategy going forward, including post-marketing surveillance of pediatric drugs, AI-powered surveillance for early detection of harmful exposures and childhood chronic disease trends, nutrition trials, and precision toxicology. These recommendations also include GRAS oversight reform, described as “Fund[ing] independent studies evaluating the health impact of self-affirmed GRAS food ingredients, prioritizing risks to children and informing transparent FDA rulemaking.” Relatedly, FDA announced earlier this month an initiative to systematically review chemicals in the food supply, with a particular focus on BHT, butylated hydroxyanisole (BHA), and azodicarbonamide (ADA). This followed FDA’s April announcement of actions aimed at phasing out all “petroleum-based synthetic dyes” from the nation’s food supply. Deputy Commissioner for Human Foods Kyle Diamantas has stated that industry should expect comprehensive reform on GRAS for new ingredients and historical GRAS ingredients later this year.
The MAHA Commission will next develop and provide a strategy to restructure the federal government’s response to childhood chronic disease. HHS Secretary Robert F. Kennedy, Jr. said the Commission will work over the next 80 days to issue policy recommendations for the White House based on the Assessment, stating “This report is really … a diagnosis. The prescription comes in 100 days.”
If you have any questions concerning the material discussed, please contact the authors of this client alert.
Back
