MAHA Commission Publishes Report to Highlight Childhood Chronic Disease Drivers

On May 22, 2025, President Trump’s Make America Healthy Again (MAHA) Commission released an assessment titled “The MAHA Report: Make Our Children Healthy Again Assessment.” The report—framed as a “call to action”—stems from a February 2025 Executive Order establishing the MAHA Commission and identifies what it views as four primary contributors to childhood chronic disease in America: (1) poor diet and ultra-processed foods, (2) environmental chemical exposure, (3) physical inactivity coupled with chronic stress, and (4) overmedicalization.

Poor Diet + Ultra-Processed Foods

The report states that “nearly 70% of children’s calories currently now come from UPFs” (ultra-processed foods) and this contributes to obesity, diabetes, and other chronic conditions.

The report defines UPFs as “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 report recommends shifting children’s diets to “whole foods” as opposed to UPFs.

In addition to targeting so-called UPFs, the report seeks to draw a link between certain food additives—namely, emulsifiers, binders, sweeteners, colorings, and preservatives—and increased risks of various diseases and disorders. The report lists the following food additives as “of potential concern”: red 40, titanium dioxide, propylparaben, butylated hydroxytoluene (BHT), and certain artificial sweeteners (e.g., aspartame, sucralose, and saccharin). Notably, the U.S. Food and Drug Administration (FDA) is already in the process of reviewing the safety of titanium dioxide, propylparaben, and BHT per the agency’s “List of Select Chemicals in the Food Supply Under FDA Review.”

The report additionally (1) criticizes Dietary Guidelines for Americans (DGA) for not expressly addressing UPFs; (2) contends that federal programs like the Supplemental Nutrition Assistance Program (SNAP) compound poor nutrition among American children, noting that “children on SNAP struggle to meet key dietary guidelines and perform poorly on key health indicators when compared with income-eligible and higher income nonparticipants”; and (3) calls for further nutrition research and a reevaluation of food additives and seed oils, in particular.

Environmental Chemical Exposure

The report expresses concern about children’s exposure to environmental chemicals, such as pesticides, microplastics, and dioxins, as a factor driving childhood chronic disease and calls on the National Institutes of Health (NIH) to conduct clinical studies to better understand exposure to PFAS, microplastics, fluoride, electromagnetic radiation, phthalates, bisphenols, and crop protection tools (e.g., pesticides, herbicides, and insecticides). Although the report calls for continued studies from the public and private sectors of various environmental chemicals, it notably does not call on regulators to restrict pesticides. Instead, the report notes that “American farmers rely on these products and actions that further regulate or restrict crop protection tools beyond risk-based and scientific processes set forth by Congress must involve thoughtful consideration of what is necessary for adequate protection, alternatives, and cost of production.”

Chronic Stress and Lack of Physical Activity

The report cites the lack of physical activity by American children, and the corresponding increase in screen time, surge in chronic stress, sleep deprivation, and psychological stressors as factors contributing to the childhood chronic disease crisis.

Overmedicalization

The report criticizes the health care system as potentially causing further harm to American children through overmedicalization, especially with regard to drugs used to treat psychological conditions, antibiotics, and GLP-1 medications. In addition, the report calls for increased clinical trials to further understanding of vaccine safety and any links to chronic disease.

Looking Ahead

As a next step, the MAHA Commission will develop and publish a strategy to address the federal government’s response to childhood chronic disease by August 2025. Notably, the report previews what we might expect to see fleshed out in the forthcoming strategy, including in relevant part the following research initiatives:

• Post-Marketing Surveillance. NIH and FDA should build systems for real-world safety monitoring of pediatric drugs and create programs to independently replicate findings from industry-funded studies.
• AI-Powered Surveillance. Create a task force to apply AI and machine learning to federal health and nutrition datasets for early detection of harmful exposures and childhood chronic disease trends.
• GRAS Oversight Reform. Fund independent studies evaluating the health impact of self-affirmed GRAS food ingredients, prioritizing risks to children and informing transparent FDA rulemaking.
• Nutrition Trials. NIH should fund long-term trials comparing whole food, reduced-carb, and low-UPF diets in children to assess effects on obesity and insulin resistance.
• Precision Toxicology. Launch a national initiative to map gene–environment interactions affecting childhood disease risk, especially for pollutants, endocrine disruptors, and pharmaceuticals.

The release of this report has resulted in significant responses from related industries and is very likely to inform a number of MAHA-aligned legislative efforts at both the federal and state levels. MoFo is actively monitoring industry and legislative trends and stands ready to provide strategic regulatory and class action counsel related to the evolving U.S. food legal landscape.