MAHA Commission Releases Four-Part Report
In a White House event on Thursday, May 22, 2025, President Trump and appointed Chair of the Commission, Health and Human Services Secretary Robert F. Kennedy, Jr., released the Make America Healthy Again (MAHA) Commission Report titled, “Make Our Children Healthy Again: Assessment.” The Report declares that U.S. children today “are the sickest generation in American history in terms of chronic disease” and names poor diet, exposure to an agglomerate of environmental toxins, a decline in physical activity, an increase in chronic stress, and overmedicalization as “four potential drivers behind the rise in childhood chronic disease.”
The Report stops short of providing recommendations but is instead a “call to action” intended to “examin[e] the root causes of deteriorating child health” promising to establish “a clear, evidence-based foundation for the policy interventions, institutional reforms, and societal shifts needed to reverse course.”
The 73-page Report is the first deliverable from the MAHA Commission, which was created by Executive Order 14212 on February 13, 2025. The Commission is expected to release a series of policy recommendations in August -- a “Make Our Children Healthy Again Strategy” -- based on the findings from the Report. In addition to RFK, Jr., the Commission Chair, and Vincent Haley, Assistant to the President for Domestic Policy - Executive Director, included among the MAHA Commission members are four other Cabinet Secretaries, FDA Commissioner Martin Makary, and Dr. Jayanta Bhattacharya, Director of the National Institutes of Health.
Section One of the Report sets out the research into why the consumption of ultra-processed foods (UPF) may be detrimental to children’s health. The Report calls out certain food additives “of potential concern,” including “food colorings, such as Red 40,” titanium dioxide, propylparaben, butylated hydroxytoluene (BHT), and the artificial sweeteners aspartame, sucralose, and saccharin.
FDA recently announced that it will take steps to expedite post-market review of titanium dioxide, BHT, and propylparaben in the food supply. Notably, FDA just recently affirmed the safety of aspartame and other artificial sweeteners when used under approved conditions. On titanium dioxide, , FDA noted the European Food Safety Authority's (EFSA) 2021 conclusions regarding the potential genotoxicity of titanium dioxide nanomaterials, but concluded it “did not identify concerns related to potential genotoxicity based on the data available and noted that TiO2 did not cause cancer” in NTP carcinogenicity studies. FDA found in early 2023 that “the available safety studies [on titanium dioxide] do not demonstrate safety concerns connected to the use of TiO2 as a color additive.”
Section Two of the Report focuses on exposures to environmental chemicals and the “unique characteristics” that make children “particularly vulnerable” from exposures that may occur during sensitive developmental windows, among other factors. The Report also points out that, globally, current regulatory and medical systems largely evaluate the safety of chemicals individually or as a class and, thus, “may be neglecting potential synergistic effects and cumulative burdens.”
Specific substances identified in the MAHA report that “call for continued studies” include phthalates, bisphenols, and PFAS “to better under the cumulative load of multiple exposures and how it may impact children’s health.” Also recommended for similar studies are microplastics, fluoride, electromagnetic radiation, and crop protection tools (e.g., pesticides, herbicides, and insecticides).
The Report identifies several “common exposure pathways” for the identified substances and materials of concern, such as food, including its packaging, drinking water, and personal care products, among others.
From there, the Report goes into the crisis of childhood behavior in the digital age, the overmedicalization of children, and a lengthy indictment of corporate responsibility for dominating and distorting “scientific literature, legislative actions, academic institutions, regulatory agencies, medical journals, physician organizations, clinical guidelines, and the news media.”
Finally, the last part of the Report is titled “Next Steps,” recommends critical research gaps that are needed "to better combat childhood chronic disease in America." It includes Generally Recognized as Safe (GRAS) Oversight Reform, which calls for “fund[ing] independent studies evaluating the health impact of self-affirmed GRAS food ingredients, prioritizing risks to children and informing transparent FDA rulemaking.”
This likely follows from Secretary Kennedy’s direction to FDA to consider rulemaking to eliminate the pathway for self-affirming substances in the food supply as previously reported in packaginglaw.com.
Keller and Heckman LLP is monitoring future developments and potential regulatory or other actions resulting from the MAHA Commission Report.