October 15, 2025
In early September, the Make America Healthy Again (MAHA) Commission released its strategic approach to address childhood chronic health in the U.S.—the final deliverable mandated by an earlier executive order issued by President Trump. The strategy outlines policy recommendations in four key areas: advancing critical research to drive innovation, realigning incentives and systems to drive research regarding health outcomes, increasing public awareness and knowledge, and fostering private sector collaboration.
The MAHA Commission was established to examine the current understanding around chronic disease in the United States and to identify policy recommendations to lower chronic disease rates, especially in children. In May, the Commission released the Make Our Children Healthy Again Assessment, which explored the “potential dietary, behavioral, medical, and environmental drivers” contributing to the rates of chronic diseases in U.S. children.
Key recommendations
The recommendations from the MAHA Commission fall into two general categories: 1) increasing oversight of certain food ingredients and marketing practices for food and drugs and 2) reducing regulatory burdens by eliminating obsolete rules and guidance.
Many of the suggestions come as no surprise. The administration has been clear about its priorities for the Food and Drug Administration (FDA) and reforming the regulatory approach to food and drugs. The MAHA Commission strategy reaffirms the FDA’s commitment to implementing policies that limit or prohibit the use of petroleum-based food dyes and notes that the U.S. Department of Agriculture (USDA) will apply the resulting framework to food served through federal nutrition programs, such as the school lunch programme.
The report also addresses reforms to the FDA’s Generally Recognized as Safe (GRAS) pathway. In the Trump Administration’s Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions, the FDA outlined its plans to issue a Notice of Proposed Rulemaking (NPRM) to implement a mandatory GRAS notification system for the use of food and animal substances that are “purported to be GRAS.” The NPRM is expected in October 2025 and would remove the GRAS “loophole” created by the current system that allows manufacturers to self-affirm that the use of a substance is GRAS without notifying the FDA.
For the food and beverage industry, the strategy also includes recommendations to address ultra-processed foods, front-of-package (FOP) labeling, the post-market assessment of chemicals in food, and Dietary Guidelines for Americans (DGAs), among other items.
The plan also addresses several forms of advertising, including increasing oversight and enforcement for violations of direct-to-consumer (DTC) prescription drug advertising laws and exploring the development of industry guidelines to limit the direct marketing of certain unhealthy foods to children. The latter would include evaluating the use of misleading claims and imagery.
To help reduce companies’ regulatory burdens, the FDA intends to withdraw outdated or obsolete guidance documents. This action would also eliminate potential confusion and better reflect modern practices. The strategy outlines a variety of other focus areas for removing burdensome regulations, including streamlining requirements for building new grocery stores, reforming outdated standards of food identity, and removing or amending regulations with outdated submission requirements like paper records.
Considerations for industry
Senior officials from the FDA, Health and Human Services (HHS), and other departments have been hinting at many of these policies since January, and the MAHA Commission previewed them in their initial assessment in May. With the final report published, the food and beverage and pharmaceutical industries should expect regulators to take rapid action to begin implementing the recommendations. HHS Secretary Robert F. Kennedy Jr. himself noted that the administration will move “very, very quickly” to implement the strategy.
Businesses should thoroughly review the strategy document and consider how any regulatory changes to comply with the report’s recommendations could impact their operations or introduce new risks. Many of those efforts are already underway, and businesses should take advantage of the associated opportunities for stakeholder engagement, including participating in the development of a definition for ultra-processed foods.
Food manufacturers whose products include self-affirmed GRAS ingredients should closely monitor the release of the FDA’s proposed rule on mandatory GRAS notifications for additional detail about how the agency will address the self-affirm pathway. During the rulemaking process, manufacturers should introduce new ingredients with caution. This may mean voluntarily notifying the FDA of the intended use of self-affirmed GRAS ingredients in anticipation of that notification becoming a requirement.
It will also be critical for businesses to keep their recall and crisis plans up to date. This will be particularly important given increased public scrutiny of practices that are being positioned as antithetical to the Make America Healthy Again campaign and increased scrutiny of advertising practices.
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