Leaked Draft Of MAHA Commission Strategy Report Outlines Sweeping Federal Actions On Chemicals In Food And The Environment

Key Takeaways

What Happened: A leaked draft of the Make Our Children Healthy Again Strategy (the Make America Healthy Again (MAHA) Commission's action plan) is circulating. The draft outlines extensive executive branch actions intended to "end childhood chronic disease," including in relation to food chemical regulation and review, nutrition policy, and agency restructuring.
Why it Matters: If implemented, the Strategy would drive near‑term regulatory activity at HHS/FDA, EPA, USDA, NIH, and other agencies, particularly around GRAS reform, post‑market review of food chemicals, food‑dye phase‑downs, cumulative exposure frameworks, and nutrition and front-of-pack labeling.
What You Should Do: While treating the draft as non‑final, food and chemical manufacturers should begin planning for likely FDA, EPA, USDA, and NIH regulatory actions, monitor the Federal Register for rulemakings and requests for information, and prepare comment strategies.

Last month, an apparently near-final draft of the MAHA Commission's long-anticipated Strategy Report (the Strategy), was made available on August 15. This leaked draft follows on President Trump's February 2025 Executive Order 14212, which created the MAHA Commission. In May 2025, the Commission's MAHA Assessment identified four key drivers of childhood chronic disease—poor diet, cumulative chemical exposures, chronic stress and lack of physical activity, and overmedicalization—and previewed a follow‑on Strategy to recommend executive actions.

While not final, the draft Strategy is worth reading. It translates the MAHA Assessment's themes into specific agency initiatives that, if adopted, would represent a coordinated push across the U.S. Department of Health and Human Services (HHS), U.S. Food and Drug Administration (FDA), U.S. Environmental Protection Agency (EPA), the National Institutes of Health (NIH), U.S. Department of Agriculture (USDA), and other agencies. Food producers and chemical manufacturers should closely monitor these agencies' regulatory proposals and actions to understand this shifting legal landscape.

Keep reading for a roundup of:

1. Potential Food Chemical Policy Changes

The draft Strategy recommends and anticipates numerous regulatory and policy changes that could impact food and food chemical manufacturers. These include:

Food Chemical Policy

FDA will continue to advance policies to limit or prohibit the use of petroleum-based food dyes and other potential food additives of concern in the U.S. food supply. This will include "working with industry partners in support of the phase out," i.e., encouraging voluntary deselection by food companies. USDA will apply these changes to food served through federal nutrition programs, with an emphasis on school lunches. FDA will also expedite review of petitions for naturally derived color additives and provide greater flexibility for label claims such as "no artificial color."
FDA will expand and systematize post-market review of food chemicals, which encompass food additives, color additives, substances said to be generally recognized as safe (GRAS), food‑contact substances, and contaminants.
FDA will update the current GRAS self-affirmation framework to ensure that "all new food additives meet applicable safety standards with increased transparency."

Notably, FDA previously announced and begun to implement all of these proposed changes—none of the food-chemical policy changes identified in the draft Strategy are new. Furthermore, the draft Strategy refers to "new" food chemicals and emphasizes remaining "within the scope of statutory authority" in the context of GRAS reform. These references suggest that FDA is not currently considering a blanket retroactive rescission of the GRAS status of food ingredients already on the market. They may also indicate that FDA is not pushing for legislative changes to the Federal Food, Drug, and Cosmetic Act with respect to GRAS, notwithstanding a March 18 HHS press release saying, "HHS also is committed to working with Congress to explore ways legislation can completely close the GRAS loophole," and calling such legislation "a crucial step." It is possible that we now know the scope of the MAHA movement's changes to federal food chemical regulation.

Nutrition Policy

USDA, HHS, and FDA will continue efforts, including a formal Request for Information, to develop a U.S. government-wide definition for "ultra-processed food" to support future research and policy development.
- A federal definition could also potentially preempt the growing patchwork of definitions proposed or adopted by various states.
Near-term release of the 2025–2030 Dietary Guidelines for Americans (DGAs) "align[ed] with science, data, and healthy recommendations" and process reforms for future revisions related to membership and scientific review.
Federal nutrition programs, such as Supplemental Nutrition Assistance Program (SNAP), Women, Infants, and Children (WIC), Head Start, and school meals, will prioritize "whole, healthy foods" and reduce reliance on highly processed foods, with concepts such as standardized food boxes raised as potential solutions.
FDA will revisit the Biden FDA's proposed Front-of-Pack Nutrition Information rule in light of public comment and the forthcoming DGAs.
FDA will "modernize" nutrient requirements and testing for infant formula, while USDA and HHS will support breastfeeding rate increases and promote safe human milk donations.

2. Other Potential Chemical Policy Changes

Beyond food, the draft Strategy sketches a cross‑agency approach to chemical exposures. As a general matter, the draft states that EPA, USDA, and NIH will collaborate to develop frameworks for evaluating cumulative impacts across chemical classes, with an emphasis on new approach methodologies (NAMs) that include organoids, computational simulations, and real-world data integration to assess potential chronic disease links. The draft further highlights priority research areas, including fluoride and pharmaceuticals in water, microplastics and other synthetic particles, ambient air quality, oral‑systemic health relationships, the microbiome, and longitudinal pediatric health data.

Separately, the draft states that precision agriculture initiatives will promote reduced pesticide volumes through targeted application technologies.

3. Potential Agriculture and Food Deregulatory Changes

The draft Strategy further proposes numerous "agriculture deregulation" and "food deregulation" action items, which largely focus on lowering regulatory burdens on small-scale producers and expanding consumer choice. The proposed changes, many of which lack details or specifics, include:

Agriculture

Defining post-harvest rinse and wash water as non-hazardous under the Resource Conservation and Recovery Act.
Reducing compliance burdens and digitizing USDA applications to ease access.
Simplifying and reducing costs for farms transitioning to organic practice.
Removing bureaucratic barriers to Community Supported Agriculture (CSA) and direct-to-consumer sales.
Improving credit reliability, land acquisition, and permitting for farmers.

Food

Expanding categorical exclusions for low-volume meat processing operations from water discharge and hazardous waste permitting.
Providing additional guidance on Hazard Analysis Critical Control Points for very small meat processors and supporting mobile processing units.
Removing barriers for small dairies to process and sell locally (it is possible that such "barriers" include prohibitions on the sale of raw milk).
Removing zoning restrictions on mobile grocery units.
Reforming or removing outdated standards of identity and guidance documents and introducing "flexibility in manufacturing requirements."

Many of the proposed changes would likely require state and local action instead of or in addition to federal action.

4. Potential Agency Restructuring and Process Changes

Organizational changes feature prominently in the draft Strategy. The proposed changes direct:

HHS to reorganize its offices to establish an Administration for a Healthy America, which will centralize leadership on childhood chronic disease prevention.
NIH to create an Office of Research Innovation, Validation, and Application to advance and scale NAMs, as well as an Office of Research Innovations, Planning, and Analysis to improve research prioritization, reproducibility, and portfolio management.
EPA to expand scientific capacity in the Office of Chemical Safety and Pollution Prevention and the Office of Water to accelerate reviews.
NIH, HHS, FDA, and USDA to impose enhanced disclosure and recusal requirements and public payment-tracking databases for federally funded research and advisory committees.

Ultimately, these may be the draft Strategy's most consequential changes from current policy. The draft's packaging of its many initiatives into a coordinated, interagency program could compress timelines for policy development and increase the likelihood of parallel actions across multiple agencies.

5. Implications for Stakeholders

For food and food chemical manufacturers, the clearest signal is heightened scrutiny of additives, colorants, and labeling. Companies should inventory products containing FD&C colors, evaluate reformulation pathways and natural‑color alternatives, and ensure claim substantiation, particularly for "no artificial color" and similar statements. FDA continues to move forward on approvals for naturally derived color additives, including most recently on butterfly pea flower, calcium phosphate, and galdieria extract blue.

Chemical manufacturers and packaging suppliers should also prepare for NAM‑driven evaluations and the incorporation of cumulative‑exposure concepts into risk assessments. They should engage early on model selection and criteria.

Across sectors, expanded transparency and conflict‑management requirements for research and advisory activities may affect collaborations, sponsorships, and advisory committee participation.

6. What's Next

Because this is a leaked draft, specific proposals and conclusions may shift. Nevertheless, the draft Strategy appears designed to prompt rapid implementation, with rulemakings, task forces, and new research initiatives expected over the coming months. Stakeholders should watch for near‑term Federal Register activity—proposed rules, draft frameworks, and requests for information—alongside the creation of task forces and public meetings, and particularly in relation to FDA and EPA activities on food chemicals and NAMs. Beveridge & Diamond will continue to track MAHA-related developments.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.