The Administration has signaled that it will release its first Make America Healthy Again (MAHA) Commission report as early as today. The MAHA Commission was created in February 2025 with a goal of investigating and addressing the contributing causes of "the childhood chronic disease crisis." The MAHA Commission will focus on many components of health, one of which is improving the food supply and nutrition of all Americans. President Trump appointed Department of Health and Human Services (HHS) Secretary Robert F Kennedy Jr. to lead the effort, given Kennedy's longstanding interest in addressing the proliferation and negative health impacts of food dyes, ultra processed foods and seed oils. Underscoring the Trump Administration's commitment to these goals, the Fiscal Year 2026 Discretionary Budget Request to Congress included $500 million for MAHA initiatives. The first of the required deliverables under the MAHA Commission Executive Order, the "Make Our Children Healthy Again Assessment"—which is intended to review the contributing factors of chronic diseases in children and to identify and evaluate existing federal programs intended to prevent and treat childhood health issues—is set to be released today. Manatt Health will provide in-depth analysis of the MAHA Commission report and implications for nutrition after its release.
Notably, the Trump Administration has not waited for the release of Make Our Children Healthy Again Assessment to make progress in furthering the goals of the MAHA Commission. Throughout the first 100 days of the Trump Administration, HHS, including the Food and Drug Administration (FDA) and National Institutes of Health (NIH), as well as the U.S. Department of Agriculture (USDA), under the leadership of Secretary Brooke Rollins, have pursued a range of food- and nutrition-related initiatives, many of which have bipartisan support in Congress. These actions are occurring during significant staffing cuts, departures and proposed budget reductions to food programs like the Supplemental Nutrition Assistance Program (SNAP), initiated by the Trump Administration and pending in Congress. The effectiveness of the MAHA Commission in fulfilling the goal of addressing childhood chronic illness as it relates to food and nutrition will ultimately be influenced by the outcome of these funding and staffing cuts.
This article describes some of these key federal actions pursued in the initial months by the Trump Administration.
Key Food and Nutrition Activities:
- FDA-NIH Nutrition Regulatory Science Program: On May 9, 2025, FDA and NIH announced "a new, joint innovative research initiative" under which FDA and NIH will "implement and accelerate a comprehensive nutrition research agenda that will provide critical information to inform effective food and nutrition policy actions to help make Americans' food and diets healthier." The initiative will explore questions such as "how and why ultra-processed foods harm people's health" and how "might certain food additives affect metabolic health and possibly contribute to chronic disease."
- Potential Elimination of "Generally Recognized as Safe" Pathway: In March, Secretary Kennedy directed the FDA to take steps to explore potential rulemaking to revise its Substances Generally Recognized as Safe (GRAS) Final Rule and related guidance to eliminate the self-affirmed GRAS pathway. Under the current system, food companies are responsible for determining if a new substance is GRAS or requires pre-market submission to FDA for review as a food additive. The self-affirmed GRAS pathway allows food manufacturers to bring new food additives to market without significant regulatory oversight. Stricter GRAS standards and expanded premarket reviews would enhance oversight of new additives, but it's unclear if the FDA will apply these changes retroactively or only moving forward. To amend this final rule, HHS will need to follow a lengthy formal rulemaking processes, which is further complicated by the Trump Administration's Executive Order restricting the promulgation of new regulations.
- Implementation of FDA's Final Rule on "Healthy" Nutrient Content Claim: At the end of the Biden Administration, FDA issued a final rule which updated the requirements governing the permissible use of the "healthy" claim on a food package with an effective date of February 25, 2025. This effective date was later postponed under the Trump Administration's January 20, 2025, regulatory freeze order. However, the Trump Administration moved forward with completing implementation and reinstated the effective date of the final rule as April 28, 2025.
- FDA Proposed Rule on Front-of-Package Nutrition Labeling: On January 16, 2025, in the final days of the Biden Administration, FDA issued a proposed rule to require a "front-of-package" label for certain foods involving a "compact informational box containing certain nutrient information on the principal display panel" with a goal of providing "consumers, including those who have lower nutrition knowledge, with standardized, interpretive nutrition information that can help them quickly and easily identify how foods can be part of a healthy diet." On May 8, 2025, FDA extended the comment period for an additional 60 days and, last week, FDA officials in the food program publicly reiterated the Trump Administration's commitment to driving forward with this regulation.
- Artificial Food Dyes: HHS and FDA announced a series of measures to phase out eight petroleum-based synthetic dyes from the nation's food supply through a combination of revoking authorizations for Citrus Red No. 2 and Orange B and partnerships with food manufacturers to voluntarily eliminate the remaining synthetic dyes and transition to natural dyes on an agreed upon timeline. Food manufactures have sought federal action to standardize the disparate food dye regulations passed by states over the last decade. However, thus far industry group responses have been mixed on whether they will comply with the FDA's voluntary requests to eliminate the targeted six petroleum-based synthetic dyes or on the proposed timeline.
- Supplemental Nutrition Assistance Program:
Secretaries Kennedy and Rollins have declared that USDA and HHS are
"pursuing reform to the Supplemental Nutrition Assistance
Program (SNAP)," including by encouraging "taxpayer
dollars to go toward wholesome foods, such as whole milk, fruits,
vegetables and meats" and urging "all governors to submit
waivers to help promote access to these critical sources of
nutrition, including waivers that can limit what can be purchased
with food stamps, get healthy foods to rural communities and
prioritize nutritional standards in school meals." In April,
Secretary Kennedy conducted a multi-state tour "to celebrate MAHA
initiatives in the Southwest," which included stops to
highlight "new state laws that ban ultra-processed foods and
dyes in public schools, restrict SNAP purchases of candy and
soda".
Republicans have identified major cuts to the SNAP program as a potential lever to offset the Trump tax cuts. House Republicans are reportedly eying potentially $230 billion in cuts, which could include rolling back the Biden-era Thrifty Food Plan update that increased benefits by about $1 a day to align with the current cost of a healthy diet. A more realistic short-term target for House Republicans may be increasing the existing SNAP work requirements, which could target removing exceptions for individuals over 54 or for parents of school-aged children. - School Food: At a recent cabinet meeting, Secretary Kennedy claimed that "70 percent of the food that our children eat [in schools] is ultra-processed food, which is killing them." He and Secretary Rollins vowed "major changes" to the school lunch program over the next school year. Yet thus far, the substantial actions by the Administration have been cuts to critical USDA programs to provide funds for schools and child care programs to purchase healthy foods from local farms. HHS and USDA will jointly issue the updated Dietary Guidelines for Americans in 2025, which govern school meals. Secretary Kennedy has emphasized transforming school food to prioritize local, whole and healthy foods. HHS and USDA's plan to revamp the school food program may encounter obstacles such as a lengthy rule-making process, opposition from the food industry, and higher costs for purchasing and preparing whole, local foods.
- Senior Food Insecurity: The recent Trump Administration Discretionary Budget Proposal to Congress included a plan to cut funding to the USDA Commodity Supplemental Food Program (CSFP), which provides healthy supplemental groceries to low-income seniors, and replace it with "MAHA food boxes." The boxes would include commodities sourced from domestic farmers and given directly to American households, removing the role of food banks and other nutrition agencies who previously administered CSFP locally.
Conclusion
Secretaries Kennedy and Rollins have consistently reiterated the Trump Administration's commitment to fulfilling the goals of the MAHA initiative and have rapidly made progress in that effort. While they have signaled their intent to clamp down on the proliferation of ultra-processed foods, there remains substantial work to actually revise the GRAS final rule, pressure the food industry to voluntarily ban all petroleum-based dyes, and update and fund the school food program to prioritize healthy, whole foods. However, the level of interest by the Trump Administration in improving Americans' access to healthy and wholesome food is unprecedented in recent years
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