In response to President Trump's February 13, 2025, Executive Order (EO) 14212, "Establishing The President's Make America Healthy Again Commission," the White House issued part of what is being called "The MAHA Report" (with MAHA an acronym for Make America Healthy Again), entitled "Make Our Children Healthy Again: Assessment" (the Assessment) on May 22, 2025. Section One of the Assessment, "The Shift to Ultra-Processed Foods," includes the Commission's thoughts on the U.S. agricultural system, food additives, food industry regulation, and government food programs, while Section Two of the Assessment, "The Cumulative Load of Chemicals in our Environment," includes its take on chemical exposures and pathways, corporate influence, and highlights some top concerns. The Assessment's core messages add yet another element of business uncertainty that chemical stakeholders would be wise to note.
Section Two calls upon the public and private sectors, but especially the National Institutes of Health (NIH), to enhance understanding of the cumulative effects of multiple exposures on children's health. Specifically, it highlights concerns related to:
- Per- and Polyfluoroalkyl Substances (PFAS);
- Microplastics;
- Fluoride;
- Electromagnetic Radiation (EMR);
- Phthalates;
- Bisphenols; and
- Crop Protection Tools (including pesticides, herbicides, and insecticides).
The Assessment's call-out of fluoride is particularly notable, citing studies that suggest a correlation between fluoride exposure and reduced intelligence quotient (IQ) scores in children. Some of the cited studies have been criticized for methodological flaws, misinterpretations, and incorrect understandings of key scientific fields. For instance, a systematic review and meta-analysis published by the American Medical Association in JAMA Pediatrics in January 2025 found an inverse association between high levels of fluoride exposure and children's IQ scores, but the authors acknowledged limitations in the data and cautioned against drawing definitive conclusions or — perhaps most importantly — applying the findings to the U.S. population. The authors note that none of the included studies were conducted in the United States (45 of the 74 studies were conducted in China, where fluoride levels are generally higher than those in the United States), and the study does not account for the impact of other factors — including socioeconomic status — that might be expected to influence the findings.
Regarding pesticides, the Assessment specifically names chlorpyrifos, atrazine, and glyphosate as examples presenting notable risks from modern agricultural production methods. Section One of the Assessment spends much time on the problems said to be associated with the modern U.S. food production system: ultra-processed foods (UPF), nutrition, and typical industry practices. The result is disproportionate risks from the American diet compared to other Western countries, such as France or Germany. Like the fluoride example, there are footnotes citing studies to raise these concerns, although the established data about pesticide residues are found to be compliant with the requirements of the Food Quality Protection Act (FQPA). The safety standard in FQPA is that there is a reasonable certainty of no harm from pesticide residues, which is contrary to the Assessment's tone that the food supply and its components are causing widespread harm to the consuming public.
The Assessment itself states that "a large-scale FDA study of pesticide residues (2009-2017) found the majority of samples (>90%) were compliant with federal standards. More recent data from the USDA's Pesticide Data Program found that 99% of food samples tested in 2023 were compliant with EPA's safety limit." If the Assessment's unlikely point is that the U.S. government's own safety thresholds are too low a bar, it is never explicitly stated. Indeed, it takes extra care in Section Two to point out that U.S. farmers (and U.S. consumers) rely on these crop protection tools, and that "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." The whiplash continues in the very next paragraph, as pesticide manufacturers are specifically called out for the "corporate influence" that comes from private corporations conducting environmental toxicology and epidemiology studies.
In addition to often feeling misaligned with itself, the Assessment also appears to be misaligned with other federal agencies, particularly the U.S. Environmental Protection Agency (EPA). While the Assessment advocates for stricter controls and greater regulatory oversight of certain chemicals, it argues against key regulations in the food industry and does not address the resource constraints faced by agencies like EPA, nor President Trump's "Unleashing Prosperity Through Deregulation" Presidential Action. Notably, on March 12, 2025, EPA Administrator Lee Zeldin announced 31 deregulatory actions, touted as "the greatest and most consequential day of deregulation in U.S. history" and reflecting a broader governmental trend toward deregulation. Yet the Assessment calls for "the current regulatory framework [to be] continually evaluated to ensure that chemicals and other exposures do not interact together to pose a threat to the health of our children." This juxtaposition highlights a disconnect between the Assessment's recommendations and the current regulatory climate, inviting uncertainty in the business community.
Although both Administrator Zeldin and U.S. Secretary of Health and Human Services Robert F. Kennedy Jr. have emphasized the importance of interagency coordination, it is unclear whether the Assessment reflects broad interagency deliberations and collaboration with key regulatory bodies. The Assessment has several instances where, after extensive condemnation of the modern food system, inserted is an ode to American farmers and farming: "Farmers are the backbone of America — and the most innovative and productive in the world. We continue to feed the world as the largest food exporter." Such accolades apparently are the sole contribution of the U.S. Department of Agriculture (USDA) during the interagency review process. This siloed approach may undermine the efficacy of the Assessment's recommendations and their potential implementation, creating further confusion for the regulated community.
Despite EPA's prime position to play a critical role in moving forward with many of the Assessment's goals, it is, along with USDA, notably absent from the list of agencies that the U.S. Department of Health and Human Services (HHS) press release cite as being "on the front lines" to "act swiftly to close research gaps and drive decisive action" associated with the Assessment. What agencies made the list of "agencies [that] will lead the charge"? NIH, the U.S. Food and Drug Administration (FDA), and the Centers for Medicare & Medicaid Services (CMS).
Ultimately, the Assessment's final recommendations, which it calls "Next Steps — Supporting Gold-Standard Scientific Research and Developing a Comprehensive Strategy," is distilled into a ten-point list:
- Addressing the Replication Crisis: NIH should launch a coordinated initiative to confront the replication crisis, investing in reproducibility efforts to improve trust and reliability in basic science and interventions for childhood chronic disease.
- 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.
- Real-World Data Platform: Expand the NIH-CMS autism data initiative into a broader, secure system linking claims, electronic health records (EHR), and environmental inputs to study childhood chronic diseases.
- AI-Powered Surveillance: Create a task force to apply artificial intelligence (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 Generally Recognized As Safe (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.
- Large-scale Lifestyle Interventions: Launch a coordinated national lifestyle-medicine initiative that embeds real-world randomized trials — covering integrated interventions in movement, diet, light exposure, and sleep timing — within existing cohorts and EHR networks.
- Drug Safety Research: Support studies on long-term neurodevelopmental and metabolic outcomes of commonly prescribed pediatric drugs, emphasizing real-world settings and meaningful endpoints.
- Alternative Testing Models: Invest in New Approach Methodologies (NAM), such as organ-on-a-chip, microphysiological systems, and computational biology, to complement animal testing with more predictive human-relevant models.
- Precision Toxicology: Launch a national initiative to map gene-environment interactions affecting childhood disease risk, especially for pollutants, endocrine disruptors, and pharmaceuticals.
These recommendations, and the Assessment as a whole, coincide with President Trump's May 23, 2025, EO 14303, "Restoring Gold Standard Science." Once again demonstrating a lack of alignment between key players, the Assessment may not hold up to that "Gold Standard," as even the White House acknowledges problems within the assessment (subsequently explained as "formatting issues"), and The New York Times and other news outlets report that the Assessment includes fake citations and faulty references. Many of the original 522 citations in the Assessment are reported to reference papers/studies that are mislabeled, contain incorrect publishing information, were not written by the cited author, include authors who did not work on the paper or omit researchers who had, or simply do not exist, with some correctly cited papers inaccurately summarized.
The errors have called into question the rigor of the Assessment and – given the type of errors made – led to claims that it may have been, at least in part, authored by AI. For an Assessment with a first "next step" of "improv[ing] trust and reliability in basic science," it's a stumble right out of the gate. The Assessment has no public authors. The White House has since uploaded a new copy of the Assessment with corrections. The MAHA Commission's Make Our Children Healthy Again Strategy, in which it is expected to develop policy recommendations, is due in August 2025, with the White House requesting $500 million in funding from Congress to cover the cost of the MAHA initiative.
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