On September 9, 2025, the U.S. Department of Health and Human Services (HHS) announced the release of the Make Our Children Healthy Again Strategy (MAHA Strategy) issued by the Make America Healthy Again (MAHA) Commission. This Strategy was required to be submitted to the President by August 12, 2025, based on the findings of the Commission in its Making Our Children Healthy Again report (MAHA Assessment), which was released on May 22, 2025, and is discussed in our blog.
In its press release announcing the Strategy's release, HHS describes the MAHA Strategy as a "sweeping plan with more than 120 initiatives to reverse the failed policies that fueled America's childhood chronic disease epidemic." HHS states that the MAHA Strategy outlines "targeted executive actions to advance gold-standard science, realign incentives, increase public awareness, and strengthen private-sector collaboration."
In the MAHA Strategy, the Commission identifies four potential issues it believes is behind the rise in childhood chronic diseases — poor diet, chemical exposure, lack of physical activity and chronic stress, and overmedicalization. The MAHA Strategy discusses the following five key focus areas to address childhood chronic diseases:
- Advancing Critical Research to Drive
Innovation: The MAHA Strategy states the National
Institutes of Health (NIH) will expand research into chronic
disease prevention, which includes focusing on nutrition and
metabolic health, food quality, environmental exposures, autism,
gut microbiome, precision agriculture, rural and tribal health,
vaccine injury, and mental health. Specifically, regarding
pesticides, the MAHA Strategy states NIH, the U.S. Food and Drug
Administration (FDA), and the U.S. Environmental Protection Agency
(EPA) will expand the use of New Approach Methodologies (NAM) to
allow earlier insight into chronic disease mechanisms using
human-relevant models, such as organoids, computational
simulations, and real-world data integration. This is intended to
develop a research and evaluation framework for cumulative
exposures across chemical classes with the assistance of EPA
research using NAMs to improve methods for evaluating human health
and environmental risks of chemical contaminations, with a focus on
pesticides acting through a common mode of action. Additionally,
the MAHA Strategy states that the U.S. Department of Agriculture
(USDA) and EPA will prioritize research programs to assist growers
adopt precision agricultural techniques to decrease pesticide
volumes. Other initiatives include but are not limited to
evaluations of water quality and air quality for their impact on
children and an evaluation of the risks and exposures of
microplastics and synthetics, including in common products such as
textiles.
- Realigning Incentives and Systems to Drive Health
Outcomes Research to Drive Innovation: The MAHA Strategy
sets forth short descriptions of numerous "policy
reforms" that HHS and other agencies will pursue. For example,
the MAHA Strategy states USDA and HHS will reform the
2025-2030 Dietary Guidelines for Americans to
align with science, data, and health recommendations in a
"user-friendly" format; HHS will coordinate with USDA and
FDA to define ultra-processed foods; FDA will improve food labeling
by revising its proposed Front-of-Pack nutrition information
rulemaking; FDA will close the "Generally Recognized as
Safe" (GRAS) loophole by implementing a mandatory GRAS
notification program; and FDA will remove harmful chemicals from
the food supply by developing and implementing an evidence-based
systematic process for post-market assessment of chemicals in food,
including chemicals present as unintentional contaminants. The
Strategy also states that the "[Centers for Disease Control
and Prevention (CDC)], informed by data and scientific review from
NIH and EPA, will update recommendations regarding fluoride and
PFAS in water."
- Process Efficiencies and Deregulation: The
MAHA Strategy states USDA will streamline organic certification
processes to encourage small farms to transition to organic
practices and reduce regulatory compliance burdens for small farms.
Under the title of "EPA Process Improvements," the
Strategy states EPA will take the following actions:
- Work to reform the approval process for the full range of
chemical and biologic products to protect against weeds, pests, and
disease to increase the timely availability of more innovative
growing solutions for farmers.
- Consider increased categorical exclusions under the National
Environmental Policy Act for low volume meat processing operations
from water discharge and hazardous waste permitting, and work with
states to fast-track approvals to strengthen regional meat
infrastructure and improve access to fresh protein in schools and
communities.
- Ensure flexibility for farms to manage manure and process water
without triggering industrial-grade permitting requirements and
avoiding the forced mandates of costly technologies or practices
that do not consider geography, weather, species, and operation
size.
- More clearly define post-harvest rinse and wash water as non-hazardous under the Resource Conservation and Recovery Act to relieve fruit/vegetable packers and producer handlers — especially smaller operations — of unnecessary wastewater treatment burdens.
- Work to reform the approval process for the full range of
chemical and biologic products to protect against weeds, pests, and
disease to increase the timely availability of more innovative
growing solutions for farmers.
- Increasing Public Awareness and Knowledge: Among the initiatives described, the MAHA Strategy states EPA will partner with food and agricultural stakeholders to ensure awareness and confidence in EPA's review of pesticides and how it relates to limiting the risks for users and the general public.
- Fostering Private Sector Collaboration: The MAHA Strategy states "USDA and EPA will launch a partnership with private-sector innovators to ensure continued investment in new approaches and technologies to allow even more targeted and precise pesticide applications. This can support increased crop productivity and reduce the total amount of pesticides needed. These partnerships should focus on precision application methods, including targeted drone applications, computer-assisted targeted spray technology, robotic monitoring, and related innovations." The Strategy further states that "USDA and EPA will promote and incentivize farming solutions in partnership with the private sector that focus on soil health and stewardship of the land."
Commentary
This final version of the MAHA Strategy is different in tone than the Assessment released in May. The text is more in keeping with "Presidential Task Force" and general policy announcements of past administrations. It lists a number of priorities and directives with only short summaries of the problem and how new actions and initiatives will address the identified issues. The Assessment was more intense in tone and similar to critiques of the modern food production and medical establishment institutions by advocacy groups whose leaders are now in leadership appointments at HHS (including Secretary Kennedy).
For example, the Assessment repeatedly mentions "corporate capture" of federal agencies and regulatory decision-making, along with an extremely dismal description of current public health policies, food production methods, and medical practices, which lead to a dangerously unhealthy diet for an overmedicated and manipulated public. Many elements of this intense critique remain in the Strategy but are often softened in tone or more obliquely embedded by the list of actions and recommendations. For example, the phrase "ultra-processed" — referring to the modern food production system and ingredients — appears more than 30 times in the May Assessment, and only twice in the September Strategy.
Regarding chemicals and pesticides, which were subject to a more negative depiction in the Assessment (especially in the cited research studies), this final Strategy does not mention any pesticides by name. In fact, the section entitled "EPA Process Improvements" cites the need to "reform the approval process" for pesticides to "increase the timely availability of more innovative growing solutions for farmers." Later, there is an explicit mention of EPA's Office of Chemical Safety and Pollution Prevention (OCSPP) using "increased scientific capacity from new hires" as part of "Agency Restructuring" to help improve processing applications.
One broad recommendation that EPA, USDA, and NIH will develop — "a research and evaluation framework for cumulative exposure across chemical classes" — may lead to new issues of concern regarding chemicals and pesticides. The specific directive — "EPA will focus on pesticides acting through a common mode of action" — includes what will be done "consistent with the statutory obligations" of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Food Quality Protection Act (FQPA). This added proviso is a bit curious since EPA has long-standing requirements to evaluate "cumulative" risks of pesticides as part of registration review, so it is unclear if this directive will lead to new and different policies or simply a restatement of current practices and procedures.
Generally, the tone of the final Strategy softens many of the sharp points made in the May Assessment, but the final recommendations and initiatives announced in the Strategy can be explained as covering most, if not all, of the MAHA agenda covered in the Assessment. It is unlikely to please all critics of the modern food safety, food production, pharmaceutical, and medical establishments; critics will have to decide whether to press their agenda as part of the initiatives outlined in the current Strategy or press for more fundamental changes.
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.
