Back in May, when the MAHA Commission released its assessment report indicting “ultra-processed foods” as one of the key “driving forces behind American children’s food crisis,” longtime advocates for food system reform wondered, what’s next? Of course, calling out a problem requires much less work than actually solving it. But even so, the early report’s focus on the litany of harms attributable to Americans’ ultra-processed diets manifested an intention to break definitively with the status quo.
Now we have the (leaked) MAHA Strategy report. This is the report that is supposed to outline the policies to fix the food system’s problems identified in the first report, although to judge from its tepid language, the food system may not need so much fixing after all. It manifests the intention: “let’s not rock the boat.” As food policy maven Marion Nestle notes, the report is full of “waffle words: explore, coordinate, partner, prioritize, develop, or work toward.” In case the embrace of voluntary industry action on food dyes did not make it clear, this Administration has little interest in regulating.
THE GOOD
A favorite industry talking point paints the concept of “ultra-processed food” as hopelessly ambiguous, despite broad consistency among researchers studying the links between UPFs and disease. So establishing a formal government definition of UPFs seems like a good idea, albeit a very modest proposal. In the earlier MAHA Assessment report, the word “ultra-processed food” appears 44 times. The word “ultra-processed food” appears just once in the 18-page MAHA Strategy report, in reference to the budding rulemaking process that will (eventually) define the term. “Who expected the MAHA report to do more to get whole milk in schools than to get UPF out,” former food regulator Jerold Mande told StatNews. True, but defining UPFs at least takes a step in the right direction.
Another “good” aspect of the strategy report is its commitment to “GRAS reform.” FDA should never have allowed companies to secretly self-certify food additives’ safety. Ideally comprehensive GRAS reform, along with a robust post-market review of chemical additives in food, and evaluation of cumulative chemical exposures—both referenced in the strategy report—will lead to meaningful protections for consumers. But even if the Administration does nothing more than require industry to disclose to FDA when a company has determined that an ingredient is “generally recognized as safe,” the added transparency will be welcome.
Finally, the Strategy report promises action, however vague, to “limit the direct marketing of certain unhealthy foods to children, including by evaluating the use of misleading claims and imagery.” Countries around the world—Canada, Norway, Germany, France, Spain, Portugal, Mexico, Chile, Argentina, Australia—have passed laws to limit, if not outright ban, food marketing to children. Similar policies are long overdue in the U.S. to protect kids from corporate junk food peddlers like Coca-Cola and McDonald’s, which have invested in establishing in-house digital marketing teams to surveil and manipulate kids into buying their products. Will this Administration pursue any policies to actually limit food advertising to kids? Not likely. But at least it has acknowledged the problem.
THE BAD
Popular reaction to the MAHA Strategy report has not been kind. This has a lot to do with what the report does NOT do: i.e. commit to any meaningful regulation of the food system. But the Administration deserves special scorn for its repeated calls for more research. The word “research” appears 54 times in the document. The report would have us believe that the Administration is going to “advance research” through NIH, FDA, USDA, and even, God help us, the EPA. Fool me once MAHA, shame on you. Fool me twice, shame on me for forgetting about the thousands of fired federal workers and billions of dollars of canceled and frozen research grants and contracts, including ones targeting chronic disease, like an ongoing 30-year, nationwide study tracking patients with prediabetes and diabetes.
The call for research also obscures the fact that we understand all too well why kids in the U.S. have such a low life expectancy compared to their peers in other rich countries. For example, the Strategy report mentions “healthcare” four times, but says nothing about the obscene fact that 5.8% of kids in the U.S.—4.4 million of them—do not have health insurance, according to the latest estimates. That number is poised to rise dramatically with the Big, Beautiful Act’s $1.02 trillion cuts to Medicaid and Children’s Health Insurance Program, which cover more than 40% of the nation’s children under six. With the Administration celebrating policies that will so obviously shorten millions of children’s lives, the calls for more research into alternative, less significant harms ring hollow, and lend credence to popular influencer claims that the MAHA movement is nothing but a “trojan horse,” or in the words of comedian John Oliver, “laundering the reputation of an administration that is doing the exact opposite.”
THE UGLY
The French philosopher Francois Duc De La Rochefoucauld famously called hypocrisy the “tribute that vice pays to virtue.” Even if the Administration seems unlikely to usher in an age of “gold-standard scientific research to help ensure informed decisions that promote healthy outcomes for American children and families,” most of us agree that the idea seems nice.
Not so much with other items in the MAHA Strategy Report. Remember the debacle that unfolded in Trump’s first term with the Farmers to Families Food Box program? Soon we may have “MAHA boxes” that “get whole, healthy food to SNAP participants.” Or at least, to the ones whose benefits have not been cut (sorry parents of 14-year-olds who can’t document at least 20 hours of work per week!). The MAHA Strategy report also takes aim at “vaccine injuries,” making all the more conspicuous its omission of gun injuries, which kill “more children and teens, ages 1 to 17, than any other cause, including car crashes and cancer.”
But let’s stick to food. One final, somewhat cryptic, item in the MAHA Strategy report deserves mention. Under the category of “food deregulation,” the report recommends policies to “Remove barriers preventing small dairy operations from processing and selling their own milk products locally.” This could refer to any number of innocuous and possibly even effective policies to counteract the very real and concerning corporate consolidation trend in the dairy sector. But Secretary Kennedy’s very public affinity for raw milk opens the door to more ominous interpretations. Should “removing barriers” extend to longstanding prohibitions on interstate sales of raw milk, infant mortality rates driven down by widespread adoption of milk pasteurization could come roaring back.
No one wants to defend the status quo in the food system. Almost everyone has struggled with their weight or diet-related disease or has a loved one who has. Parents especially should not have to dedicate so much time and energy to keeping an obesogenic environment at bay. But this latest report offers yet more evidence that food system reformers should not expect this Trump Administration to fix the food system any more than the first one did. More likely, its going to leave it a lot worse.