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The Make America Healthy Again (MAHA) Commission has this week unveiled the new Make Our Children Healthy Again Strategy – a plan aiming to tackle chronic disease in American children.

The MAHA Commission, chaired by US Health and Human Services secretary Robert F. Kennedy Jr, was established with ambitions to address the root causes of the escalating health crisis in the US.

The Commission is focusing heavily on dietary reform and the implementation of numerous major initiatives intended to improve public health, with secretary Kennedy having already been pushing for a number of changes – such as the removal of artificial dyes from food and beverage products – during his term.

Its latest strategy report, published on 9 September 2025, outlines more than 120 actions aiming to ‘advance science, realign incentives, increase public awareness and strengthen cross-sector collaboration’.

With several of the key initiatives focusing on dietary health, the food and beverage industry is set to be significantly impacted by these proposals, which Kennedy said will “realign” the food system.

Key focus points for the food industry

GRAS reform

The Commission has proposed a significant overhaul of the current Generally Recognized as Safe (GRAS) approval process for food and beverage ingredients.

The GRAS system was first introduced by the Food and Drug Administration (FDA) in 1958 and was made voluntary in 1997. Manufacturers are encouraged to submit a GRAS notice to the FDA, providing an analysis of the substance, its properties and the necessary supporting information to determine its safety in food applications. The FDA will then review this and issue a ‘no questions letter’ to the company if it has no concerns.

However, manufacturers can currently self-affirm their ingredient as GRAS without notifying the Food and Drug Administration. Kennedy has referred to this as a “loophole,” and is now planning to implement a mandatory GRAS notification programme with the FDA.

The report states that this move will increase consumer transparency with respect to substances found in the nation’s food supply. While Kennedy first called on the FDA to review the rules back in March, the proposed changes have now been added to the FDA’s spring 2026 Unified Agenda for planning and consultation.

The change will not impact ingredients that are already determined as GRAS. But for food-tech companies bringing novel ingredients to market that have not yet been affirmed, such as ingredients made using advanced fermentation methods, the reform would lengthen the regulatory approval process and result in significant delays for companies working toward launching their products/ingredients to market.

Defining UPFs

The report touches on plans to develop a US government-wide definition for ‘ultra-processed foods’ (UPFs), aiming to improve clarity and support future research and policy activity.

It highlights research suggesting that over 60% of children’s calories now come from highly processed foods in the US, which have been associated with a range of chronic health conditions including diabetes and obesity.

While discussion around UPFs has been ramping up in recent years, there is currently no universally accepted definition of what this means and which foods fall into this category – though they are commonly defined by the Nova system, a framework developed by researchers in Brazil.

Generally, UPFs are recognised to be pre-packaged foods that have undergone various industrial processing methods and often contain synthetic additives, as well as high levels of salt, sugar and saturated fat.

Food dyes

The Commission said the FDA will work to continuously advance policies that limit or prohibit the use of petroleum-based food dues (FD&C certified colours) across all US food products.

Kennedy has been increasingly calling on companies to eliminate artificial colours from their products, with several food giants including Hershey, Nestlé and JM Smucker having already announced commitments to phase out the dyes.

Last month, Kellogg’s became the first food company to sign a legally binding agreement regarding the removal of all synthetic dyes from its cereals by the end of 2027. This followed an investigation launched by Texas attorney general Ken Paxton earlier in the year after Kellogg’s claimed it would remove petroleum-based colourings in the US, but did not do so.

More food and beverage manufacturers are likely to make similar commitments as situation continues to unfold, with regulatory pressures mounting and consumers becoming increasingly concerned about health effects linked to certain artificial colourants, including behavioural issues in children and even potential carcinogenic effects.

The MAHA strategy noted that the US Department of Agriculture (USDA) and the Department of Health and Human Services will work to develop research and policies that support domestic agriculture production of plants used as natural colour sources.

Nutrition labelling

The FDA will consider revisions to its proposed front-of-pack nutrition information labelling rule changes based on input received during the comment period, and is working toward development of a final rule.

Proposed in January 2025, the changes would require front-of-pack nutrition labels on packaged foods sold in the US, prominently displaying the product’s saturated fat, sodium and added sugar levels.

Named the Nutrition Info Box, the initiative aims to give consumers readily visible information about a food’s nutritional profile in order to encourage healthier food choices.

Food manufacturers would be required to add a ‘Nutrition Info’ box to the front of most packaged food products, three years after the final rule’s effective date for businesses with $10 million or more in annual food sales, and four years after the rule’s effective date for businesses with less than $10 million in annual food sales.

Infant formula

The strategy has pledged to modernise nutrient requirements for infant formula and increasing testing for heavy metals and other contaminants, aiming to ensure access to high-quality formula products in the US.

The FDA is encouraging companies to develop new infant formula products while working on opportunities to help inform consumers about formula ingredients.

Kennedy said that the agency will “use all resources and authorities at its disposal to make sure infant formula products are safe and wholesome for the families and children who rely on them,” aiming to bolster the resilience of the domestic formula supply while ensuring safety and nutritional adequacy.

Dairy and agriculture deregulation

The Commission plans to undertake several actions that aim to ‘eliminate outdated or unnecessary regulations’ and ‘cut red tape’.

Among these is a plan to remove restrictions on whole milk sales in schools, enabling districts to offer full-fat dairy options alongside reduced fat alternatives.

Whole and 2% milk has been banned in US schools for more than a decade, an initiative implemented by the Obama administration amid efforts to reduce childhood obesity by providing low-fat alternatives.

The Whole Milk for Healthy Kids Act would eliminate these restrictions and could increase dairy uptake in schools if signed into law.

The Commission also pledges to ‘remove barriers’ preventing small dairy operations from processing and selling their own products locally, though it does not expand on specific actions to be taken.

Kennedy has previously been vocal about his advocacy of raw milk, believing it to offer health benefits despite safety risks posed by potential contamination with bacteria that would otherwise be killed during pasteurisation.

The MAHA strategy also mentions plans to streamline organic certification processes and reduce costs for small farms transitioning to organic practices.

Precision agriculture, pesticides and soil health

The report affirms the government's current pesticide review procedures through the Environmental Protection Agency (EPA), which it describes as 'robust'.

However, it promises continued investment through a partnership between USDA, EPA and private sector businesses to allow more targeted and precise pesticide applications to support increased crop productivity and reduce the total amount of pesticides needed.

These will focus on precision application methods including targeted drone applications, computer-assisted targeted spray technology, robotic monitoring and related innovations.

The strategy also pledges to incentivise farming solutions in partnership with the private sector that focus on soil health and stewardship of the land. This includes providing growers with new tools to better enable soil health practices and prioritising the 'acres of shovel-ready conservation projects already planned by farmers'.

Industry reaction

The report has drawn mixed reactions from industry and in the media, with some criticising its vague nature and calling for expansion on the action points outlined in the strategy.

Marion Nestle, Paulette Goddard professor of nutrition, food studies, and public health emerita at New York University, commented on the strategy: "The report has a lot of ideas for actions that really could improve health, but is short on specifics and weak on regulatory action".

"It dropped any mention of reducing sugar and salt in processed foods...What’s still missing is regulation. So much of this is voluntary, work with, promote, partner."

Sarah Starman, senior food and agriculture campaigner at Friends of the Earth, described it as a "slap in the face to millions of Americans," criticising its lack of focus on organic farming initiatives and reduction of pesticide use.

She commented: "Laughably, the report calls the EPA’s lax, flawed and notoriously industry-friendly pesticide regulation process ‘robust.’ This, in spite of the fact that EPA currently allows more than 1 billion pounds of pesticide use on US crops each year, including the use of 85 pesticides that are banned in other countries because of the serious risks they pose to human health and the environment."

"The American public deserves better than hollow assurances. We deserve a plan that would actually fix the EPA’s broken processes, curb the influence of the chemical industry over the agency, and decrease our exposure to toxic pesticides."

Kenneth Hartman Jr, president of the National Corn Growers Association, said the strategy offers "a reasonable and science-based approach for achieving its objectives".

"We are encouraged that when the commission engaged with agricultural stakeholders and followed the science, it reaffirmed what we already know: EPA is the appropriate agency for regulating crop inputs," Hartman said.

"We are also delighted to see precision agriculture, soil health and land stewardship prioritised, as these are areas in which corn farmers have led the way for many years. We look forward to working with the administration and Congress as they turn to the implementation of the report."