In follow-up to the initial MAHA Report published in May, the HHS has published a 20-page, 120-initiative MAHA Strategy paper “narrowly” focused on nutrition and metabolic health, food quality, cumulative exposures, microbiome, precision agriculture, and mental health, that Robert F Kennedy Jr. said are being done “very, very quickly.”
Just how quick that will be is yet to be seen as it’s difficult enough to complete 120 strategies, but with the paper having very little meat or details on how each is to be achieved or regulated, there is still an awful lot of pre-work to do. This is particularly true given that many of the initiatives focus on conducting research rather than taking action, though this shouldn’t be surprising given that the first approach listed in the document for ending childhood chronic disease is “advance research.” But assuming that that will eventually lead to action, let’s take a look at the initiatives that are focused on the food industry.
Among these are ultra-processed foods, GRAS, artificial colors, nutrition labeling, and updating the Dietary Guidelines for Americans. And, once again, realignment within HHS is discussed calling for a new Administration for Healthy America.
- Ultra-processed foods (UPF). With only a single sentence on UPFs, it seems that attention has devolved to working on a definition “to support potential future research and policy activity.” However, the agency’s stated intention to update the 2025 Dietary Guidelines for Americans (DGAs) does plan to prioritize whole foods (i.e., protein foods, fruits, and vegetables) and minimize highly processed foods and added sugar.
- Nutrition Labeling. The new DGAs will also be combined with comments received on FDA’s proposed rule on Front-of-Package Nutrition Labeling to inform a final rule that increases transparency for consumers.
- GRAS continues to hold the agency’s attention, with FDA updating regulations to reform GRAS to discontinue self-affirmed GRAS, closing what has been termed the “GRAS loophole,” and implementing a mandatory GRAS notification program, and increasing consumer transparency with respect to substances found in our nation’s food supply.
- Artificial colors. This focuses on continuing FDA plans to limit or ban the use of petroleum-based food dyes (FD&C certified colors) in all food products approved in the U.S. To help move this forward, USDA and HHS will develop research and policies for production of plants used as natural colors, and FDA will expedite review and approval of naturally sourced color additive petitions.
- Administration for Healthy America (AHA). The strategy paper also references the AHA restructuring plan, which was announced in May, as combining five current agencies into one to conduct high-quality nutrition research and ingredient assessments, with an ultimate goal of developing more targeted nutritional recommendations.
- Pesticides. While there was some expectation that the Administration would come down harder on pesticide residues, the strategy instead focuses on ensuring public “awareness and confidence in EPA’s pesticide robust review procedures” and continuing to invest in new approaches and technologies for more targeted and precise pesticide applications.
It feels as if the pre-election push to improve America’s health is struggling to make significant headway. While we have a movement in California to ban ultra-processed foods in school lunches, which is likely to run into a challenge given the lack of definition, MAHA is starting with the basic need to define UPF. But that will take time and require some real thinking around the impact on both health and affordable food. Other aspects, such as colors, have made traction, not through regulation but through the industry making voluntary changes. GRAS changes are likely one of the biggest impacts on industry and this space needs very close monitoring. At the very least, check to see what you are using that was self-affirmed, and be ready to make changes.
Given this limited agenda for change, and the number of strategies being “continued,” fulfilling the strategy may not be that difficult after all. Moving forward with actions to presumably be derived from those strategies is another story. But the paper does provide industry with continuing information on the thinking of the current administration and some areas on which to focus in order to be proactive and stay ahead of potential rules.
