On May 22, 2025, the Make America Healthy Again (MAHA) Commission, chaired by US Secretary of Health and Human Services Robert F Kennedy Jr., delivered the Make Our Children Healthy Again Assessment (MAHA report). The Executive Order-mandated report probes the rising “childhood chronic disease crisis” in the United States and its possible causes.
In the week since publication, an independent investigation by NOTUS found the MAHA report contained multiple citations that do not exist, and statistics unsupported by the scientific literature. Following the investigations, updates to remove several citations and problematic assertions have been made to the Assessment. This article relies on the version of the MAHA report posted online as of May 30, 2025, and all quoted passages were cross-checked against their references.
According to the Centers for Disease Control (CDC), more than 40 percent of the nation’s 73 million children live with at least one chronic condition, including asthma, obesity, autoimmune disorders, or behavioral challenges. The Assessment largely attributes the increased rates of childhood diseases on food, environmental chemicals, technology, and increasing pharmaceutical use. Each cause is covered in a section of the Assessment.
This news article focuses on the assertions made in the MAHA report concerning ultraprocessed foods (UPFs) and exposure to environmental chemicals.
Ultra-processed foods
Ultra-processed foods (UPFs) have been associated with negative health outcomes in children and other populations (FPF reported). The MAHA Commission attributes these harms to nutrient depletion, increased caloric intake, and the inclusion of food additives. It notes that “[o]ver 2,500 food additives […] may be used to mimic the taste and texture of conventional food and increase its shelf life [in the US]. Studies have linked certain food additives to increased risks of mental disorders, ADHD, cardiovascular disease, metabolic syndromes and even carcinogenic effects” (FPF reported). The Assessment source for the “over 2500 food additives” is from the year 1983, and the current US Food and Drug Administration inventory lists over 3900 direct food additives.
The MAHA report argues that food system consolidation, marketing, corporate interests, and even government support programs have contributed to UPFs becoming a larger share of the American diet since World War II.
Environmental chemicals
In the introduction of the section on cumulative load of chemicals in our environment, the Assessment states: “[n]o country in the world has fully accounted for the fact that children are often exposed to complex mixtures of chemicals.” The MAHA Commission outlines how children and adolescents are particularly vulnerable to environmental chemical exposure owing to sensitive developmental windows, an immature immune system, adolescent brain remodeling, and endocrine disruption.
Beyond their heightened sensitivity, children encounter chemicals through distinctive routes including breastmilk (FPF reported), ingesting household dust, and frequent hand-to-mouth behavior, among others. “A limited review of the epidemiological and clinical studies of several environmental exposures reveals that certain studies, though findings vary, show these exposures, including when combined, may affect children’s health.”
The MAHA report highlights PFAS, microplastics, fluoride, electromagnetic radiation, phthalates, bisphenols, and crop protection tools (pesticides, herbicides, etc.). It warns that manufacturer-funded studies dominate the evidence base, with “[l]imited comparisons between industry-funded research versus non-industry studies” creating a potential bias. To illustrate, they cite research from vom Saal and Hughes of 115 bisphenol A (80-05-7, BPA) studies published before 2005 showing that “100% of chemical industry-funded studies declared BPA safe, while over 90% of non-industry research identified harm at low doses.” In 2023, the European Food Safety Authority lowered the tolerable daily intake for BPA to 0.2 ng/kg bw/d (FPF reported), 25,000 times below what FDA considers safe.
Next steps
The purpose of the MAHA Assessment is to compile evidence behind declining childhood health trends in America. Within two months, the MAHA Commission is required to submit to the President a strategy to begin addressing the issues identified. The Assessment already outlines a few recommendations including addressing the replication crisis that highlights the need for scientific studies to be duplicated to confirm the validity of their findings, post-market surveillance (FPF reported), GRAS reform (FPF reported), applying alternative testing models (i.e., New Approach Methodologies, FPF reported), and using ‘precision toxicology’ to map gene-environment interactions affecting childhood disease risk.
Considering the available science, FPF concurs with the report’s emphasis on better addressing chemical mixtures (FPF reported, also here), which is also a problem in Europe and elsewhere (FPF reported). In addition to not sufficiently considering mixtures, the current US regulatory framework also does not consider multiple endpoints associated with non-communicable diseases relevant to human health, such as cardiovascular diseases, brain-related disorders, metabolic and endocrine diseases, as well as immunological and reproductive disorders, and cancers. A framework approach to consider the impacts of chemicals on chronic diseases has been proposed (FPF reported) and FPF has recently submitted comments in response to FDA’s public consultation on post-market assessment of FCMs (FPF reported).
The MAHA report singles out bisphenols, particularly BPA. Despite mounting evidence of harm, BPA remains permitted in U.S. food-contact applications at a reference dose 25,000-fold higher than the current European Union limit. The FDA’s Food Contact Substance (FCS) notification database also withholds the studies underlying its safety decisions. Publishing those data and related correspondence would allow independent review and advance the MAHA Commission’s transparency goals.
Research published by Food Packaging Forum scientists and others outline possible directions these initiatives could take, particularly regarding food contact materials and chemicals.
Some points had been previously articulated in reports on FDA reform published by the US Government Accountability Office (FPF reported) and the independent Reagan-Udall Foundation (FPF reported) in 2022.
The Food Packaging Forum has developed a set of science-based insights the US administration could consider as it develops a strategy.
Read more
Make America Healthy Again Commission (May 2025). “Make our children healthy again assessment.”
Emily Kennard and Margaret Manto (May 29, 2025). “The MAHA report cites studies that don’t exist.” NOTUS
Sareen Habeshian (May 29, 2025). “White House moves to fix errors in MAHA commission report.” Axios
Food Packaging Forum (June 4, 2024). “Addressing the chemical safety of food contact materials (FCMs) in the US: Science-based insights for policymaking.”
