On September 9, 2025, the White House released the Make Our Children Healthy Again (MAHA) Strategy, an inter-agency plan the U.S. Department of Health and Human Services (HHS) describes as “sweeping,” with more than 120 initiatives spanning food, health, education, and research. Actions related to food contact chemicals and materials include investigating new approach methodologies (NAMs, FPF reported), a focus on microplastics (FPF reported), GRAS reform (FPF reported), and removing harmful chemicals from the food supply (FPF reported). The plan also highlights expanded federal research on environmental exposures and cumulative risks (FPF reported, also here).
The Strategy is divided into four sections, (i) advance research, (ii) realign incentives, (iii) foster private sector collaboration, and (iv) increase public awareness. Sections (i) and (ii) contain actions related to food contact chemicals and materials.
Advance research
New Approach Methodologies (NAMs). According to the strategy, the Environmental Protection Agency (EPA), Food and Drug Administration (FDA), and National Institutes of Health (NIH) “have all committed to using NAMs moving forward, when appropriate.” Techniques such as organoid models, computational simulations, and the integration of real-world data could generate faster, more predictive insights into chronic disease mechanisms. The goal is to improve prevention, diagnosis, and personalized care while reducing reliance on animal studies “that often fail to replicate complex human conditions.”
Cumulative exposure. EPA, NIH, and the Department of Agriculture (USDA) will develop a government-wide research and evaluation framework for cumulative exposure across chemical classes. The work will emphasize NAMs and advanced computational tools. EPA will prioritize pesticides that act through a common mode of action.
Microplastics and synthetics. “HHS, in collaboration with NIH and EPA, will complete an evaluation of the risks and exposures of microplastics and synthetics, including in common products such as textiles.”
Realign incentives
Post market review of chemical additives in food. FDA will continue developing and implementing a systematic process for post-market assessment of chemicals present in food. The scope includes food additives, color additives, GRAS substances, substances used in contact with food, and unintentional contaminants (e.g., environmental contaminants) (FPF reported).
Ultra-processed foods. “USDA, HHS, and FDA will continue efforts to develop a U.S. government-wide definition for ‘ultra-processed food’ to support potential future research and policy activity” (FPF reported).
GRAS reform. FDA will update regulations to reform the GRAS [generally recognized as safe] designation, within the scope of statutory authority, by closing the “GRAS loophole,” implementing a mandatory GRAS notification program, and increasing consumer transparency with respect to substances found in the US food supply.
What’s next
This Strategy follows a report published in May 2025 by the MAHA Commission to compile evidence behind declining childhood health trends in America (FPF reported). While the actions outlined in the Strategy and earlier MAHA reports seem largely positive, following recent upheaval at US research organizations, implementation may be problematic. Civil society organizations including Earthjustice and the American Lung Association have been critical.
A comment period on the FDA protocol for post-market assessment of food contact substances closed mid-August 2025. The proposal and comments are currently undergoing external scientific review. FDA has not provided a timeline for issuing a response to comments or updated protocol. The HHS, FDA, and USDA request for information on ultra-processed foods is open until September 23, 2025.
Any consultations or requests for information related to food contact chemicals and materials will be shared via the Food Packaging Forum’s consultations page.
References
Make America Healthy Again (MAHA) Commission (September 9, 2025). “Make our children healthy again: Strategy report.” Whitehouse.gov (pdf)
U.S. HHS (Sept 9, 2025). “MAHA Commission Unveils Sweeping Strategy to Make Our Children Healthy Again.”
Read more
Meg Duff (September 11, 2025). “MAHA strategy ‘not a plan that will make America healthy again’, NGOs say.” Chemical Watch News & Insight.
Alejandro Davila (September 9, 2025). “Trump’s MAHA Commission Report Offers No Solutions, Leaves Kids Exposed to Toxics.” Earthjustice.
