On September 9, 2025,the U.S. Department of Health and Human Services (HHS) announced the release of the Make Our Children Healthy Again Strategy (MAHA Strategy) issued by the Make America Healthy Again (MAHA) Commission. This Strategy was required to be submitted to the President by August 12, 2025, based on the findings of the Commission in its Making Our Children Healthy Again report (MAHA Assessment), which was released on May 22, 2025, and is discussed in our blog.

In its press release announcing the Strategy’s release, HHS describes the MAHA Strategy as a “sweeping plan with more than 120 initiatives to reverse the failed policies that fueled America’s childhood chronic disease epidemic.” HHS states that the MAHA Strategy outlines “targeted executive actions to advance gold-standard science, realign incentives, increase public awareness, and strengthen private-sector collaboration.”

In the MAHA Strategy, the Commission identifies four potential issues it believes is behind the rise in childhood chronic diseases — poor diet, chemical exposure, lack of physical activity and chronic stress, and overmedicalization. The MAHA Strategy discusses the following five key focus areas to address childhood chronic diseases:

• Advancing Critical Research to Drive Innovation: The MAHA Strategy states the National Institutes of Health (NIH) will expand research into chronic disease prevention, which includes focusing on nutrition and metabolic health, food quality, environmental exposures, autism, gut microbiome, precision agriculture, rural and tribal health, vaccine injury, and mental health. Specifically, regarding pesticides, the MAHA Strategy states NIH, the U.S. Food and Drug Administration (FDA), and the U.S. Environmental Protection Agency (EPA) will expand the use of New Approach Methodologies (NAM) to allow earlier insight into chronic disease mechanisms using human-relevant models, such as organoids, computational simulations, and real-world data integration. This is intended to develop a research and evaluation framework for cumulative exposures across chemical classes with the assistance of EPA research using NAMs to improve methods for evaluating human health and environmental risks of chemical contaminations, with a focus on pesticides acting through a common mode of action. Additionally, the MAHA Strategy states that the U.S. Department of Agriculture (USDA) and EPA will prioritize research programs to assist growers adopt precision agricultural techniques to decrease pesticide volumes. Other initiatives include but are not limited to evaluations of water quality and air quality for their impact on children and an evaluation of the risks and exposures of microplastics and synthetics, including in common products such as textiles.

   

• Realigning Incentives and Systems to Drive Health Outcomes Research to Drive Innovation: The MAHA Strategy sets forth short descriptions of numerous “policy reforms” that HHS and other agencies will pursue. For example, the MAHA Strategy states USDA and HHS will reform the 2025-2030 Dietary Guidelines for Americans to align with science, data, and health recommendations in a “user-friendly” format; HHS will coordinate with USDA and FDA to define ultra-processed foods; FDA will improve food labeling by revising its proposed Front-of-Pack nutrition information rulemaking; FDA will close the “Generally Recognized as Safe” (GRAS) loophole by implementing a mandatory GRAS notification program; and FDA will remove harmful chemicals from the food supply by developing and implementing an evidence-based systematic process for post-market assessment of chemicals in food, including chemicals present as unintentional contaminants. The Strategy also states that the “[Centers for Disease Control and Prevention (CDC)], informed by data and scientific review from NIH and EPA, will update recommendations regarding fluoride and PFAS in water.”

   

• Process Efficiencies and Deregulation: The MAHA Strategy states USDA will streamline organic certification processes to encourage small farms to transition to organic practices and reduce regulatory compliance burdens for small farms. Under the title of “EPA Process Improvements,” the Strategy states EPA will take the following actions:

   

  • Work to reform the approval process for the full range of chemical and biologic products to protect against weeds, pests, and disease to increase the timely availability of more innovative growing solutions for farmers.

     

  • Consider increased categorical exclusions under the National Environmental Policy Act for low volume meat processing operations from water discharge and hazardous waste permitting, and work with states to fast-track approvals to strengthen regional meat infrastructure and improve access to fresh protein in schools and communities.

     

  • Ensure flexibility for farms to manage manure and process water without triggering industrial-grade permitting requirements and avoiding the forced mandates of costly technologies or practices that do not consider geography, weather, species, and operation size.

     

  • More clearly define post-harvest rinse and wash water as non-hazardous under the Resource Conservation and Recovery Act to relieve fruit/vegetable packers and producer handlers — especially smaller operations — of unnecessary wastewater treatment burdens.
• Increasing Public Awareness and Knowledge: Among the initiatives described, the MAHA Strategy states EPA will partner with food and agricultural stakeholders to ensure awareness and confidence in EPA’s review of pesticides and how it relates to limiting the risks for users and the general public. 
• Fostering Private Sector Collaboration: The MAHA Strategy states “USDA and EPA will launch a partnership with private-sector innovators to ensure continued investment in new approaches and technologies to allow even more targeted and precise pesticide applications. This can support increased crop productivity and reduce the total amount of pesticides needed. These partnerships should focus on precision application methods, including targeted drone applications, computer-assisted targeted spray technology, robotic monitoring, and related innovations.” The Strategy further states that “USDA and EPA will promote and incentivize farming solutions in partnership with the private sector that focus on soil health and stewardship of the land.”

Commentary

This final version of the MAHA Strategy is different in tone than the Assessment released in May. The text is more in keeping with “Presidential Task Force” and general policy announcements of past administrations. It lists a number of priorities and directives with only short summaries of the problem and how new actions and initiatives will address the identified issues. The Assessment was more intense in tone and similar to critiques of the modern food production and medical establishment institutions by advocacy groups whose leaders are now in leadership appointments at HHS (including Secretary Kennedy).

For example, the Assessment repeatedly mentions “corporate capture” of federal agencies and regulatory decision-making, along with an extremely dismal description of current public health policies, food production methods, and medical practices, which lead to a dangerously unhealthy diet for an overmedicated and manipulated public. Many elements of this intense critique remain in the Strategy but are often softened in tone or more obliquely embedded by the list of actions and recommendations. For example, the phrase “ultra-processed” — referring to the modern food production system and ingredients — appears more than 30 times in the May Assessment, and only twice in the September Strategy.

Regarding chemicals and pesticides, which were subject to a more negative depiction in the Assessment (especially in the cited research studies), this final Strategy does not mention any pesticides by name. In fact, the section entitled “EPA Process Improvements” cites the need to “reform the approval process” for pesticides to “increase the timely availability of more innovative growing solutions for farmers.” Later, there is an explicit mention of EPA’s Office of Chemical Safety and Pollution Prevention (OCSPP) using “increased scientific capacity from new hires” as part of “Agency Restructuring” to help improve processing applications.

One broad recommendation that EPA, USDA, and NIH will develop — “a research and evaluation framework for cumulative exposure across chemical classes” — may lead to new issues of concern regarding chemicals and pesticides. The specific directive — “EPA will focus on pesticides acting through a common mode of action” — includes what will be done “consistent with the statutory obligations” of FIFRA and the Food Quality Protection Act (FQPA). This added proviso is a bit curious since EPA has long-standing requirements to evaluate “cumulative” risks of pesticides as part of registration review, so it is unclear if this directive will lead to new and different policies or simply a restatement of current practices and procedures.

Generally, the tone of the final Strategy softens many of the sharp points made in the May Assessment, but the final recommendations and initiatives announced in the Strategy can be explained as covering most, if not all, of the MAHA agenda covered in the Assessment. It is unlikely to please all critics of the modern food safety, food production, pharmaceutical, and medical establishments; critics will have to decide whether to press their agenda as part of the initiatives outlined in the current Strategy or press for more fundamental changes.