MAHA’s Manifesto: UPFs, Food Dyes To Blame For Chronic Disease

The Make American Healthy Again (MAHA) Commission released its highly-anticipated, 68-page report outlining “four major drivers” it believes to be the root causes of rising rates of chronic diseases in children, including the prevalence of ultraprocessed foods (UPFs), synthetic food dyes and environmental toxins such as PFAS, microplastics and pesticides, among other factors, in the food system.

“Rising rates of childhood chronic disease are likely being driven by a combination of factors, including the food children are eating, the chemicals they are exposed to, the medications the are taking, and various changes to their lifestyle and behavior, particularly those related to physical activity, sleep and the use of technology,” the report begins.

The Commission was formed via an executive order when Health and Human Services (HHS) Secretary Robert F. Kennedy Jr. was sworn into his post in February. Commission participants also include USDA Secretary Brooke Rollins, Assistant to the President on Domestic Policy Vincent Haley, Secretary of Urban Housing and Development Scott Turner, and EPA administrator Lee Zelden, among others.

Here are our key takeaways about what was said in relation to the consumer packaged food industry.

Ultraprocessed Foods: The report first took aim at the dominance of UPFs within the U.S. food system. On multiple occasions, it cited that 70% of the food industry is made up of UPFs. At some points, the report claims 70% of U.S. children’s daily caloric intake comes from UPFs while at other times it claims the figure is 50%.

UPFs are an issue, it says, because they have led to “a depletion of micronutrients and dietary fiber” while increasing sugar and carbohydrate consumption. The prevalence of ultraprocessed grains, ultraprocessed sugar (identified as high-fructose corn syrup) and ultraprocessed fats (identified as refined seed oils) were named as the root cause of this nutrient depletion in our food system. Notably, excessive sodium consumption was not identified as a prominent feature of UPFs.

The report goes on to outline why the Commission believes UPFs have also led to increased caloric intake and a reduced consumption of whole foods such as fruits and vegetables. Additionally, it states that preliminary evidence suggests a possible link between the consumption of synthetic food colorings and the development of autism in children, but noted additional research is needed to establish a “definitive link.”

Titanium dioxide was identified as potentially causing “cellular and DNA damage,” and artificial sweeteners, such as aspartame, sucralose, and saccharin, were said to possibly disrupt the gut microbiome.

As it has previously done, Kennedy’s cohort also criticized the Dietary Guidelines of America (DGA), claiming that it “maintains problematic reductionist recommendations” when it comes to macronutrients such as saturated fats and sodium rather than instructing the public to minimize UPF intake. The report also criticized the “technical language [of the guidelines] that can be difficult for the average person to understand” and took issue that DGA does not distinguish between “nutrient-dense foods and ultra-processed products” when making recommendations.

Environmental Toxins: Beyond UPFs, the MAHA Commission also took aim at environmental toxins including fluoride, pesticides, microplastics and PFAS. It said the latter three of those toxins have been found in the blood and urine of “American children and pregnant women… some at alarming levels.”

But overall, this part of the report focused on the “cumulative load of multiple exposures” and the limited research this combination of chronic exposure has on health outcomes. The report stated that the National Institute of Health, as well as the private sector, needs to conduct additional research to better understand the impact.

However, that statement was quickly followed by criticism of the use of “crop protection tools,” commonly known as pesticides, insecticides and herbicides, pointing specifically at glyphosate, which it said has been known to cause reproductive and developmental disorders, in addition to “cancers, liver inflammation and metabolic disturbances.”

“The U.S. government is committed to fostering radical transparency and gold-standard science to better understand the potential cumulative impacts of environmental exposures,” the report reads. “We must understand and ameliorate any potential links between cumulative chemical exposure and childhood chronic disease. This cannot happen through a European regulatory system that stifles growth.”

Corporate Consolidation And Conflict: Kennedy has long criticized corporate influence on nutrition programs and other areas of public health. A lack of federally-funded “gold-standard science” is part of the problem, the report states, noting that only between 4% to 5% of the NIH’s budget goes to nutrition research. The critique arrives as the Trump Administration has cut $1.8 billion in NIH grant funding.

Corporate consolidation in the food industry is also to blame for poor health and the prominence of UPFs, the Commission said, since a “small number of corporations control a large share of food production, processing, distribution, and retail” and many of the products sold by “Big Food” could be considered UPF.

The report highlighted lobbyists’ role in nutrition research and food marketing, claiming that the “chemical manufacturing industry” spent about $77 million in 2024 on federal lobbying activities while 60% of those individuals held “federal posts.” It also acknowledged a study that found children are exposed to 15 food ads per day and said more than 90% of those promotions are for products high in fat, sugar and sodium.

The Commission also said conflicts of interest at the DGA are to blame for the poor health of children, noting that these guidelines influence the Supplemental Nutrition Assistance Program (SNAP) and national school lunch program requirements.

What’s Next?

The publication of today’s report happened to come the same day the Republican-controlled House of Representatives passed a sweeping tax bill that will, in part, eliminate programs that supported schools in purchasing locally sourced produce for lunch programs and decimate funding and nutrition education programs for SNAP recipients. That bill still needs to pass a Senate vote.

The MAHA Caucus, led by Senator Roger Marshall (R-KS) as well as congressman Vern Buchanan (R – FL), John Joyce (R – PA) and Lloyd Smucker (R -PA) will now study the report’s findings and work to develop a roadmap for action and implementation of key priorities, said Marshall’s legislative assistant Lacy Pitts at IFT’s Food Policy Impact 2025 meeting in April. Pitts acknowledged that the caucus would work independently of the commission.

According to HHS, over the next 82 days the commission will produce a follow up, stratgy-focused report known as the Make Our Children Healthy Again Strategy outlining its action plan to address these issues.  It also appears the Commission is interested in applying AI tools to evaluate environmental exposure and track chronic disease cases in children, but limited details were provided on what that would look like.

“Real transformation requires more than vision – it requires clarity,” the report states. “Before we act, we must fully understand the scope of the crisis, the conditions that created it, and the mechanisms through which it continues to grow. Without this foundation, interventions risk being reactive, fragmented, or ineffective.”