WASHINGTON — Processed food companies and federal nutrition guidelines and programs could be in the crosshairs of President Donald Trump’s new Make America Healthy Again (MAHA) Commission, according to a report by investment firm TD Cowen.

Formed in an executive order on Feb. 13, the MAHA Commission will be chaired by newly appointed US Department of Health and Human Services (HHS) Secretary Robert F. Kennedy Jr. Other participants will include the commissioner of the Food and Drug Administration (FDA); the secretary of the US Department of Agriculture (USDA); the directors of the Centers for Disease Control and Prevention (CDC) and National Institutes of Health (NIH); and the administrator of the Environmental Protection Agency (EPA), among other cabinet secretaries and federal agency heads. Vince Haley, assistant to the president for domestic policy, will serve as executive director.

Plans call for the commission to reorient the nation’s health care strategy toward preventive care and wellness as a way to reduce the rise in chronic disease, with nutrition a key focus. The executive order cites the US diet, food production methods, food ingredients, medications and medical treatments as some of the “potential contributing causes” of chronic disease.

According to the order, the administration seeks a national health care system that “promotes health rather than just managing disease.” It spotlights statistics indicating that 6 in 10 Americans have at least one chronic disease and 4 in 10 have two or more, with 30% of adolescents deemed prediabetic and over 40% of teens considered overweight or obese.

“To fully address the growing health crisis in America, we must redirect our national focus, in the public and private sectors, toward understanding and drastically lowering chronic disease rates and ending childhood chronic disease,” the executive order said. “This includes fresh thinking on nutrition, physical activity, healthy lifestyles, overreliance on medication and treatments, the effects of new technological habits, environmental impacts, and food and drug quality and safety.”

Initially, the focus will be on childhood chronic disease. Within 100 days of the executive order, the commission is scheduled to submit the Make Our Children Healthy Again Assessment, a report that identifies issues and concerns surrounding childhood chronic disease and gauges the efficacy of current research and data and federal efforts to combat chronic health conditions. That is slated to be followed, within 180 days of the order, by the Make our Children Healthy Again Strategy action plan to lower the incidence of childhood chronic disease.

“The order focuses on the pharmaceutical industry, linking ‘increased prescription of medication’ to the health crisis, but we believe it also poses risks to food and beverage businesses because the language contains inferences to ultra-processed foods,” TD Cowen food industry analyst Robert Moskow said in a Feb. 18 analysis.

Closer scrutiny of food industry likely

Moskow pointed to one section of the order that said the initial assessment will “study the scope of the childhood chronic disease crisis and any potential contributing causes, including the American diet, absorption of toxic material, medical treatments, lifestyle, environmental factors, government policies, food production techniques, electromagnetic radiation and corporate influence or cronyism.”  

“We believe they will make a push against how ingredients get approved under FDA’s GRAS process (Generally Recognized As Safe), which allows companies to self-certify ingredient safety,” he said. “While they are presumably safe to ingest in small amounts, some believe they cause harm when used over the long term and that chemical reactions can occur between them when consumers eat multiple processed foods over the course of a day.”

Moskow said another concern to food companies is another part of the order that calls for the commission to “assess the threat that potential overutilization of medication, certain food ingredients, certain chemicals, and certain other exposures pose to children with respect to chronic inflammation or other established mechanisms of disease.” He also cited the possible effect of health care influencer Dr. Casey Means, who advocates that Americans take more control of their own health by better controlling their metabolism via diet, exercise, sleep and the assistance of wearable health monitoring technology.

“This aligns with Dr. Casey Means’ recommendation (who has advised RFK Jr.) of limiting seed oils because they are inflammatory,” he said. “Most packaged foods use seed oils (e.g. canola, soybean, corn oils) because they are inexpensive, withstand industrial processing and do not go rancid for a very long time.”

The commission’s potential scrutiny of food production, Moskow explained, “likely refers to extensive industrial processing (e.g. extreme heat, extrusion, chemical treatments, pressure steaming, drying) that some believe depletes nutrients and quickens calorie absorption into the body. Companies employ these production techniques to scale up, lower production costs and lengthen shelf lives of their products.”

Though the timelines for the MAHA Commission’s two reports aren’t until late May and mid-August, the assessment and the action plan “could contain some strong language around reformulations that food and beverage brands will need to implement,” Moskow noted. The order said the commission chairman may hold public hearings or other events as well as receive expert input “from leaders in public health and government accountability.”

“The big challenge of initiatives like these is that they tend to tax the internal resources of food companies and distract them from their core competencies — creating indulgent, convenient food at low costs,” Moskow said. “In that vein, we expect food companies to spend a great deal of effort in the months ahead, proactively removing artificial flavors and preservatives that are unlikely to meet the new standards. Removing highly ubiquitous ingredients such as seed oils, however, would present a much bigger challenge and a much higher cost. We expect constituents of the agribusiness industry to present studies at the hearings to make the case that they are safe.”

Regarding federal programs that could get a closer look by the MAHA Commission, the TD Cowen analysis said the executive order’s aim to “identify and evaluate existing federal programs and funding intended to prevent and treat childhood health issues for their scope and effectiveness” likely points to the Dietary Guidelines for Americans (the latest iteration of which, for 2025-2030, is pending), the Supplemental Nutrition Assistance Program (SNAP) and school lunch programs.