By Susan Mayne, PhD

In May, the Make America Healthy Again (MAHA) Commission released the much-anticipated MAHA Report. The report conveys the commission's thinking about what is driving the "increase in childhood chronic disease," in particular, "obesity, diabetes, neurodevelopmental disorders, cancer, mental health, autoimmune disorders, and allergies." The report identifies four major drivers: poor diet, more specifically the shift to ultra-processed foods (UPFs); the cumulative load of chemicals in the environment; lack of physical activity and chronic stress impacting childhood behavior in the digital age; and the overmedicalization of our kids.

The report is meant to lay the foundation for forthcoming federal policies and resource commitments to address these "drivers." Consequently, the scientific evidence supporting this report is critical, as errors about the causes will result in proposed solutions that miss the mark, failing to improve children's health, or worse.

What Does the Report Say About Poor Diet and UPFs?

The report notes that the majority (nearly 70%) of children's calories come from UPFs, and attributes adverse health effects to (1) nutrient depletion due to "ultra-processed grains, sugars, and fats," (2) increased caloric intake, and (3) inclusion of food additives.

In unpacking this assertion, we must recognize that the term "ultra-processed" in current scientific literature refers to foods, not ingredients. Therefore, there is no definition of, or research on, ultra-processed grains, or sugars, or fat. The current Dietary Guidelines for Americans -- which are due to be updated by the Trump administration and may be released this summer -- are data-driven and science-based. These guidelines already recognize differences between refined versus whole grains, and added sugars versus sugars that are inherently in foods such as lactose in milk and sugars found naturally in fruit, and note that saturated fats should be limited in favor of poly- and monounsaturated fats. So, the MAHA report seems to be creating new terms that have no accepted meaning in nutrition science literature, dividing grains/sugars/fats by some unknown or unstated degree of processing, based on unknown criteria and therefore lacking evidence.

The second driver of UPF adverse health effects per the report is increased caloric intake. There is strong evidence in the literature, including the seminal trial reported in 2019 by Kevin Hall, PhD, that diets with a large proportion of UPFs versus diets comprised of minimally processed foods lead to calorie overconsumption in short-term studies of adults. So, this is a reasonable claim.

The third driver of adverse health effects of UPFs identified in the report is food additives. In particular, the report focuses on emulsifiers, binders, artificial sweeteners, colorings, and preservatives. From a scientific perspective, there is limited evidence that food additives (other than sodium, added sugars, and sources of saturated fat) used in UPFs broadly speaking are associated with chronic disease.

Only limited research has been done to study the potential mechanisms underlying UPFs' adverse health effects. Interim but nonetheless provocative data presented by Hall indicate that energy density (kcal/g, a function of factors such as fat vs fiber and water content) and hyperpalatability (a function of fat, added sugar, refined carbohydrates, and sodium) appear to mediate the effect of UPFs on calorie overconsumption; diets containing 80% UPFs with low levels of energy density/low hyperpalatability did not lead to a significant increase in calorie intakes as compared to a diet comprised of minimally processed foods (unfortunately, Hall resigned from the NIH prior to the completion/reporting of this important trial).

Another recent study concluded that the U.S. food supply contains more hyperpalatable foods (a greater percentage of calories from fat, sugar, starchy carbohydrates, and sodium) compared to 16 other countries, and the hyperpalatable foods within the U.S. had, on average, significantly more calories from fat, sugar, starchy carbohydrates, and sodium relative to hyperpalatable foods from most other countries examined. The authors suggested that reducing levels of hyperpalatable ingredients such as sodium could help to reduce UPF intake and calorie overconsumption, improving population health.

As for other additives, some studies suggest a potential association between consumption of synthetic food dyes and adverse neurobehavioral effects, such as inattentiveness, hyperactivity, and restlessness in sensitive children. The data are inconsistent, and observational research is challenged by the co-occurrence of synthetic dyes and added sugars. Yet, FDA recently requested voluntary removal of certified food dyes from the U.S. food supply. As for other additives, there is considerable interest in various categories such as emulsifiers, but data, especially human data, are lacking and more research is needed.

So, the report deviates from current scientific evidence on additives in significant ways, omitting well-accepted drivers of chronic disease found in UPFs, especially sodium, added sugars, and saturated fat. Instead, the report criticizes the current Dietary Guidelines for "problematic reductionist recommendations" in reference to advice to "reduce saturated fat" or "limit sodium" instead of focusing on minimizing UPFs.

In the case of sodium, for example, this dangerously ignores decades of research demonstrating that sodium is over-consumed in the U.S., contributing to chronic disease; this includes evidence from randomized intervention trials where sodium alone is manipulated, providing direct evidence for causation (i.e., the opposite of "reductionist science"). FDA's current approach to sodium reduction applies to commercially processed, packaged, and prepared foods, not just UPFs, so focusing only on UPFs would miss the mark on these other foods.

What Does the Report Say About Whole Foods?

The report promotes consumption of whole foods, with the following foods explicitly identified: leafy greens, salmon, legumes, nuts, beef, and whole milk and other dairy products. The specific inclusion of beef and whole milk, but not poultry or low-fat milk (anywhere in the report), is notable. For example, it states, "Beef contains protein that maintains skeletal muscle, which plays a key role in regulating metabolic health."

By contrast, substantial, credible nutrition research, as recently reviewed by the 2025 Dietary Guidelines Advisory Committee, finds that swapping beef for other protein sources is associated with reductions in chronic disease risk, concluding that a healthy dietary pattern is "lower in red and processed meat." Also, the International Agency for Research on Cancer has classified red meat as "probably carcinogenic to humans" (class 2A carcinogen), while poultry is not considered to be carcinogenic. Beef also contains trans fat, while poultry and fish do not.

So, while in general the promotion of whole foods over UPFs is rational and well-supported, the featuring of beef and whole milk over alternatives more consistently associated with chronic disease risk reduction is not.

The Impact on Nutrition When Science Misses the Mark

Focusing subsequent policies and resources on broad categories of additives -- rather than additives in UPFs such as sodium, saturated fats, and added sugars that are known to both increase chronic disease risk while also contributing to hyperpalatability -- is a missed opportunity and could undermine public health, particularly with regard to obesity and cardiometabolic disease. Similarly, highlighting beef at the expense of other protein sources such as poultry, fish, and plant-based proteins reflects ideology rather than science, again to the detriment of children's health.

Despite the lack of evidence behind many of the report's conclusions, it very well may foreshadow the forthcoming Dietary Guidelines update. Only time will tell the impact of ensuing nutrition policies on our children's health.

Susan Mayne, PhD, is Professor (adjunct) at the Yale School of Public Health in New Haven, Connecticut. She was previously the C.-E.A. Winslow Professor of Chronic Disease Epidemiology at the Yale School of Public Health prior to serving as the Director of FDA's Center for Food Safety and Applied Nutrition during the Obama, Trump, and Biden administrations (2015-2023).