There are many striking things in the recently-released MAHA Strategy Report: Make Our Children Healthy Again. One of the most striking is the scant mention of dietary supplements.

Aside from a brief promise to study “potential health benefits of select high-quality supplements” under the newly remade NIH’s future research agenda, and a warning that the FDA will “take action against unapproved products, often marketed as supplements,” the only other time the word “supplement” appears in the report is in the name of the Supplemental Nutrition Assistance Program (SNAP), aka food stamps.

Probiotics? Not a word. Herbs and botanicals? Nada. Vitamin D? Nothing.

During the September 9 press conference presenting the new report, neither Health and Human Services (HHS) Secretary Robert F. Kennedy, Jr., — the undisputed leader of the MAHA movement — nor any of the other MAHA committee members said anything about supplements. I was quite surprised.

Historically, HHS and its myriad agencies have never been particularly friendly toward supplements. So I was not too shocked when the Biden administration’s 2021 National Strategy for the Covid Response contained no mention of vitamin D, or zinc, or any other potentially immune-boosting supplement.

But now, we’re talking about MAHA! RFK Jr! A whole committee of mavericks and iconoclasts who seem hellbent on upending establishment views — and in many cases the establishments themselves.

We’re talking about the center-stage moment for a movement that represents legions of health-conscious Americans deeply committed to health freedom, nutrition, and natural medicine. And I’d wager a nice dinner at your favorite restaurant that over 90% of people who identify as MAHA Moms and Dads take supplements daily … and give them to their kids.

Kennedy himself has stated that he took “so many supplements he can’t remember them all,” and he’s on record promising to fight for supplements to take “their rightful place” in healthcare.

Given that supplements are part of the lives of so many in the MAHA world, that the U.S. supplement industry generates somewhere between $55 billion and $70 billion in sales annually, and that industry folk have been voicing MAHA principles long before there was ever a MAHA movement, one would think the committee would make more than a fleeting mention of them.

Equally surprising is that none of the normally vociferous supplement industry trade groups has raised a ruckus about this.

Perhaps the industry’s thought leaders are happy with the committee’s mere mention that supplements might have “potential benefits” worthy of study. It’s certainly more love than the industry has gotten from HHS in the past.

Or perhaps they are waiting hopefully, figuring that sooner or later RFK Jr. and other supplement-friendly folk among the MAHA committee members will eventually get around to working them into the national agenda.

Time will tell.

For the moment, I’m left wondering whether supplements, and the supplement industry, really have a formal place at the MAHA table.

Unknown Attitudes

Though his past statements indicate that Kennedy values vitamins, minerals, herbs, probiotics and the like, he has been pussyfooting around the topic since assuming office. We know that in principle, he’s quite friendly toward the industry. But so far, he’s said little publicly to indicate how and where supplements fit into MAHA’s vision for overhauling American healthcare.

Marty Makary, MD, the new FDA commissioner, is an even bigger question mark.

A well-respected Johns-Hopkins oncologic surgeon, Makary has repeatedly challenged medical dogma and physician group-think, especially around nutrition. He has openly bashed the medical community’s vilification of all saturated fats, and its decades-long embrace of “low-fat” products — many highly processed — as “healthy” alternatives to natural full-fat foods.

But in his public statements, his journal articles, and his best-selling books Blind Spots (2024) and The Price We Pay (2021), Makary has said nothing about supplements.

Philosophically, it seems the new FDA chief would be more open-minded than his predecessors. But Makary is also pragmatic, skeptical, and demanding of real evidence to support purported health benefits. So, he’s not likely to give supplements a pass simply because they’re supplements and they’ve been largely dismissed by medical orthodoxy.

Makary is also very safety-conscious, as indicated by his strong stance against the sale of products containing 7-OH, an opioid compound found in the herb Kratom. He is pushing to classify 7-OH as a Schedule I controlled substance.

“7-OH is not just like an opioid. It does not just have opioid-binding properties. 7-OH binds to the mu receptor, which means, scientifically by definition, it is an opioid. And yet it is sold in vape stores, in smoke shops, in convenience stores, and gas stations,” he said during an FDA press conference in July.

But he also made a distinction between natural Kratom leaf, which only contains trace amounts of 7-OH, and the highly concentrated synthetic 7-OH found in vape products, which he says is 13 times more potent than morphine. He stressed that FDA is going after the latter, not the former.

In general, though, Makary has given no indications about how he intends to regulate the supplement industry, or if he is considering changes to DSHEA.

What we do know is that there are several components of the MAHA agenda that will likely have significant impact on the industry, and not necessarily in a good way.

The Self-Affirmed GRAS Conundrum

For one, Kennedy is intent on “closing the self-affirmed GRAS loophole,” and he’s given Makary the job of making that happen. Kennedy and other prominent MAHA leaders see self-affirmed GRAS as a backdoor for food makers and chemical companies to pipeline questionable substances into the nation’s food supply without oversight or transparency.

One of MAHA’s main objectives is to remove harmful chemicals from the food supply — and especially from foods consumed by children. To Kennedy and company, self-affirmed GRAS hinders that goal because it essentially gives ingredient-makers a pathway to avoid regulation.

The administration clearly favors a policy of mandatory FDA review for novel ingredients. Leaving aside the question of whether or not the FDA — especially under Trump administration austerity — would have the capacity to handle all the newly required safety reviews, there’s little doubt that mandatory reviews would slow the process of bringing new ingredients to market.

In its intention to eliminate self-affirmed GRAS, HHS has not signaled any intention to specifically target supplements; the concern is really with food manufacturers.

But as many industry leaders have pointed out, a lot of supplement ingredients are self-affirmed GRAS. So, any change in the regulations would likely have heavy impact.

A clampdown on new ingredients could potentially stifle innovation across the industry, while also adding new costs and hassles.

This may be one reason why the MAHA committee is not saying much about supplements. It’s hard to claim “we’re getting the GRAS out of the grocery store” while simultaneously lauding an industry rife with self-affirmed GRAS ingredients.

Ultra Processed = Ultra Problematic

Then, there’s the question of “Ultra Processed.” Another of MAHA’s main priorities is to minimize children’s (and all Americans’) consumption of ultra-processed foods (UPFs), and to require food manufacturers to label UPFs as such. The first step toward those seemingly admirable goals is to establish a formal definition of “ultra-processed.”

Despite the widespread use of that term in industry, in medicine, and among the general public, there’s never been a clear and authoritative definition of UPFs. People have a general sense it means manufactured, chemically-laden comestibles of questionable nutritional value, but packed with sugar, salt, and toxic fats. From a policy-making perspective, though, there’s never been a standard definition.

Kennedy and company aim to change that.

In the first MAHA report, issued in May, the committee tipped their collective hat to the Nova food classification system’s definition: “industrially manufactured food products made up of several ingredients including sugar, oils, fats and salt, and food substances of no or rare culinary use.”

Nova, developed by Brazilian public health researcher Carlos Monteiro and colleagues, defines four general categories of foods, based on the degree to which they’ve been processed:

• Group 1: Unprocessed or minimally processed foods (raw fruits and vegetables, whole grains, foods that have undergone little processing other than removal of inedible parts, roasting, freezing, drying, crushing, or pasteurization).
• Group 2: Foods processed solely with ingredients used in traditional culinary practices, and produced by simple culinary processes.
• Group 3: Foods prepared or processed by combinations of components from Groups 1 and 2 (some types of cheese, smoked fish or meat, preserved fruits, pickles, fresh-baked bread).
• Group 4: Ultra-processed foods industrially-produced, and utilizing “food substances never or rarely used in kitchens, or classes of additives whose function is to make the final product palatable or more appealing.” Such products are usually based on commodity ingredients from a small number of high-yield plants (corn, wheat) or obtained from animals (dairy, beef, pork, etc.).

Though it remains to be seen how HHS will ultimately define UPF for policy purposes, it is likely to contain a lot of Nova’s conceptual DNA.

What does this have to do with supplements?

Well, supplements are considered foods under federal law, and let’s face it, most of them are highly processed. Many contain “substances never or rarely used in kitchens.”

Again, there’s no indication that the FDA or any other of the HHS agencies view supplements as targets in their crusade against UPFs. But as a category, supplements do present something of a conundrum. And it will be interesting to see how the regulators and the industry dance around this one.

SNAP: Soda Out, Supplements In?

Another of the MAHA committee’s stated goals is to work with state governments to make soda and junk food ineligible for purchase under SNAP. The goal, obviously, is to make unhealthy food less accessible to vulnerable people, and to financially motivate them to make healthier choices.

Approximately 42 million Americans receive SNAP, which had a total expenditure of $113 billion in 2023.

According to the May MAHA report, “Children receiving SNAP benefits are more likely to consume greater quantities of sugar-sweetened beverages and processed meats compared to income-eligible nonrecipients. By one estimate, nearly twice as much will be spent by SNAP on UPFs and sugar-sweetened beverages ($21 billion) compared to fruits and vegetables ($11 billion) in FY2025.”

During the MAHA press conference, Secretary of Agriculture Brooke Rollins, whose department oversees SNAP, said USDA has already called on governors in all 50 states to apply for waivers that would enable them to restrict soft drink and junk food purchases under SNAP, and to solicit new ideas for how to make the programs healthier.

So far, Rollins said, 12 states have had waivers approved, with several more pending.

Some supplement industry watchers have expressed hopes that legislative efforts to include supplements as eligible purchases under SNAP could gain new traction from the MAHA agenda. A proposed provision to the 2018 Farm Bill which called for supplement inclusion was ultimately nixed by the Senate. This failure followed the 2017 SNAP Vitamin and Mineral Improvement Act, championed by then-Congressman Mike Rogers (R-AL), which also went nowhere.

It remains to be seen whether the MAHA agenda will spark renewed political interest in supplement inclusion. This would require legislative action to revise SNAP’s definition of “food” which, contrary to DSHEA, currently excludes supplements.

Such a move would make sense as part of MAHA’s sweeping effort to reform SNAP and reduce the nation’s staggering chronic disease burden. So far, though, the MAHA committee has made no mention of this possibility.

Of course, all the SNAP reforms — real or merely wished-for — need to be seen in context. The reality is that the One Big Beautiful Bill Act (OBBBA) will cut $186 billion from the SNAP program over the next decade.

Reforming Medical Education

One of the most hopeful pieces of the new MAHA agenda is the committee’s mandate for nutrition training as part of standard medical school education. During the recent press conference, Kennedy said HHS will require “nutrition and metabolic health courses” in medical schools receiving federal funding.

The Sept. 9 report stated that: “HHS and CMS (Centers for Medicare & Medicaid Services) will address the current monopolies that exist for the accreditors of medical education programs by using their regulatory authorities to bring in competing accreditors of medical education programs, including those with a focus on treating the root causes of chronic disease in the United States. Accreditation reform can also increase nutrition education and ensure medical school curricula better align with making America healthy again.”

Improving nutrition education for the country’s future clinicians is, indeed, an admirable goal, and much needed. But leaving aside the big questions of how to implement major curriculum change across the nation’s 199 medical schools, there are also big questions about what, exactly, constitutes nutrition education that “aligns with making America healthy again,” and who will be in charge of teaching it.

The danger here is that the MAHA movement could end up replacing one set of dogmas and orthodoxies, with another set more to its liking but not necessarily healthier or more scientific. The truth is, MAHA circles seethe with dietary dogmas such as all seed oils are poisonous; beef tallow is a healthier alternative; everyone should drink raw, unpasteurized milk; animal protein diets are inherently healthier than vegetarian or vegan diets.

There may be some merit in some of the MAHA diet concepts. But many of the movement’s dietary propositions are still far from being scientifically validated.

There’s also a question about whether education about supplements will be included in the MAHA medical education reform. One would hope so, given how central supplements are to many peoples’ health protocols, and how many practitioners now recommend or dispense them. But again, the MAHA committee has made no mention of this.

The New Gold Standard

One term that pops up often in MAHA committee communications is the hackneyed “Gold Standard Science.”

The Sept. 9 report stated that “The NIH will establish new mechanisms to strengthen Gold Standard Science, as required by Executive Order 14303 of May 23, 2025, including capacities for high-quality systematic reviews, incentives for replication and reproducibility, the identification of evidence gaps and the development of a Scholars Program to address the quality crisis in scientific peer-review and publishing.”

It further notes that when it comes to food regulation (or de-regulation), agencies under HHS will, “Ensure the use of gold standard science for regulatory decision-making and update outdated methodologies as necessary.”

Throughout the press conference, FDA’s Marty Makary, NIH Director Jay Bhattacharya, and Environmental Protection Agency Administrator Lee Zeldin swore that “gold standard science” will be the north star as they direct their respective agencies.

So, what exactly is considered “Gold Standard Science” in the MAHA-verse? The aforementioned EO 14303 gives some explicit and long-winded definitions.

After placing blame on federal Covid-19 policy for the loss of public confidence in science, then branding certain measures of global warming as “misleading,” and bashing the incorporation of DEI principles in the sciences, the EO goes on to define the Gold Standard as: reproducible; transparent; communicative of error and uncertainty; collaborative and interdisciplinary; skeptical of its findings and assumptions; structured for falsifiability of hypotheses; subject to unbiased peer review; accepting of negative results as positive outcomes; and without conflicts of interest.

That all sounds reasonable. But here’s where the fun starts: the EO explicitly directs agency heads to, “take all necessary actions to reevaluate and, where necessary, revise or rescind scientific integrity policies or procedures, or amendments to such policies or procedures, issued between January 20, 2021, and January 20, 2025.”

Make of that what you will, but it sure sounds to me like the administration is directing federally-employed science folks to trash any science policy established under the Biden administration.

Politics aside, it will be interesting to see how much of the supplement industry’s science will pass muster as “gold standard” under the administration’s new definition. It’s another question to add to the growing list of questions about the role of dietary supplements in the MAHA effort to roll back the tide of chronic disease.