The Make America Healthy Again (MAHA) movement, with U.S. Department of Health and Human Services (HHS) Secretary Robert F. Kennedy Jr. at its spiritual helm, is demonstrating a nascent but discernible evolution. As Kennedy embarks on his second year shaping the nation’s public health policy, MAHA is exhibiting increasing confidence and resourcefulness, akin to a young child transitioning from infancy to toddlerhood. This shift is occurring against a backdrop of significant regulatory scrutiny and political maneuvering, particularly as the 2026 midterm elections approach.
A recent analysis published in Scientific American posits that the MAHA movement has already "upended science and medicine," a claim attributed to its pronounced skepticism towards established scientific consensus and traditional medical practices. This stance has, according to industry observers, begun to reshape regulatory frameworks, particularly concerning nutrition and supplement policies.
Ivan Wasserman, managing partner at Amin Wasserman Gurnani LLP, notes that "If we define MAHA as an overall movement or concept focusing on food’s impact on health, it has had a huge impact on nutrition and supplement regulations." He elaborates, "In addition to actual changes—including at the state level with regulations on ultra-processed food, school lunch programs, artificial dyes and other chemicals added to foods—the political force that is MAHA voters has spurred politicians to show they are doing something to address their concerns." This burgeoning influence underscores the movement’s growing political capital.
The political calculus surrounding MAHA is particularly relevant as the nation heads into the 2026 midterm elections. Republican strategists are keenly observing the "MAHA Moms," a demographic showing significant engagement with the movement’s agenda. Polling data suggests that approximately 40% of parents express support for the MAHA agenda, positioning this voting bloc as a potentially crucial driver of turnout in an electoral cycle historically unfavorable to incumbents. This demographic’s alignment with MAHA could translate into significant political leverage.
Adding a layer of complexity, the Trump administration’s recent endorsement of glyphosate, a substance long identified as a primary concern for "MAHA Moms" and a former point of contention for RFK Jr. himself, highlights the evolving dynamics. Industry analysts are keen to observe the lines being drawn between the broader Make America Great Again (MAGA) agenda and the specific tenets of MAHA. Protective measures favoring large multinational corporations, often referred to as "Big Ag," "Big Chem," and "Big Food," are increasingly evident. The prominent inclusion of meat in revised dietary guidelines and the defense of glyphosate as a matter of national security exemplify instances where MAHA’s agenda may encounter limitations when it intersects with Trump’s overarching political platform.
As MAHA solidifies its identity and strengthens its ties to the Trump political apparatus, leading legal and industry experts are offering insights into the movement’s trajectory and what to anticipate in the coming years. Their perspectives shed light on the strategic maneuvers and regulatory shifts that are likely to define the food and supplement landscape.
Setting the MAHA Stage in 2025: A Year of Preparation
Claudia Lewis of Venable LLP characterizes MAHA’s initial year as primarily focused on "setting the stage for the future rather than completely overhauling nutrition and supplement regulation immediately." This strategic approach, she explains, laid the groundwork for more substantive changes to come. During 2025, the Food and Drug Administration (FDA) made several notable announcements, including plans to phase out certain petroleum-derived synthetic color additives in foods and a reinforced focus on the safety of infant formula and toddler milk. These actions, while not constituting immediate regulatory overhauls, signaled a shift in enforcement priorities and a greater emphasis on consumer safety.
Ivan Wasserman echoed this sentiment, stating, "In the first year, there certainly has been a flurry of pronouncements and promises, but other than the new food pyramid, which isn’t really a regulation, there haven’t been many significant regulatory changes, which isn’t surprising as such changes take time." This period can be seen as a phase of policy articulation and a signaling of future regulatory directions, rather than the immediate implementation of sweeping new rules.
A key observation from 2025 is the strategic decentralization of regulatory action. While federal pronouncements set a national tone, the most tangible regulatory developments have occurred at the state level. This approach appears designed to mitigate the immediate impact of large industry lobbies by allowing states to enact legislation first. This has led to a patchwork of regulations across the country, with some states taking more proactive stances than others.
"It’s notable that roughly three dozen states have introduced legislation aimed at restricting certain synthetic additives and high-sugar products in schools and other child-focused settings, and at strengthening on-pack or menu labeling requirements for foods and supplements," Lewis observed. "At the state level, legislatures are expected to keep advancing bills that limit food additives in school meals, require new disclosures or mandate on-pack warnings." New Jersey, for instance, has proposed annual reporting of new Generally Recognized As Safe (GRAS) determinations, including details on intended use, safety data, and the rationale behind the GRAS conclusion.
Two significant developments in 2025 for MAHA were progress on addressing synthetic dyes and scrutiny of self-affirmed GRAS notifications. Justin Prochnow of Greenberg Traurig LLP identified the phasing out of synthetic dyes as having "long legs" due to its broad public acceptance. "It really is the least controversial of all of the MAHA items," Prochnow stated, "as most people don’t likely believe that synthetic color dyes are a good thing."
The issue of GRAS, however, remains a complex and ongoing concern for the industry. Prochnow highlighted a critical point: "The FDA used to require submissions of GRAS notifications until such a backlog developed that it became voluntary at the end of 1997, beginning of 1998. Now, all of a sudden, FDA will have more ability to review mandatory notifications? That seems unlikely." This historical context suggests that any move toward mandatory GRAS reviews would represent a significant procedural shift and potential bottleneck for new product introductions. The industry will be closely monitoring these developments to assess their impact on innovation and the time-to-market for new products.
The MAHA Watchlist for 2026: Emerging Regulatory Battlegrounds
The coming year, 2026, is poised to be a pivotal period for regulatory action, with experts anticipating a potentially intense period of change. Ivan Wasserman anticipates that "The next two years could be very busy on the regulatory front—perhaps the busiest in my 30-plus years of practice." His forecast includes the potential elimination of the self-affirmed GRAS pathway, the release of long-awaited final guidance on new dietary ingredient notifications, and new restrictions on caffeine labeling.
Ultra-processed foods (UPFs) are emerging as a significant focal point in the regulatory landscape. In 2025, the FDA and USDA jointly issued a request for information to help define UPFs, a move that has garnered attention from various stakeholders. The issue was recently highlighted in a 60 Minutes segment featuring Robert F. Kennedy Jr. and former FDA Commissioner David Kessler, a vocal critic of the supplement industry, united in their concern over UPFs. This high-profile attention is likely to embolden class-action plaintiff lawyers.
"UPFs are turning into a combined effort and focus of the administration and class-action plaintiff lawyers," Prochnow commented. "The more that RFK Jr. and the administration talk about UPFs and how bad they are, the more the plaintiff lawyers latch onto it." This convergence of regulatory and legal pressure creates a formidable challenge for the food industry concerning UPFs.
The FDA’s Human Foods Program, in its priority list for 2026, has placed a spotlight on modernizing oversight of dietary supplements. This renewed focus has legal experts bracing for further MAHA-driven impact. "FDA stated that it will ‘continue to support dietary supplement priorities with targeted enforcement strategies on violative products,’" Wasserman noted. "While their plans are obviously and intentionally vague at this point, the hope is FDA will embark on a path to regulatory changes that will end in a smart, balanced approach to level the playing field against bad actors and keep safe, effective and compliant supplements available to consumers."
Another area drawing attention from Prochnow is the regulation of peptides. "I think FDA will need to weigh in on the regulation and sale of peptides in a non-drug context," he stated. "There are many companies out there marketing peptides like BPC-157 and others as non-drug products labeled as ‘For Research Purposes Only’ when that is not the case. With the popularity of GLP-1 drugs and other peptides, the FDA is likely going to need to opine on this growing category." The marketing of peptides for non-research purposes, particularly in light of the surging interest in GLP-1 agonists and similar compounds, presents a regulatory challenge that the FDA is expected to address.
Will MAHA Emerge as a Net Positive for Supplements?
Predicting the ultimate impact of the MAHA movement on the supplement industry remains a complex endeavor, much like forecasting the behavior of a toddler. However, by examining the trends and expert opinions, a cautiously optimistic outlook for supplements can be discerned, despite the primary focus on food-related issues.
"As a general rule, supplements would seem to be a category that is looked upon favorably by MAHA and RFK Jr. as alternatives to prescription drugs," Prochnow observed, "but the regulatory and enforcement focus continues to be on synthetic colors, added sugars and UPFs." This indicates that while supplements may not be the immediate target of MAHA’s reform efforts, they are generally viewed as a potentially beneficial category, especially as alternatives to pharmaceutical interventions.
This perspective is a common theme: MAHA’s current efforts are primarily directed at perceived "villains" within the food supply chain, with supplements awaiting more explicit policy articulation at the federal level. Ivan Wasserman concurred, stating, "I haven’t seen evidence yet of RFK or the MAHA movement in general being big champions of the supplement industry, with the main focus seemingly on encouraging more consumption of whole foods."
From a broader viewpoint, MAHA could serve as a catalyst for much-needed modernization of the regulatory framework that has governed the supplement industry for over three decades under the Dietary Supplement Health and Education Act of 1994 (DSHEA). "DSHEA was passed long ago, so it’s time for it to be re-evaluated and updated so that it aligns more directly with how consumers understand and use supplements," Lewis argued. "This administration has several initiatives, which is a good start. Whether it proves to be a net positive or negative will largely depend on how the framework and the specific proposals are implemented in practice. It certainly has the potential to be positive." The long-standing nature of DSHEA suggests that a comprehensive review and update are overdue, and MAHA’s influence may accelerate this process, potentially leading to a more robust and relevant regulatory environment for dietary supplements.