Although the leaked draft of the second report does not provide great detail about new federal actions to combat chronic childhood disease, it echoes several initiatives previously announced by the U.S. Food and Drug Administration (FDA) and emphasizes a “deregulatory” approach.

Specifically, the second report mentions FDA’s efforts to advance and implement policies to limit or prohibit the use of petroleum-based food dyes in foods, including expediting the review and approval of color additive petitions for colors from natural sources, as well as the exploration of potentially providing greater flexibilities regarding the use of "no artificial color" and other labeling claims. It upholds FDA and HHS’ collaboration with industry at the forefront of this effort, saying the agencies will “highlight success stories of the private sector.”

Additionally, the report says FDA will continue to develop and implement an enhanced, evidenced-based systematic process for the post-market assessment of chemicals in food—an effort that began under the previous Administration. The agency will also update regulations to reform the Generally Recognized as Safe (GRAS) rule within the scope of statutory authority, as directed by Secretary Kennedy in March.   

In line with “Operation Stork Speed,” which was also announced in March, the leaked report says FDA will modernize nutrient requirements, increase testing to help ensure access to high-quality and healthy infant formula sold in the U.S., and take steps to address potential barriers to innovation.

The report draft outlines specific “food deregulation” actions, including:

• Removing barriers preventing small dairy operations from processing and selling their own milk products locally
• Providing additional guidance on Hazards Analysis Critical Control Points (HACCP) requirements for very small meat processors serving local markets
• Providing additional support for mobile processing units serving multiple small farms
• Reforming “outdated and unnecessary” food standards of identity (SOIs)—as of August, FDA has already revoked 52 SOIs and proposed an amended SOI for pasteurized orange juice
• Reviewing regulations for outdated methodologies that inhibit the use of gold standard science for regulatory decision-making
• Removing or amending regulations with outdated submission requirements (e.g., paper records) that present obstacles for submission and use of modern analytical techniques
• Withdrawing outdated or obsolete guidance documents
• Exploring opportunities to introduce flexibility in manufacturing requirements while maintaining high standards to protect public health.

Also mentioned in the report is HHS’ drastic restructuring, announced in March 2025, which included the firing of 3,500 and 2,400 CDC and FDA staffers, respectively.

Aviva Musicus, ScD, Science Director at the Center for Science in the Public Interest (CSPI), a major consumer advocacy voice on food safety-related matters, sharply criticized the focus on “voluntary action and education instead of regulation” in the leaked second report. “The report seems to twist itself into knots to make it clear that it will not be infringing upon food companies,” she stated, emphasizing the report’s use of noncommittal language like “explore,” “potential,” and “guidelines” in reference to agency actions.

“Talk is cheap… we need to judge the administration by what it does, not what it says,” stated Dr. Musicus, asserting that the Administration’s actions thus far are “poised to make America sicker, hungrier, and more at risk from unsafe food.”