The U.S. Department of Agriculture (USDA) first started regulating genetically modified plants in 1987. In the decades to follow, new breakthroughs like CRISPR gene editing technology have made it easier for plant breeders to find and tweak traits that make plants more productive, better tasting, and more likely to survive until harvest. In addition to delivering these benefits, biotech crops have been proven safe over and over again, and, in some cases, are even indistinguishable from their conventionally bred counterparts. As the pace of biotechnology innovation accelerated over the last 40 years, USDA’s regulatory framework for crops made with biotechnologies remained largely unresponsive. Efforts to implement substantial changes were unsuccessful until 2020. Since then, a cascade of changes and reversals have created a period of regulatory whiplash.

In 2020, USDA finalized the SECURE rule which updated premarket oversight of genetically engineered organisms developed with biotechnology. The rule marked the first significant update to USDA’s agricultural biotechnology regulations in decades. While the new framework had shortcomings, it did succeed in significantly streamlining regulatory processes and reducing the burden of environmental review for some products. This lasted for 4 years until a U.S. District Court found fault with the rule, threw it out, and required USDA to revert back to the legacy regulations that were in place prior to 2020. The shift back to the legacy regulations at the start of 2025 increased the extent to which USDA was required to conduct Environmental Assessments (EA), and in some cases Environmental Impact Statements (EIS), in line with NEPA, lengthening review times specifically for petitions to deregulate new genetically modified plant varieties.

In the latest whiplash-inducing move, the White House Council on Environmental Quality under President Trump rescinded its own NEPA regulations and directed individual agencies to update their NEPA implementing procedures. In response, USDA released its revised NEPA implementing regulations, fully rescinding and rewriting those relevant to the the Animal and Plant Health Inspection Service, among others. Given these changes, and confirmed via an announcement from the agency, USDA will no longer conduct a NEPA analysis during its review of petitions seeking a determination of nonregulated status for genetically modified organisms.

This change is poised to shorten the time it takes USDA to review petitions, accelerating the rate at which improved plant varieties reach farmers, without adding environmental risk. But, simply curbing NEPA review of agricultural biotechnology will do little to alleviate regulatory burden on developers, and could even elicit prolonged legal backlash.

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Sidestepping NEPA will speed up reviews

When a plant breeder submits a petition seeking nonregulated status for their product, the Animal Plant Health Inspection Service (APHIS) conducts a plant pest risk assessment (PPRA) to determine the potential for the modified plant to survive, reproduce, become a weed, or to facilitate the spread of plant diseases or pests. Historically, APHIS also conducted a NEPA analysis (EA or EIS) on factors beyond plant pest risk, to determine if the organism’s unconfined release would have a significant impact on the human environment. The PPRA and NEPA assessments were published simultaneously for public comment before a final decision was made for a modified organism’s regulatory status.

In line with the USDA’s revised NEPA implementing regulations, APHIS announced it will now complete its PPRA first. As soon as the agency completes a PPRA that determines a plant does not pose a plant pest risk, APHIS claims it will no longer have legal authority to consider or mitigate environmental impacts under the Plant Protection Act, and therefore has no obligation to conduct NEPA analysis for petitions.

The environmental community has decried the White House’s rollback of NEPA as an unprecedented weakening of bedrock environmental law. While this perspective highlights a general concern for environmental oversight, the specific impact on plant biotechnology reviews has the potential to be a net positive for the climate. Scientific bodies have repeatedly asserted that genetically engineered crops are as safe as their conventional counterparts on the market, in terms of both human health and environmental impact. At the same time, new advances in crop biotechnology offer faster, more targeted, and more effective genetic improvements that have created crops that are higher yielding (reducing deforestation driven by cropland expansion) or have increased pest resistance (reducing the volume or toxicity of pesticide applications). Gene-edited microbes can improve crop nutrient uptake and efficiency (reducing the need for fertilizers that can cause runoff-induced environmental degradation and greenhouse gas emissions from synthetic fertilizer application and production). The faster these innovations get through regulatory approval, the faster they can reach farmers and start reaping yield-boosting, input-reducing, and land-sparing benefits.

Crucially, forgoing NEPA analysis will not change the way APHIS makes regulatory determinations on petitions. Nor will releasing genetically modified organisms on farms without NEPA analysis cause environmental catastrophe. Even when the agency did complete EAs, APHIS was still only able to make decisions about petitions based on its statutory authority under the Plant Protection Act: whether there is a plant pest risk. The completion of EAs on a wider variety of impacts beyond what is included in the PPRA was only ever procedural, not a factor that could legally preclude deregulation.

Broader impacts on reviews and litigation prospects

Limiting NEPA review for agricultural biotechnology will reduce the amount of time it takes APHIS to issue regulatory decisions. Prior to 2020, it took APHIS an average of 15 months to issue decisions on petitions, and almost all of these evaluations included preparation of a NEPA analysis, most often an EA.

USDA claims this rollback of regulation will “unleash innovation.” In practice, this change does mean less work for regulators and less wait time for developers. But in comparison to the agency’s reversion to legacy regulations after the SECURE rule was vacated, the burden of review will remain much higher for most products. Beyond decreasing review wait time, reducing NEPA analysis does nothing to lessen the regulatory burden on developers. The petition submission package APHIS requires developers to submit remains exactly the same, as does the types of products that are subject to review. While the SECURE rule paved the way for small and mid-sized crop breeders to benefit from a streamlined review process for transgenic crops, that progress was largely undone by the reversion to the legacy regulations. Now it’s likely only the largest developers will be able to bear the expenses of an extensive submission package and still prolonged regulatory review. The reversion to the legacy regulations is the opposite of deregulation in practice, despite USDA’s claim that they have reduced regulation by 66%.

Despite the positive impact of USDA’s revised NEPA implementing regulations on regulatory streamlining, the abrupt move away from NEPA analysis is sure to invite new litigation. Plaintiffs could argue that deregulating a genetically engineered crop, which allows its unconfined release, is a "major Federal action significantly affecting the quality of the human environment,” for which APHIS would be required to complete an environmental analysis consistent with NEPA requirements. They could contend that APHIS' decision to entirely cease NEPA analysis for petitions is an arbitrary and capricious reversal of long-standing practice. In defense, APHIS could rely on precedent set by the Ninth Circuit’s ruling in Center for Food Safety v. Vilsack (2013) and subsequent changes to NEPA. However, it’s unclear how these arguments will fare in future legal proceedings, especially given that the Supreme Court’s decision in Loper Bright limited agency discretion to interpret statutory triggers for environmental reviews.

USDA might have traded a chance at reducing review timelines for unleashing years of uncertainty on the agricultural biotech industry. If anti-GMO activists are successful in winning lawsuits that question APHIS compliance with NEPA, USDA will once again revert to its preexisting review processes and developers will be forced to keep up with an ever evolving regulatory landscape. The Trump administration has made clear its interest in unleashing innovation and rolling back regulations that unnecessarily limit the growth of American industries. To truly ease the regulatory burdens delaying safe products of agricultural biotechnology from reaching the market, USDA will have to do more than this legally-dubious attempt to cut back on a small part of the review process. USDA must think bigger and pursue politically durable ways to overhaul and modernize what products they review in the first place.

Imagine a world where crops thrive with less water and fewer pesticides, where livestock resist disease without antibiotics, and where we continue to grow more food for a growing population despite climate shocks. This isn't a distant dream; it's the tangible promise of agricultural biotechnology. From vibrant purple tomatoes engineered for enhanced nutrition and citrus armed against devastating diseases to the landmark approval of gene-edited pigs resistant to respiratory infection, biotechnology-enabled innovations hold immense potential to dramatically reduce agricultural emissions, significantly boost yields, and fortify global food security. However, realizing this future hinges on the complex, shared regulatory authority wielded by the U.S. Department of Agriculture (USDA), Food and Drug Administration (FDA), and Environmental Protection Agency (EPA), agencies charged with unlocking biotechnology’s potential while safeguarding our farms, environment, and dinner tables.

The current U.S. regulatory framework stifles innovation with overly burdensome hurdles limiting the advancement of new genetically engineered crops, animals, and microbes. Regulatory reform is needed to enable new innovations to more quickly reach the market, generating powerful returns for agricultural productivity and the environment while also accelerating American leadership in agricultural biotechnology. The Trump administration has expressed real interest in both maintaining U.S. agricultural competitiveness and rolling back regulations that unnecessarily limit the growth of American industries. In March, the White House revoked a previous Executive Order guiding the growth of the U.S. bioeconomy. This leaves the current administration with significant runway to establish their own goals for advancing innovation in biotechnology centered around deregulation. The administration could finally level the playing field for biotechnology products with conventional products, a goal that presidential administrations have tried and failed to achieve since 1992.

But, any goals to improve regulatory oversight of agricultural products produced with biotechnology are put at risk by ongoing federal workforce reductions. Since a series of probationary staff firings in President Trump’s first weeks in office, the federal workforce remains under threat. Federal agencies continue to enact deferred resignation ‘buyouts’ and the administration is pushing for pending layoffs outlined in reduction in force plans. Federal agencies recently sent their budget request to Congress, the first comprehensive summary of the new administration’s priorities for each federal office and program, as well as a look into their preferred size of government. At a high level, the President’s budget proposes a 22% cut to USDA, a 4% cut to FDA, and a 54% decrease to EPA below fiscal year 2025 levels. Sweeping reductions in staff across these agencies will stretch already resource constrained regulatory efforts that include completing technical reviews, issuing industry guidance, and developing new rules. Sacrificing deregulatory goals in favor of short-term “wins” for downsizing the federal government is a mistake.

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USDA Needs Staff to Overhaul Plant Biotech Regulations

Genetically modified crops have significantly improved U.S. agricultural productivity and reduced the need for inputs like pesticides. For example, farmer adoption of genetically modified corn in the U.S. raised yields by 17% from 1996 to 2020, while also boosting net farm income. Insect resistant genetically modified crops used with integrated pest management practices can reduce the use of broad-spectrum pesticides without compromising yields. However, despite the clear benefits of genetically modified crops, outdated regulatory frameworks fail to keep up with the pace of technology and continue to hinder innovation.

Due to the result of a years-long lawsuit over how USDA regulates plant biotechnology, the administration has a window of opportunity to relieve regulatory bottlenecks. At the close of 2024, the U.S. District Court for the Northern District of California vacated the SECURE rule, which had been in place at USDA since 2020. Accordingly, USDA’s Biotechnology Regulatory Service, the office tasked with regulating the introduction of plants developed using genetic engineering, threw out the SECURE rule and reverted back to using a decades-old regulatory review process. The old framework relies on an outdated understanding of genetic engineering that limits innovation in agriculture. Rather than continuing to operate under this outdated framework, USDA should prioritize developing new product- and risk-based regulations immediately.

Rewriting USDA’s regulatory framework will be resource-intensive and can take several years. Doing so while also managing an existing pipeline of applications, will likely require more, rather than less staff. But, the Trump administration’s pursuit of workforce reduction has already impacted the agency.

Over the course of two deferred resignation program iterations since President Trump took office, more than 15,000 USDA employees have left the agency. This includes over 1,200 staff at the Animal and Plant Health Inspection Service, which houses BRS—a loss of almost 20% of the workforce. Court ordered delays on the agency’s release of its forthcoming reorganization and reduction in force plans are likely holding back the flood gates on another round of layoffs.

Before President Trump came to office for his second term, BRS was a prime example of how regulatory efficiency can be steadily improved without the need for additional staff. For example, at the end of 2023, BRS completed less than 20% of regulatory status reviews (which are required for plants developed using genetic engineering that have not previously been evaluated to determine whether the modified plant can be safely grown and bred in the U.S.) on time, leaving 80% of applications delayed. A year later, BRS had reduced the average response time for an initial review of a regulatory status request by 145 days. Over the two year period, BRS full time staff stayed relatively constant.

The President’s budget asks Congress to keep funding for BRS flat at existing levels, but indicates the BRS team is down about 25% of staff from the start of the year. It will be crucial for Congress to maintain current resources for BRS to ensure the office can be fully staffed to continue timely review of products in the existing application pipeline in addition to developing new regulations.

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FDA Workforce Reduction Risks Slower Regulatory Review Times

Increasing animal health and productivity through disease resistance can reduce both antibiotic use and greenhouse gas emissions associated with livestock production. Most recently, FDA approved pigs with a heritable intentional genomic alteration that makes them resistant to porcine reproductive and respiratory syndrome (PRRS), which causes losses costing $1.2 billion each year in the U.S. The pigs have been genetically modified using CRISPR genome editing to remove a DNA sequence essential for the PRRS virus to cause infection. Gene editing and genetic engineering are also being used to increase cattle resistance to diseases like bovine respiratory disease, mastitis, and bovine viral diarrhea virus. According to Breakthrough's analysis, if half of the U.S. beef herd were resistant to bovine respiratory disease, about 309,000 fewer cattle would be needed to produce today’s level of beef, reducing emissions by 2.3 MMT CO2e per year. But achieving this kind of progress will require an experienced and capable workforce at FDA to review new breakthroughs before they can reach the market.

FDA’s Center for Veterinary Medicine (CVM) is tasked with evaluating the safety and effectiveness, including potential environmental impacts, of novel technologies, like intentional genomic alterations in animals. The Human Foods Program under FDA is responsible for overseeing the safety of gene-edited foods intended for human consumption. This includes oversight of the voluntary consultation process for developers of foods made with biotechnology-derived new plant varieties (NPV) to engage with the agency ahead of commercialization. The new administration has an opportunity to improve this consultation process. In 2024, FDA released new guidance that unjustifiably increased oversight of gene-edited NPVs relative to conventionally bred NPVs. FDA should course correct and ensure its regulatory processes related to NPVs are based on the risks of the end product, rather than being process-based.

According to a recent report from the National Security Commission on Emerging Biotechnology, staff at FDA’s regulatory offices were already spread thin at the start of the year. Amid a staff of nearly 20,000, the Commission estimates that FDA had less than 10 employees working on premarket oversight of plants and microorganisms produced with biotechnology. Despite this, the budget request for the Department of Health and Human Services sent to Congress includes plans to cut 534 staff from FDA’s Human Foods Program. In April, about 140 staff from CVM were fired as part of a reduction in force, adding to the earlier layoffs of probationary staff at FDA that were in their first two years of service. Several dozen were temporarily reinstated in the days that followed, including those working on bird flu response activities. The president’s budget request reflected a reduction of 124 staff compared to fiscal year 2025. In addition to layoffs of staff that directly conduct IGA animal reviews or lead NPV consultation processes, cuts to management and administrative teams could also jeopardize ongoing reviews.

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Staffing Changes at EPA Could Help Address Regulatory Backlogs

Regulatory streamlining can help new pesticides that are better for biodiversity, farmers, human health, or the environment reach the market faster. Many conventional pesticides in EPA’s review pipeline are intended to be applied to new herbicide-tolerant genetically engineered crops. EPA is also charged with overseeing biopesticides, including biochemical pesticides, microbial pesticides, and plant incorporated protectants.

EPA is touting their reductions in force and restructuring as a way to improve regulatory processes, specifically for the review and registration of new pesticides, new uses for existing pesticides, and reauthorizations. EPA’s decision to move 130 staff to its Office of Chemical Safety and Pollution Prevention, which houses the Office of Pesticide Programs (OPP), to address the backlog of 12,000 delayed pesticide registrations is a welcome step in the right direction. Of course, moving staff from one program to another doesn’t happen in a vacuum. There are well warranted concerns that prioritizing reviews will come at the cost of the agency’s independent health and environmental research initiatives. But, in a vacuum, increasing the staff capacity at OPP is especially positive given that other corners of the administration seem diametrically opposed to putting more pesticides on the market. While a federal report recently released by the Making America Healthy Again Commission acknowledged that past EPA reviews did not establish a direct link between pesticides and bad health outcomes, it alleges there is still cause for concern around specific products like glyphosate and indicates a need for more, not less, scrutiny of pesticides.

Efforts at the EPA to streamline reviews of new pesticides and to maintain science-based pesticide residue limits have the potential to enable farmers to leverage the benefits of crop protection tools with lower toxicity and environmental impacts. However, as EPA reallocates staff for OCSPP and evaluates opportunities for regulatory improvements, it must dedicate sufficient resources to adequately train staff and prioritize efforts to retain existing staff with deep regulatory expertise. Without this, the EPA risks inconsistent and unpredictable regulatory decision making.

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Prioritizing Smart Deregulation and Strategic Staffing

So far under the second Trump term, Agriculture Secretary Brooke Rollins has put forward various agriculture agendas to lower egg prices and support small and family farms. Health Secretary Kennedy has acknowledged the power of biotechnology for life sciences. But, the administration has not yet put forward a comprehensive strategy to accelerate biotechnology innovation in agriculture. The Trump administration should put deregulation at the center of their strategy, prioritizing efforts across USDA, FDA, and EPA to streamline and improve reviews of products of biotechnology that pose real risks.

To ensure efforts to cut red tape are successful, the administration needs to be forward thinking about staffing. When considering plans for future workforce reduction, the leaders of USDA, FDA, and EPA must not allow indiscriminate staffing cuts that jeopardize the government’s ability to efficiently complete regulatory reviews and pursue beneficial deregulatory efforts. This includes retaining and attracting regulators with sufficient scientific expertise. Crucially, Congress must appropriate sufficient funding for these activities in FY26 and beyond. And the Trump administration must put that funding to use under a coherent and cross-agency national biotechnology strategy.

A federal reckoning over glyphosate is imminent as the Make America Healthy Again (MAHA) movement gains a foothold with Secretary of Health and Human Services Robert F. Kennedy Jr. wielding influence across President Trump’s cabinet. Banning or restricting glyphosate use in the U.S. will either force producers to incur higher costs by turning to alternatives or worsen the environmental impacts of agriculture.

Debate over the health and environmental impacts of glyphosate, the active ingredient in a range of herbicides including RoundUp, is not new. Concerns about its potential link to health conditions like cancer have led to numerous lawsuits against manufacturers of glyphosate-based products since the 1990s. After decades of paying billions in settlements and with 67,000 pending cases, the CEO of pesticide manufacturer Bayer recently warned that the rising costs of litigation could soon force the company to stop selling Roundup in the U.S. altogether. In what is being described as a last ditch effort, Bayer, along with other manufacturers and farm groups, is lobbying for legislation in several states that would limit the extent to which they could be sued over failure-to-warn claims so long as their product labels comply with federal requirements related to human health risks set by the Environmental Protection Agency (EPA). North Dakota and Georgia were the first states to pass the legislation into law earlier this year.

Beyond the challenges posed by ongoing and expensive litigation, the MAHA movement presents another growing threat to pesticide manufacturers. Kennedy has painted glyphosate as a central villain in his messaging, in which he frequently harkens back to his legal career targeting the manufacturer of RoundUp. MAHA’s growing influence on public discourse has supporters drawing links between chronic disease and various elements of the food and pharmaceutical industries, agricultural practices, and environmental exposures. MAHA-aligned groups like Moms Across America echo Kennedy’s long held criticisms and Trump’s latest pick for U.S. surgeon general calls achieving a pesticide-free world the single most effective strategy to address health issues. This set the stage for MAHA to become strange bedfellows with environmental groups who have long stirred up fear around pesticide contamination in conventional food products and called for pesticide bans. Unfortunately for both camps, and American consumers, the research fails to show that such restrictions will lead to healthier people or a healthier planet.

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Comparing glyphosate toxicity with alternatives

Glyphosate is the most commonly used herbicide in the United States. It is applied to an average of 298 million acres or three-quarters of U.S. cropland each year according to data through 2016. A ban or restriction on the use of glyphosate in the U.S. would have the greatest impact on corn, soybeans, and cotton—90 percent of these crops are grown from herbicide resistant varieties. Should the Trump administration ban or restrict glyphosate use in American agriculture, we can expect farmers to swiftly transition to more expensive alternative herbicides. In addition to being higher cost, alternative herbicides can also have greater toxicity and lower efficacy than glyphosate.

Kennedy’s concern with pesticides centers around toxicity. He claims exposure and ingestion are linked to various health issues including non-Hodgkin lymphoma (NHL). Detractors often cite the International Agency for Research on Cancer’s classification of glyphosate as “probably carcinogenic to humans” as evidence glyphosate causes cancer. IARC’s assessment of glyphosate has been called procedurally and scientifically flawed and it overlooked one of the largest longitudinal cohort studies which followed 50,000 pesticide applicators and their spouses. The study found no association between glyphosate and any solid tumors or lymphoid malignancies, including NHL and its subtypes. Per Canada’s 2019 evaluation, “no pesticide regulatory authority in the world currently considers glyphosate to be a cancer risk to humans at the levels at which humans are currently exposed.”

The irony is that the rise of glyphosate use since the 1980s displaced other more toxic pesticides in American agriculture. Glyphosate outperforms alternatives on cost, as well as its effectiveness and relatively low application rate of 20 ounces per acre. However, toxicity needs to be considered along with effectiveness and use intensity per acre to give an accurate picture of an herbicide’s risk profile. Lower toxicity isn’t always lower risk when it comes to real world product use. For example, if a less toxic herbicide is less effective, it might be used more intensively, further exacerbating its effects. While herbicide use intensity has increased since the turn of the century, toxicity has stayed the same or decreased for many crops.

While pesticides can be toxic, human health risks are a function of exposure to a relevant dose. When it comes to acute toxicity, defined as risk associated with exposure during the application process, glyphosate has lower toxicity to humans than 94% of all alternative herbicides. Kennedy often claims, without citing any evidence, that the harms of glyphosate stem from prolonged exposure via low dose ingestion of residues in food products. Risk of prolonged exposure is measured as chronic toxicity, for which glyphosate is lower than 90% of all herbicides. USDA regularly finds that 99% of sampled food products are compliant with federal pesticide residue exposure limits, including for glyphosate. Furthermore, the majority of corn, soybean, and cotton acres in the U.S. grow commodities that are not for direct human consumption. Restricting glyphosate for crops that are used for animal feed, energy, or fiber will have absolutely no impact on health outcomes in consumers.

Today, the leading herbicides used in U.S. corn production include atrazine, mesotrione, glyphosate, acetochlor, and s-metolachlor, according to the most recent data available for 2021. For U.S. soybean production, glyphosate dominates along with 2,4-D and glufosinate. With the exception of mesotrione, all other alternatives outlined in the chart below are more toxic relative to glyphosate based on how many milligrams per kilogram of body weight needs to be injected to cause death in 50% of a test population.

Notes: LD50: A higher LD50 indicates lower acute toxicity. This is the dose that is lethal to 50% of test animals. Toxicity rating ranges from very low to high and is modeled after the U.S. Environmental Protection Agency, Office of Pesticide Programs, Label Review Manual, Chapter 7: Precautionary Statements. EIQ Value: A higher EIQ value indicates higher hazard. Source: Eshenaur, B., Grant, J., Kovach, J., Petzoldt, C., Degni, J., and Tette, J. https://cals.cornell.edu/new-york-state-integrated-pest-management/risk-assessment/eiq. Environmental Impact Quotient: “A Method to Measure the Environmental Impact of Pesticides.” New York State Integrated Pest Management Program, Cornell Cooperative Extension, Cornell University. 1992 – 2020.

Cornell University developed an Environmental Impact Quotient (EIQ) that summarizes pesticide risk to farmers, consumers, and non-target organisms in one metric. The EIQ calculation weighs chronic and acute dermal toxicity for farmworkers, chronic toxicity to account for constant potential exposure average consumers would have to pesticide residues in food and water, and acute toxicity for fish, birds, bees, and arthropods. The EIQ also considers leaching and surface runoff potential. Active ingredients assessed by Cornell have EIQ values ranging from 13 to 153. The higher the EIQ value, the greater the hazard. While limited in some respects, EIQ values provide a point of comparison. As outlined in the table above, glyphosate ranks in the middle of other leading herbicides when it comes to environmental impact.

Economic realities must be considered in addition to human health and environmental impacts. A recent report, commissioned by Bayer, found that alternative crop protection products can cost producers up to 2.5 times the cost of glyphosate on a per acre basis. An independent 2021 study modelled the economic impact of a hypothetical tax, as a proxy for regulation, on glyphosate in U.S. corn production. The researchers found that even a modest 10% tax on glyphosate, projected to reduce glyphosate use by about 5%, would result in $98 million in annual losses due to increased costs for farmers and decreased corn production. They find that the market economic loss from restricted weed control outweighs any human health and the environmental benefits achieved by switching to alternatives. Notably, the results indicate farmers would not be able to fully compensate for glyphosate restrictions with alternative herbicides. While a reduction in glyphosate use would lead to a modest increase in the use of other herbicides, this substitution is found to be relatively small and not sufficient to offset the reduction in glyphosate, suggesting substitutes aren’t as available or effective.

A lack of sufficient herbicide alternatives could lead farmers to increase mechanical management of weeds through tillage. However, the costs of shifting toward tillage would be nearly double the cost of buying and applying glyphosate. Such a shift would increase production costs for corn, wheat, soy, and wheat by almost $2 billion. To boot, tillage is a practice criticized by regenerative agriculture supporters, including recently announced nominee for U.S. surgeon general Casey Means, for increasing risk of soil erosion and release of carbon stored in soils, as well as for associated fossil fuel emissions.

Meanwhile, glyphosate and glyphosate tolerant crops have contributed to the adoption of reduced tillage practices in U.S. soybean and corn production. The introduction of glyphosate-resistant corn and soybean, coupled with the application of glyphosate, is credited in one study with preventing at least 41 billion pounds of carbon emissions between 1996 and 2013. Stripping U.S. farmers of crop protection tools will jeopardize the fact that over half of U.S. cropland today is managed with reduced or no-till practices.

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Let’s all just go organic instead?

Conceivably the Trump administration might not only focus regulatory action on glyphosate, instead targeting a wider swath of synthetic pesticides. Groups like the Center for Biological Diversity recommend the administration revoke EPA tolerances for atrazine, glyphosate, 2-4,D, neonicotinoids, paraquat, and organophosphates and enact policies that would incentivize U.S. agriculture to shift to organic production methods.

A nationwide shift to organic agriculture in the wake of a broad pesticide ban is practically impossible due to a range of systemic constraints. First, organic farming typically produces lower yields, requiring more land to produce a given amount of food. Differences in yield are especially pronounced for certain commodities including wheat. Second, there is not nearly enough manure in the U.S. to fertilize all crops in place of synthetic fertilizers. Therefore, shifting to organic production would also require additional land to produce manure or to grow legumes and other nitrogen-fixing crops that provide needed nutrients. Lastly, organic production is often more costly. Although organic price premiums may enable farmers to make up for the elevated cost of production of farming organically, price premiums can fluctuate. The magnitude of shifting a significant percentage of U.S. farmland to organic can’t be understated. Less than 1 percent of U.S. cropland and pasture is certified organic. Organic sales only made up about 5.5 percent of all retail food sales in 2021.

Even if successful, a shift to using organic alternatives to control weeds, pests, or diseases would not eliminate synthetic pesticide use in agriculture outright. Nor would it necessarily reduce the overall toxicity of agricultural inputs since organic alternatives for weed control are not always less toxic. Whether organic producers use more or less pesticides in terms of volume than conventional production depends on the crop. And the toxicity of organic pesticides can be higher than synthetic alternatives even if the amount applied is orders of magnitude less. For example, organic production of grapes, potatoes, tomatoes, apples, citrus, and stone fruit in the U.S. continues to be reliant on copper sulfate, which is a synthetic chemical allowed under organic standards set by USDA to combat fungal and bacterial diseases. Copper sulfate has a very high LD50 acute toxicity of 450 mg/kg. According to the European Chemical Agency, copper sulfate is “very toxic to aquatic life” and its use has been shown to result in significant consequences to biodiversity. Alternatives to synthetic herbicides that can be used in organic production include clove oil and acetic acid (high concentration vinegar). These non-synthetic herbicides are contact herbicides, meaning they disrupt the cells in the plant tissue they come into contact with, therefore requiring precise and often more frequent application to kill the entire plant. Glyphosate, on the other hand, is a systemic herbicide that disrupts biological processes throughout the plant once absorbed, killing the weed in one go. Glyphosate has a total EIQ value of 41.33. In comparison, acetic acid has a higher hazard value at 45 due to higher potential risks to farmworkers and consumers.

Europe is often venerated by MAHA enthusiasts as having an enviable precautionary regulatory regime for food additives, chemicals, and ingredients. Even President Trump recently asserted that U.S. agriculture is “probably heading towards [the United Kingdom’s] system with no chemicals” under Kennedy’s direction, though the UK does not have a “no chemical” food system. Rather than a beacon, policymakers should view Europe’s farming policy objectives as a cautionary tale. The EU’s Farm to Fork strategy, for example, includes the goal of shifting 25% of production to organic farming. Critics warn such a shift will cause the EU to increase its imports of agricultural products, offshoring environmental damage to other nations, particularly in South America. USDA found that the EU’s plan to increase organic production would increase consumer costs and worsen food security. Other countries have also grappled with these tradeoffs. These exact consequences of a dramatic shift to ban synthetic agricultural inputs were born out in Sri Lanka in 2022. The Mexican government postponed their ban on glyphosate citing concerns that the government has yet to identify an alternative that can replace glyphosate without sacrificing productivity.

Policies that incentivize transitions to organic production, sans synthetic inputs like pesticides and fertilizers, would not only place economic burdens on farmers, but would also have environmental consequences when it comes to spurring increased land used to compensate for yield losses and persistent nitrogen needs. Given the cautious optimism expressed by left leaning environmental organizations that the MAHA wave might be well enough aligned with their goals to be worth jumping on, it’s worth emphasizing the climate consequences of banning synthetic pesticides like glyphosate in favor of organic systems. In large part due to lower on average yields compared to conventional production, a global shift to organic production is projected to lead to a 16-33% increase in land use and a corresponding 8-15% increase in worldwide deforestation.

Without worldwide conversion to vegetarianism, which is next to impossible per current trends, and substantial reductions in global food waste, increasing the share of global agriculture under organic production beyond the 2% it occupies today is expected to increase greenhouse gas emissions from agriculture.

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Kennedy’s influence spurs industry action and concern in Congress

Announcements made by President Trump’s USDA and HHS so far have proven more aligned with MAHA moms, far left environmentalists, and consumer protection groups than Republicans in Congress would have hoped. A recent letter from GOP members called on Kennedy and other agency leaders involved in the MAHA Commission to reject misguided health solutions and instead put forward policies supported by sound science and risk-based analyses. The lawmakers emphasize the importance of weighing the role well-regulated agricultural inputs like pesticides play in keeping food prices low and farming profitable.

It’s clear pesticide manufacturers like Bayer and farmers that rely on low toxicity chemical inputs like glyphosate are hinging their strategy on EPA, who has deemed glyphosate as safe for decades and is not under Kennedy’s jurisdiction. This might prove a losing strategy.

Bayer’s multi-state campaign seeks to ensure states defer to the Environmental Protection Agency’s authority over pesticide labeling. That is, if the label on Roundup is approved by the feds, Bayer would be insulated from pesticide injury lawsuits that claim the manufacturer failed to warn users of the product’s health risks. Bayer and other agriculture industry groups also support federal action to shore up the statute that preempts states from adding their own pesticide labeling requirements. If passed, this would provide pesticide manufacturers more consistent regulatory clarity and likely lessen their legal liability. But, with a farm bill still a long way off, it’s clear Congressional action is sure to move more slowly than state legislatures, if at all.

While Kennedy does not oversee the EPA, his role as HHS Secretary grants him considerable influence over public health policy which can interact with environmental regulations. His influence at the cabinet level and interest in shaping policies and programs outside of HHS jurisdiction should not be underestimated. An EPA that abandons reliance on scientific evidence and instead caters to loud calls from activists to ban pesticides in the name of health would disrupt the status quo, rendering any legislative proposals that affect EPA regulations entirely ineffectual.

Look no further than the Food and Drug Administration which has become unrecognizable in a matter of months under Kennedy. The once-cautious agency has said it is considering significant food ingredient policy changes—starting with food dyes like Red 40—without any of the typical processes, like posting a regulatory notice for comment, and top officials blatantly contradicting decades worth of the agency’s prior risk assessments. Food dyes are just the start of a long list of supposed “poisons” in the U.S. food supply Kennedy is keen to address. One can expect current efforts to target food dyes to give way to scrutiny over other ingredients and inputs, like glyphosate, with further reaching implications for the stability and sustainability of our nation’s food supply.

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Up next for the MAHA Commission

The MAHA Commission, established by executive order at the start of President Trump’s second term, was tasked with releasing an initial assessment followed by a comprehensive federal policy strategy to end childhood chronic disease. The Commission was directed to focus, in part, on food production techniques and “food ingredients, certain chemicals, and certain other exposures.”

The Commission’s initial assessment outlined several environmental exposures that could impact child health, including crop protection tools with an explicit mention of glyphosate. The report’s discussion of pesticides was considerably more balanced than Kennedy’s past rhetoric regarding their risks, but leaves the door open for more drastic measures in the future. The Commission notes that some studies have raised concerns about possible links between crop protection tools and adverse health outcomes in children but recognizes that instigating a sudden change to production practices and inputs could jeopardize agricultural production and the global food supply. The Commission also contends that, when it comes to pesticides, EPA has a robust risk- based approach to consider risks to human health and the environment. Despite these assertions, the Commission doesn’t rule out the possibility of further regulating or restricting crop protection tools.

The report makes a promise to not go beyond risk- and scientific processes without “thoughtful consideration,” indicating the administration could take actions that aren’t based in science or that go beyond congressional authority. The Commission perpetuates the idea that if there were natural alternatives to synthetic products that had similar efficacy and cost, those alternatives would be preferred. The entirety of the report appeals to the nature fallacy by questioning the safety of synthetic chemicals in the U.S. food and agriculture system. The report fails to acknowledge the environmental and human health benefits of synthetic crop protection tools. Holding costs and efficacy constant, some synthetic pesticides will prove superior across other important factors like toxicity, application rates, and environmental persistence. Pesticides are also an important part of fruit and vegetable production, keeping fresh produce an affordable part of children’s diets. Comparisons across this range of factors are worth making, but should adhere to, rather than abandoning, sound science.

The MAHA Commission will now turn to drafting a policy agenda to address the disease drivers identified in its initial assessment. As the Commission considers proposals relevant to research initiatives, the forthcoming update to the Dietary Guidelines, or regulatory actions, the Commission should prioritize supporting farmers in reducing the impacts of pesticide use without sacrificing yields.

USDA should support the research, development, and adoption of technologies and products that enable both organic and conventional producers to reduce the toxicity of pesticide use, either by using less or employing products with better efficacy and lower toxicity. USDA conservation programs should be leveraged to scale the use of precision agriculture technologies to improve application of synthetic pesticides. Federal research dollars should be dedicated to developing less toxic alternatives to use in organic production systems, such as alternatives to copper sulfate to better fight fungal and bacterial diseases. In addition, the Commission should propose that federal agencies support public and private plant breeding programs to develop crop varieties that have improved pest and disease resistance, reducing the need for pesticides.

When it comes to evaluating the effects of agricultural pesticides on human health and determining pesticide residue limits, it is imperative that the Commission rely only on science backed human health risks and differentiate risks based on acute vs. chronic toxicity levels. The Commission should emphasize the importance of EPA putting adequate staffing and resources behind farmworker pesticide surveys and USDA continuing work under its Pesticide Data Program (PDP). Activities led by PDP include sampling, testing, and reporting of pesticide residues on agricultural commodities in the U.S. food supply.

All of the Commission’s proposals should appropriately weigh the extent to which pesticide bans or restrictions would incentivize substitutions with more toxic products or lead to declines in agricultural productivity and increases in food prices. Implementing policies that fail to anticipate these follow on effects would not only have food security implications at home, but also jeopardize America’s global leadership as a food exporter. Further, the Commission should refrain from asserting misleading links between the use of glyphosate in non-food crops, dietary exposure, and human health outcomes.

Ultimately, the Commission must resist the urge to center agricultural practices and inputs as a silver bullet for addressing disease. Employing a narrow focus on specific on-farm agricultural inputs, like glyphosate, and attributing chronic health conditions to agricultural production techniques is not only misguided but detracts from public health interventions that could actually curb rates of chronic illness.

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Thank you to Jon Entine, Executive Director of the Genetic Literacy Project, for contributing feedback on this article.

With the establishment of the President’s Make America Healthy Again Commission, the MAHA movement is taking aim squarely at industrial agriculture. Its leader, and now Secretary of Health and Human Services (HHS), Robert F. Kennedy Jr. champions seemingly noble causes like ending childhood chronic disease and promoting health rather than managing disease. But Kennedy's single-minded focus on certain foods, chemicals, and processes is based on thin scientific evidence and overly simplistic assumptions about the relationship between agricultural systems and food-related health outcomes. There is little reason to believe that his proposals to restrict or regulate these food production practices will measurably improve public health or environmental outcomes in the United States. Worse, should Kennedy succeed in implementing his agenda, he risks making America's food supply less healthy and more expensive—undermining the Commission’s own objectives.

Prior to his confirmation, there were hopes that Kennedy’s vision for American agriculture would be less extreme than many of his past statements have suggested and that Secretary Brooke Rollins would provide a counterweight to Kennedy at USDA. But early returns have not been promising. In his first speech at HHS, Kennedy emphasized nothing will be off limits including “glyphosate, other pesticides, ultra-processed foods, artificial food additives." Meanwhile, Rollins has publicly identified herself as a “MAHA mom.”

President Trump’s executive order creating the MAHA Commission promised to “prioritize gold-standard research on the root causes of why Americans are getting sick.” But when it comes to things like agricultural chemicals and seed oils, Kennedy is intent on ignoring evidence that contradicts his claims. This disconnect between MAHA's stated health goals and its narrow focus on certain food production practices is setting MAHA up to fail, diverting resources away from more serious public health threats and making healthy foods less affordable and accessible to the American public.

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Hyperfocus on pesticides

Kennedy has long been a vocal critic of industrialized agriculture, consistently alleging that farmers are poisoning Americans. He frequently links chronic diseases to the "intensity of chemical pesticides" used in farming, emphasizing the need to shift away from pesticide use toward regenerative practices. His criticisms are largely focused on the dangers of pesticides, like glyphosate, asserting that their widespread use in farming causes a litany of cancers and other diseases. However, the U.S. continues to approve the use of glyphosate, finding that it is “not likely to be carcinogenic to humans” and that it poses “no other meaningful risks to human health when the product is used according to the pesticide label.” The European Union also continues to approve glyphosate’s use, citing lack of substantial scientific evidence linking it to harmful effects on human health or the environment.

The impacts of pesticide use on human health are heavily debated topics with mixed scientific evidence. Claims that glyphosate is responsible for increasing rates of celiac disease and gluten intolerance are widely disputed. Research linking glyphosate to other potential health issues like DNA damage, inflammation, liver and kidney damage in animals, increased risks of non-Hodgkin’s lymphoma (NHL) in farmers, is also contested. While a 2019 meta-analysis of human epidemiological studies found a compelling link between glyphosate and increased risk for NHL, a recent systematic review and the most recent Agricultural Health Study which used a cohort approach both came to the opposite conclusion.

It’s crucial to assess risks of pesticide overuse in context, considering factors such as dosage, exposure levels, and toxicity. As an example, some epidemiological studies linking glyphosate to health issues use measures of urinary glyphosate concentrations. But urinary measures reflect recent short-term exposure, not cumulative exposure over time, and the presence of glyphosate alone does not mean the chemical is causing disease or other adverse effects. Clear associations between urinary glyphosate levels and health outcomes can be hard to establish due to significant variability in how glyphosate shows up in urine samples thanks to factors like hydration, diet, how long it's been since your last meal, and kidney function. More broadly, epidemiological studies are limited in their ability to establish causality, especially if a study doesn’t account for other confounding factors, like lifestyle or genetics, that can contribute to the onset of certain health conditions.

Conclusions from studies that rely on in vitro models or that use higher exposure levels than those typically encountered by average consumers should also be taken with a grain of salt. For example, the study that found a link between glyphosate exposure and DNA damage arrived at that conclusion after researchers exposed human blood cells in a laboratory setting to concentrations of glyphosate that are more than 80 times greater than EPA's pesticide residue limits for foods like grains, fruits, and vegetables. The study's findings suggest that significant DNA damage or methylation changes occur only at concentrations far higher than what is expected in real world scenarios. More research is needed to fully understand the long-term effects of low-level exposure that real world consumers are likely to be exposed to or ingest via their diets, especially when it comes to chronic or cumulative effects.

For now, EPA’s conclusion, based on the literature and extensive analysis available today, is that glyphosate does not pose a significant risk to consumers at current exposure levels. EPA’s risk-based approach to setting these levels enables farmers and consumers to reap the benefits. Though pesticide use has increased for some crops over the last two decades, there has not been a corresponding increase in overall toxicity, due in part to the shift toward glyphosate as a replacement for older, more toxic products. Further, the quality of agricultural pesticides has improved over time and precision agriculture technologies—like sensors, variable-rate applicators, and GPS-based yield mapping—enable farmers to reduce pesticide application rates without sacrificing yields. Elevated exposures experienced by farmworkers point to greater need for these technologies to be more widely adopted.

While Kennedy’s stance on glyphosate highlights broader concerns about pesticide use in agriculture, it's important to recognize that the alternatives he proposes are no better. Organic and regenerative farming methods may avoid the use of synthetic pesticides like glyphosate but they are not pesticide-free. Organic systems often employ natural pesticides that can still leave residue and in some instances have even higher dose-response toxicity rates than synthetic options. Moreover, organic foods are not proven to be universally safer, healthier, or more environmentally-friendly. Furthermore, it is clear that without synthetic pesticides and fertilizers, organic foods cost more to produce and often cost at least 20% more in grocery stores than non-organic produce. Shifting more of American agriculture to organic production, would increase prices for fruits, vegetables, meats, and other foods conventional nutritional wisdom, and presumably MAHA, would suggest Americans need to eat more of. Higher prices would disproportionately impact lower-income households with already reduced access to affordable fresh produce options.

Regardless, Kennedy has called for a large-scale transition to “regenerative, no-till, and less chemically intensive agriculture.” It is not at all clear that no-till or other regenerative practices would help make food healthier for end consumers. Practices like no-till farming and cover cropping are championed by some for their potential benefits to soil health, including by reducing erosion and enhancing water retention. However, the direct link between soil health and the nutritional profile, or “healthiness”, of crops remains unclear.

While soil quality may influence the overall viability of crops, variations in environmental factors and agricultural techniques make it difficult to draw concrete conclusions about how these factors impact human health. Evidence linking specific soil health factors with a food crop’s macro and micronutrient content is weak. According to a recent report, comparative studies have failed to find consistent links between soil health, management practices, and nutritional quality of food grown in either conventional or organic production systems. The nutritional quality of food is also heavily influenced by food processing, casting further doubt on Kennedy’s attempts to connect agricultural management strategies directly to human health outcomes. Without evidence of conclusive links between soil health and chronic disease trends, it's hard to see how policy decisions pursuant to farming practices would fall within Kennedy’s purview at the helm at HHS to begin with.

For all of these reasons, it's imperative that Kennedy and leaders of USDA and EPA employ a science and data-driven approach to the MAHA Commission’s work. This should include and take into account the importance of pesticides in keeping yields high and food prices low.

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Seed oils and ultra-processed foods

While Kennedy’s criticism of agricultural practices and pesticides highlight his delusion that farming techniques are driving human health outcomes, his concerns also extend to food processing and manufacturing methods. He argues seed oils, including soybean and canola, are among the most harmful ingredients in modern foods. Kennedy claims that seed oils contribute to a wide range of health problems, including obesity and chronic inflammation. In a 2024 interview, he stated that seed oils are "heavily subsidized" and pointed to their ubiquity in processed foods as proof they are driving the obesity epidemic. Kennedy has elevated beef tallow as a preferable alternative.

Kennedy’s views on seed oils reflects a broader critique of food processing, with an emphasis on returning to "natural" food sources over industrially refined products. The extraction process for oils like soybean, canola, and sunflower involves mechanical pressing or the use of chemicals, followed by refining steps like bleaching and deodorizing. Critics like Kennedy argue that these processes strip the oils of their nutrients. Proponents of seed oils maintain that modern refining methods are safe and produce oils no more "unnatural" than other widely used cooking oils, such as olive or coconut oil.

The debate about the “health” of seed oils largely revolves around their omega-6 fatty acid content, with Kennedy and his allies asserting that ingesting these compounds causes chronic inflammation. However, research on the health effects of seed oils paints a different picture. A 2012 review of 15 randomized controlled trials found no evidence supporting the claim that omega-6 fatty acids, found in seed oils, contribute to inflammation. In fact, a 2017 meta-analysis of randomized controlled trials concluded that increased intake of linoleic acid from seed oils did not significantly affect inflammatory markers. Several studies instead suggest that replacing saturated fats with seed oils can offer health benefits. For instance, a recent cohort study from Harvard University found that replacing butter with plant-based oils was associated with lower mortality rates. Additionally, a meta-analysis showed that substituting animal-sourced saturated fat with vegetable oils rich in linoleic acid was linked to a reduced risk of heart disease and death from heart disease. The American Heart Association has also supported replacing saturated fats, like butter, beef tallow, and lard, with omega-6 fats to lower heart disease rates.

Kennedy and the MAHA movement’s focus on seed oils stems, in part, from a broader pushback against “ultra-processed foods.” There is consensus that heavily processed foods that have more salt, sugar, and calories are worse for the consumer—mainly because they are easily over-eaten and can displace consumption of foods with higher nutrient density. But, the term "ultra-processed" has become so expansive and imprecise it has limited usefulness.

The imprecise nature of the term "ultra-processed" undermines its effectiveness as a marker of food quality or whether it can be easily pinned as the culprit responsible for obesity rates. Not to mention it's already proving too vague a category to regulate. While it is true that many processed foods are linked to worse health outcomes due to their higher calorie content and low nutrient density, other processed foods, such as breakfast cereals and yogurt, don't fit this pattern. A major study from the National Institutes of Health found that people eating an ultra-processed diet consumed more daily calories on average. Researchers speculate this is due to the higher energy density of ultra-processed foods. It may therefore be more effective to focus on addressing specific risk factors like nutrient density, sugar, and salt content, rather than focusing on the extent or type of food processing. MAHA’s emphasis on the dangers of ultra-processed foods does nothing more than provide a vague, and therefore expansively overwhelming, directive to consumers.

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If not food production techniques, then what?

If the Trump administration launches its MAHA strategy on the back of Kennedy’s misguided pursuit of getting fast food chains to replace vegetable oil with beef tallow and eliminating trace amounts of pesticides in the food supply, it will amount to little more than window dressing. MAHA’s proposed alternatives to modern food production inputs and techniques not only illustrate a complete unwillingness to grapple with the consequences of setting U.S. agriculture back when it comes to on-farm productivity, food security, and food prices. Their proposed alternatives can’t even be called healthier.

Kennedy’s focus on seed oils in particular is largely a distraction from the added sugars, sodium, refined carbohydrates, and saturated fat already dominating the junk food aisle and fast food menus. Americans eat out more than ever, restaurants are increasing portion sizes and calories per meal, healthier foods cost more, and snack food companies’ large marketing budgets are all more prevalent factors contributing to today’s high obesity rates.

The risk of presenting the elimination of pesticides from our farmland or seed oils from our diets as silver bullets to combat a very real chronic disease epidemic is that it will allow this administration to sidestep solutions to combat the real drivers of poor health outcomes plaguing Americans.

Improving public health will require moving past the seed oil debate. Federal agencies like USDA and FDA will need to spearhead and promote solutions that are far less popular than what’s trending on MAHA TikTok. Making Americans feel better by RFK’ing their fries is always going to be more appealing than recommending less fried foods in one’s diet, reducing intake of sodium and added sugars, encouraging more physical activity, grappling with the Trump administration’s trade fiascos, or figuring out how to enhance agricultural productivity.

The MAHA Commission should carefully weigh whether to indulge Kennedy’s personal persuasions over data-based reasoning as they develop their forthcoming assessment and strategy. Favoring the former will doom any chance the Commission has at meaningfully improving health and nutrition outcomes. Sweeping restrictions to our nation’s agricultural inputs and rolling back advances in food processing risks far more in terms of food security than it stands to gain in public health advances.

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By Emily Bass

The early days of Donald Trump’s second presidential term saw a record number of executive orders, an almost immediate freeze on federal funding, and a swift, yet indiscriminate, hollowing out of the federal research workforce. While the White House frames these moves as “much-needed reforms,” they undermine American innovation and appear to contradict the administration's stated priorities.

Protecting U.S. innovators and unlocking the power of technology are consistent themes across recent White House’s statements on everything from artificial intelligence to fintech to energy. This flurry of America First announcements, however, were punctuated with abrupt and seemingly uncoordinated efforts to shrink the scientific workforce. Dismissals and agency directives for future layoffs have come from the White House, the Office of Personnel Management, and Elon Musk via various X accounts leaving no corner of government untouched.

The U.S. Department of Agriculture (USDA) has been significantly impacted by workforce reductions. USDA terminated federal employees serving in its Animal and Plant Health Inspection Service, Food Safety and Inspection Service, and Natural Resource Conservation Service, leaving local NRCS offices across the country understaffed. Agricultural Research Service (ARS) staff experienced layoffs to the tune of some 800 employees, with probationary staff hit particularly hard. ARS is USDA’s chief in-house research agency with more than 90 research units and laboratories spanning 42 states.

After slashing the ARS workforce by more than 10%, USDA scrambled to rehire scientists there and in other offices working on avian influenza. A sporadic round of reporting in the days that followed indicated that ARS scientists, but not technical support staff, were being widely reinstated across sites, including those working on plant breeding in California and at the National Bio and Agro-Defense Facility in Kansas. Still, sites like the U.S. Dairy Forage Research Center in Wisconsin say they are not fully operational.

Other impacted federal research networks overseen by USDA include the National Animal Health Laboratory Network and the nation’s gene banks, which house collections of seed varieties and living crops that researchers use when breeding new crop varieties. With additional guidance from the White House foreshadowing large-scale workforce reductions still to come in March and April, these labs are bracing for a continued layoff whiplash.

The fluctuation of ARS staffing, as well as the broader funding freeze on grants, is also impacting agricultural research programs at land grant universities across the country. ARS sites are often co-located with public land grant institutions, with both benefiting from shared resources and often partnering on research efforts.

Agricultural research initiatives led by public land grant universities have also been affected by the rollback of USAID-sponsored research funding. Over a matter of weeks, USAID was systematically dismantled but in a final blow, the Trump administration shuttered 21 USAID-funded Feed the Future Innovation Labs. These labs were co-located at land grant institutions, like Kansas State University, University of Illinois, and Michigan State University, and were tasked with conducting specialized research on agricultural challenges that disrupt the global food supply, including food safety, post-harvest losses, and pest and disease management.

While the scale and pace of President Trump’s actions are unparalleled, the impact of cutting support for public agricultural research is all too predictable. Past government shutdowns have hindered ARS sites’ ability to continue data collection and reporting. Shutdowns can disrupt ongoing experiments and long-term research projects that benefit farmers. Delays in research timelines can be detrimental and costly to time-sensitive experiments, especially those tied to planting seasons. Furthermore, pausing or altogether halting in-process research studies is a significant waste of government resources. This can lead to the sacrifice of any concrete results after sinking multiple months or years of grant funding, staff time, and other resources into a project.

Further workforce reductions and ongoing funding freezes for research grants risk doing the same with far-reaching consequences for the agriculture sector. Agricultural economists have found that the long-term decline in public agricultural research funding has slowed improvements in U.S. agricultural productivity. The Trump administration should bear these lessons in mind as they consider whether to further reduce or otherwise hamstring the nation’s public agricultural research capacity.

Ironically, the Trump Administration’s first major announcements related to food and agriculture—establishing the Make America Healthy Again Commission and revealing a strategy to combat avian influenza—put research front and center. The administration needs a strong USDA research workforce and functioning laboratories to accomplish their outlined goals. Farmers concerned with how Robert F. Kennedy Jr.’s MAHA agenda will restrict their ability to use key agricultural inputs like pesticides and consumers worried that the unchecked spread of avian influenza could keep egg prices volatile or metastasize into another pandemic should be wary of how this administration plans to deliver comprehensive research strategies with frozen resources and insufficient staffing.

The long-term consequences of funding and staffing cuts are clear. When agricultural research funding dries up, farmers lose access to innovations that improve yields, resilience, and profitability. Universities may be able to mitigate some of the impact by finding new private or philanthropic funding sources if federal grants stay frozen. But, the White House and USDA’s actions in the coming weeks will be consequential for the U.S. research enterprise: Will they take an inconsistent approach to U.S.-led innovation that leaves agriculture behind, allowing vital research institutions to wither? Or will they strengthen these institutions, and U.S. agricultural competitiveness in the process?

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By Emily Bass

Robert F. Kennedy Jr. appeared before the Senate Finance and HELP Committees last week as President Trump’s pick to lead the U.S. Department of Health and Human Services (HHS). After more than 6 hours of questioning, Kennedy made his beliefs about food and agriculture crystal clear. He doubled down on his beliefs that the way farmers grow food is poisoning Americans, emphasized the need to phase out use of chemicals in agriculture and made contradictory statements around his plans to work with farmers as he implements a Make America Healthy Again (MAHA) agenda at HHS.

Farmer and agriculture industry groups, with the exception of Farm Action, were remarkably silent in the lead up to Kennedy’s appearance before Congress. While we at the Breakthrough Institute warned Senators about the risk of allowing Kennedy to implement his vision for the future of farming—one that limits farmers’ access to inputs key to maintaining yields and escalates baseless fears around biotechnology—agriculture interest groups took a wait and see approach. Any hope these groups had that Kennedy’s closed door meetings with Senators from top agricultural states in the lead up to his hearings would sway his leanings on industrialized agriculture or otherwise convince him of the importance of pesticides, fertilizers, and gene editing technologies should now be dashed.

Throughout his two nomination hearings, Kennedy attempted to walk back his previous public statements on vaccines, but on agriculture issues he doubled down, making no attempt to tamp down his unscientific claims. The fact of the matter is that RFK Jr. is exactly who we have said he is. His unscientific positions of health, food, and farming are reckless. If he does end up leading HHS, the consequences for the future of U.S. agriculture are real and worrying.

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In response to questions in both hearings about how he would support farmers, Kennedy lamented that we “cannot export American food to Europe,” that the “Europeans won’t take our food,” and that we need to “offer farmers an off ramp to chemically intensive agriculture… so they can grow crops that they can sell in Europe.” Europe is the 5th largest export destination for U.S. agricultural products. The insinuation that current U.S. farming practices, such as the use of pesticides, are standing in the way of U.S. crops being exported to Europe is false. Both organic and non-organic agricultural commodities are sold to Europe today. Existing trade agreements allow USDA certified organic products access to the EU’s market, but conventional, non-organic U.S. commodities are exported to the EU as well. For example, the EU is one of the largest export destinations for U.S. soybeans, second only to China as of 2023. Almost all U.S. soy exports to the EU are conventionally grown.

In response to a question from Finance Committee member Senator Roger Marshall (R-KS) on how he feels about farmers and ranchers, Kennedy claimed “we only have 60 harvests left,” blaming deteriorating soil health. His claim that most millennials and all gen z-ers will, in their lifetime, experience the end of agricultural production is a myth, first raised in 2014, that has been thoroughly busted. A majority of soils, even those managed with intensive agricultural practices, have many hundreds, if not thousands of years of harvests left.

Reiterating this apocalyptic and unscientific claim alone should spark concern coming from the potential head of one the world’s largest scientific research organizations. His attempt to leverage this unfounded claim to justify dramatic changes to modern farming practices should raise even greater alarm bells for U.S. agriculture.

Kennedy went on to say farmers are using seeds and chemicals that are making them and Americans sick and that “we should incentivize transitions to regenerative and no-till agriculture and to less chemically intensive agriculture.” In the HELP hearing, he reiterated “there is illness all over the farm community” that is “undoubtedly related to the intensity of chemical pesticides,” emphasizing the need to limit pesticide use.

It is not at all clear that no-till or other regenerative practices would help U.S. farmers reduce the use of pesticides, or in any way improve access to the European market. Many farmers practicing no-till still use herbicides. In fact, practicing no-till on corn and soy operations often rely more heavily on the use of herbicides, like glyphosate. Ironically, Kennedy has been a stark opponent of glyphosate often asserting its use in farming causes a litany of cancers and other diseases. (To note, both the EU and the U.S. continue to approve the use of glyphosate finding no scientific evidence of harmful effects on human health or the environment.)

Incentivizing a sweeping transition to organic practices—not explicitly mentioned by Kennedy during the hearings but an idea he has repeatedly pushed in past appearances—could enable more U.S. crop exports to the EU, however, it would be to the detriment to overall yields and output. This tradeoff is one worth grappling with. Organic agriculture, on average, is about a fifth less productive than conventional agricultural production. Practices commonly called “regenerative” like cover cropping often have yield penalties.

Kennedy’s proposed transition, and its expected yield penalties, is not necessarily one that U.S. farmers want, despite Kennedy’s implications that this is the case. Kennedy fails to reckon with the economic realities facing food production today, the costs to farmers to transition operations to organic, and how a Republican administration already wary of public spending could feasibly stomach subsidizing such a transition.

Prioritizing production practices with the sole goal of exporting more organic products to Europe at the expense of decreasing total U.S. food production and lowering agricultural exports overall does not align whatsoever with the Trump White House’s America First agenda. Estimates indicate global agricultural productivity growth needs to double to sustainably meet global food demand by 2050. As pressure mounts to reverse slowing productivity growth rates worldwide, investing in a transition that compromises yields will not enable U.S. agriculture to lead globally. Instead, farmers should be doubling down on ways to grow and export more, while minimizing the need for cropland expansion.

Decreasing U.S. agricultural productivity specifically risks ceding our role as the world’s leading food exporter to competitors like Brazil, China, and Russia who are seeking to grow export markets not just in Europe, but especially in countries with rising populations, GDPs, and food demand.

During both hearings, Kennedy reiterated that the chemical industry, fertilizer giants, and herbicide companies agree with his ideas. Yet, agricultural input manufacturers have not raised a finger to back up Kennedy’s proposals. In fact they have actively pushed back against misinformation surrounding farm inputs and emphasized that the use of pesticides remains critical for sustaining yields and food security.

Kennedy’s interest in erasing decades of progress in U.S. farming is abundantly clear. However, Kennedy did not offer up concrete proposals for whether or how he would leverage HHS agencies and programs to address any of the “problems” he raised. No Republicans, or Democrats for that matter, pressed him to do so.

Republicans seem to be burying their heads in the sand, not just on ethics concerns or Kennedy’s waffling views on vaccines, but also on the role HHS, and more specifically FDA, plays in regulating agriculture and the food system. At HHS, Kennedy could restrict pesticide use by more strictly enforcing residue limits, imposing inordinate testing requirements, and pressuring EPA to deny new pesticide registrations or revoke existing approvals for products like glyphosate. He could influence approvals of new biotech animals via FDA regulations and meaningfully obstruct the whole of government response needed to reign in avian flu.

The highly pathogenic avian influenza (H5N1 or “bird flu”) sweeping through U.S. poultry populations has sent the price of eggs skyrocketing. The disease has now spread to 16 states across hundreds of dairy herds, with public health experts calling for pandemic preparedness in case it eventually spreads to the general public.

Kennedy has referred to the disease as a “lab-grown plague” and cast doubt on human vaccines, which are still under development, being safe or effective. Suspending research on H5N1, disrupting vaccine programs, or halting pandemic readiness activities would have significant consequences for poultry and dairy producers, as well as the health of the general public.

Senator Chuck Grassley (R-IA) told Kennedy he expected him to stay away from agriculture altogether, to “leave agricultural practice regulations to the proper agencies,” being USDA and EPA. Senator Steve Daines (R-MT) asked Kennedy to commit to working with USDA before implementing any policy that might affect or impact the food supply. Kennedy’s agreement to the latter was met with nods and murmurs of agreement.

Despite initial sighs of relief, this promise of cooperation should spark concern for farmers and consumers alike. Republicans clearly hope other administration leadership, like Brooke Rollins at USDA, will box in Kennedy’s influence on agriculture. But cross-agency coordination goes both ways. Ignoring the risk that, if confirmed, Kennedy’s pervasive MAHA views will seep into USDA or EPA could backfire. Confirming his nomination could be the starting gun to administration-wide efforts to reform U.S. agriculture in ways that considerably jeopardize national food security and American leadership in export markets.

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