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This document provides guidance to food manufacturers on how to improve labelling of caffeine present in prepackaged beverages using a voluntary approach.
Provisions currently exist in the Food and Drug Regulations for the use of caffeine and caffeine citrate as food additives in cola type beverages at a maximum level of use of 200 ppm in the finished product. In addition, an Interim Marketing Authorization (IMA) is being issued to permit the immediate use of caffeine and caffeine citrate in beverages that fall under the food category described as "non-alcoholic carbonated water-based flavoured sweetened beverages". This category of beverages is commonly referred to as carbonated "soft drinks". Under the IMA, the maximum permitted level of use of caffeine and caffeine citrate (calculated as caffeine), singly or in combination, will be 150 ppm in the finished product. The IMA will become effective upon the date of publication in Canada Gazette, Part I. The permitted maximum level of caffeine and caffeine citrate in cola type beverages will remain at 200 ppm as stipulated in Division 16 of the Regulations.
It is a regulatory requirement that the label of most prepackaged foods must declare a list of ingredients, including food additives such as caffeine, in descending order of proportion. However, there is no regulatory provision for mandatory quantitative labelling of caffeine, (e.g., milligrams caffeine per stated serving size). As for "natural caffeine", there are a number of food ingredients that naturally contain caffeine. These ingredients must appear in food ingredient lists. However, as is the case for "food additive caffeine", there is no requirement to identify the quantitative amount of caffeine in composite foods containing ingredients that are natural sources of caffeine. While coffee or chocolate are broadly recognized as caffeine sources, some ingredients (e.g., guarana, yerba matÚ) are likely less recognized as caffeine sources. For these natural sources of caffeine, there is no regulatory provision requiring that a food label identify the presence of caffeine nor state the amount of caffeine present in the food.
In 2002, Health Canada established recommendations on maximum caffeine intakes for adults in general and certain specific population sub-groups. These recommendations are published in the Health Canada publication "It's Your Health - Caffeine".
Caffeine and Food also contains these recommendations as well as information on the amounts of caffeine typically found in various foods:
Quantitative labelling of caffeine in foods would provide consumers with additional information that they can readily use to more accurately determine daily caffeine intake. Therefore, Health Canada is issuing this guidance document to urge food manufacturers to quantitatively label caffeine when present in certain prepackaged foods, such as beverages.
To assist food manufacturers and to ensure that there is consistency among manufacturers when voluntary labelling the caffeine content of foods, Health Canada is providing the following general labelling guidelines to industry:
The Food Directorate is open to receiving comments and feedback from both industry and consumers on these preliminary guidelines. Comments may be submitted in writing, either electronically or by regular mail. If you are submitting your comments electronically, please use the word "Caffeine Labelling" in the subject box of your e-mail.
Bureau of Chemical Safety
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