Changes are on the horizon for caffeine as a supplemental ingredient, and they could directly impact your business. Whether you manufacture energy drinks, snack bars, or functional beverages, these updates will determine how you formulate and market your products moving forward.
At the same time, Health Canada is tightening regulations to ensure consumers stay informed and protected, which means businesses must adapt. In this article, we’ll break down exactly what’s changing, why it matters, and what you need to do to stay compliant.
So, keep reading to make sure your business is ready for these regulatory shifts.
What are the proposed changes?
Health Canada is updating the List of Permitted Supplemental Ingredients to include new requirements for caffeine use in certain supplemented foods. One of the key changes is the introduction of a mandatory cautionary statement: “Do not [eat/drink] on the same day as any other source of caffeine” for solid supplemented foods containing more than 56 mg of caffeine per serving.
Specifically, this applies to products such as chocolate confectioneries, protein-isolate- and cereal-based bars, chewing gums, and the newly proposed category of gummies.
Moreover, new labelling requirements will take effect, giving businesses until January 1, 2028 to comply. The goal is to enhance consumer awareness and reduce excessive caffeine consumption.
In addition, Health Canada is revising the conditions under which caffeine as a supplemental ingredient can be added to foods. These changes focus on:
1. Permitted food categories
Firstly, limiting caffeine supplementation to specific food and beverage types.
2. Maximum allowable levels
Secondly, adjusting the amount of caffeine permitted per serving to align with safety assessments.
3. Labelling requirements
Finally, strengthening disclosure to ensure consumers understand caffeine content and potential health impacts. These changes aim to mitigate risks associated with excessive caffeine consumption, particularly among vulnerable populations such as children and pregnant individuals.
Who will be affected?
Manufacturers and distributors of supplemented foods, including energy drinks, snack bars, and functional beverages, must assess their product formulations to ensure compliance. Otherwise, non-compliance could result in reformulation needs, relabelling efforts, or even product removal from the market.
In particular, if your product includes caffeine as an additive, now is the time to review your ingredients and packaging in alignment with the new guidelines.
List of Permitted Supplemental Ingredients
Health Canada maintains a List of Permitted Supplemental Ingredients, detailing ingredients approved for use in supplemented foods, along with their specific conditions. Specifically, if your product contains caffeine, it’s essential to check this list to ensure compliance with the latest regulations.
By doing so, you can help prevent reformulation delays and ensure your products remain on the market.
How to stay compliant
To prepare for the proposed regulatory changes, businesses should take a proactive and strategic approach. Here’s how you can get started:
- First, review product formulations: Assess caffeine levels and ensure they align with the new permitted thresholds. This will help you avoid costly reformulations later.
- Next, update labelling: Ensure packaging includes required caffeine disclosures and safety warnings. Businesses have until January 1, 2028, to comply with new labelling requirements. Taking early action can smooth your transition.
- Monitor regulatory updates: Stakeholders can stay informed by signing up for Health Canada’s Consultation and Stakeholder Information Management System (CSIMS). That way, you won’t miss critical updates.
- Also, submit feedback: Industry stakeholders can provide input on the proposed modifications until May 21, 2025, by emailing food.ibr-ipr.aliments@hc-sc.gc.ca with “caffeine (P-SIS-25-01)” in the subject line. Your input may help shape the final regulations.
- Finally, consult compliance experts: Work with regulatory specialists to navigate changes efficiently. They can help you stay ahead and avoid unnecessary risk.
Why this matters for your business
Regulatory changes can impact product development timelines, marketing strategies, and overall brand reputation. Therefore, staying ahead of compliance updates helps prevent costly disruptions and ensures consumer trust in your products.
At Quality Smart Solutions, we specialize in helping businesses navigate evolving regulations. If you need assistance ensuring compliance, contact us today or fill out the form below.
