Health Canada has modified the List of Permitted Supplemental Ingredients to permit up to 30% juice content in certain caffeinated beverages that fall within item 1 of the List of Permitted Supplemented Food Categories. The change (reference number MASF-2606) took effect August 13, 2026, the same day it was published, responding to a pre-market submission that requested relaxing the existing 25% juice threshold for carbonated and non-carbonated water-based beverages containing added caffeine as a supplemental ingredient.
The modification affects caffeine entries C.1(1) and C.1(2) in Part IV of the List of Permitted Supplemental Ingredients and applies to beverages with a total caffeine content from all sources of up to 150 p.p.m. and up to 400 p.p.m., respectively. Additional editorial revisions have been made to improve consistency between entries and to correct a typographical error in the French version of the list regarding the unit of measurement for L-asparagine.
Because the change is permissive and already in force, manufacturers don’t face a compliance deadline, but reviewing product formulations now is still the practical move for anyone considering the higher limit.
What Changed and Why
Prior to this modification, the conditions of use for caffeine entry C.1(2) specified that caffeinated beverages must not contain, singly or in combination, 25% or more fruit and/or vegetable juice, purée, pulp or nectar, as consumed. A petitioner filed a pre-market submission requesting that this threshold be raised to 30%.
Health Canada conducted a safety assessment of the proposed change and found no concerns with permitting up to 30% juice in beverages containing added caffeine. As a result, the department applied the modification not only to caffeine entry C.1(2), as originally requested, but extended it to caffeine entry C.1(1) as well. This decision was deliberate: applying different juice limits to beverages with lower versus higher caffeine content would have created a regulatory inconsistency in which products with lower caffeine were subject to stricter formulation conditions than their higher-caffeine counterparts.
Importantly, the label prohibition remains intact. Caffeinated beverages sold under the supplemented foods framework are still prohibited from displaying the terms “juice,” “purée,” “pulp,” or “nectar” on their product label, including in the common name, except where required in the ingredient list. This restriction was preserved expressly to prevent caffeinated products from being represented in ways that might suggest they are healthier choices or that could make them more appealing to children.
Scope of the Modification
The change applies specifically to carbonated or non-carbonated water-based beverages, including concentrates and mixes intended to be reconstituted, that belong to item 1 of the List of Permitted Supplemented Food Categories. Only beverages that are already authorized to contain added caffeine as a supplemental ingredient fall within the scope of this update.
Regulated parties are not required to adopt the new 30% limit. The modification is permissive, meaning manufacturers may continue formulating to the original threshold of less than 25% juice if they prefer to maintain the status quo. However, manufacturers that choose to take advantage of the higher limit must review their Supplemented Food Facts table to ensure it accurately reflects any resulting changes to nutrient composition.
Changes to juice content can affect nutritional values, and any discrepancy between the actual product composition and the declared values on the label would constitute a compliance issue.
Editorial Revisions to the List
Beyond the substantive change to the caffeine entries, Health Canada has made editorial revisions to ensure internal consistency within the List of Permitted Supplemental Ingredients. These include alignment between the English and French versions of the caffeine entries in column 5, and a correction to the French version of the L-asparagine entry, where the unit of measurement was affected by a typographical error.
Health Canada has clarified that these editorial changes do not introduce new regulatory requirements, and therefore do not trigger any obligation to reformulate products or revise labels. They are purely corrective in nature.
Consultation Process
The proposal underpinning this modification (reference number P-SIS-25-02) was published July 25, 2025, and closed for comments on October 8, 2025. Health Canada received six comments, two of which were out of scope, including one submitted through the corresponding World Trade Organization notification (G/SPS/N/CAN/1599). Feedback was largely supportive, and no new scientific information was submitted that would have changed the proposal.
One government representative questioned how the 30% limit compares to other jurisdictions’ standards. Health Canada responded that the change is permissive relative to the existing 25% limit, and that the retained prohibition on juice-related terms preserves the policy intent of preventing caffeinated products from being represented as healthier options.
A separate industry association flagged unclear guidance on the pre-market submission process; Health Canada pointed stakeholders to the Guidance Document: Pre-market Submission Process for Supplemented Foods for more detail than the higher-level Guidance Document: Supplemented Foods Regulations provides.
What This Means for Your Business
For manufacturers of caffeinated beverages regulated as supplemented foods, this modification opens a narrow formulation window: products that previously could not exceed 25% juice content may now contain up to 30%, provided they meet the applicable caffeine thresholds and stay within the carbonated or non-carbonated water-based beverage category under item 1 of the List of Permitted Supplemented Food Categories.
Adopting the new limit isn’t a simple administrative update. Manufacturers that reformulate must review their Supplemented Food Facts table for accuracy and evaluate any resulting label changes against the broader supplemented food labelling requirements under Part B of the Food and Drug Regulations. Companies with no plans to change their formulation don’t need to take action; the label prohibition on juice-related terms in the common name is unchanged, and existing compliant labels remain valid.
Quality Smart Solutions’ Canada food compliance services include regulatory assessments for supplemented food manufacturers navigating formulation changes, label updates, and pre-market submission preparation.
Frequently Asked Questions
Does this change require all caffeinated beverage manufacturers to reformulate their products?
No. The modification to the List of Permitted Supplemental Ingredients is permissive, not prescriptive. Manufacturers may continue to formulate their products with less than 25% juice content if they choose to maintain that threshold. The new 30% limit is an option available under the updated conditions of use in caffeine entries C.1(1) and C.1(2), not a mandatory standard.
If a manufacturer reformulates to use up to 30% juice, what labelling obligations apply?
Any manufacturer that opts for the new 30% limit must ensure that changes to nutrient composition resulting from increased juice content are accurately reflected in the Supplemented Food Facts table. The prohibition on displaying the terms “juice,” “purée,” “pulp,” or “nectar” in the common name or elsewhere on the label (except in the ingredient list) remains unchanged. Health Canada has been explicit that this labelling restriction is retained to prevent caffeinated beverages from being represented as healthier products.
Does the L-asparagine correction affect any compliance obligations for products containing that ingredient?
No. The correction to the French version of the L-asparagine entry addresses a typographical error in the unit of measurement. Health Canada has confirmed this is an editorial revision with no substantive effect on the authorized conditions of use for L-asparagine. Manufacturers are not required to reformulate or revise their labels as a result of this change.
When do these changes take effect, and is there a transition period?
The modifications came into force on August 13, 2026, the same day they were published. Health Canada has stated that because the changes are permissive and don’t introduce new regulatory requirements, no transition period applies. Manufacturers who want to adopt the new 30% threshold can do so now, provided they’ve reviewed and updated their Supplemented Food Facts table and formulation records accordingly.
Key Takeaways
- Health Canada has modified the List of Permitted Supplemental Ingredients to permit up to 30% juice content in caffeinated beverages regulated as supplemented foods, effective August 13, 2026.
- The change applies to caffeine entries C.1(1) and C.1(2) and covers carbonated and non-carbonated water-based beverages, including concentrates and mixes, in item 1 of the List of Permitted Supplemented Food Categories.
- Adoption of the new 30% limit is optional; manufacturers may continue to comply with the original less-than-25% threshold, and there is no transition period or compliance deadline attached to this change.
- Manufacturers that reformulate under the new limit must update their Supplemented Food Facts table to reflect any changes in nutrient composition.
- The prohibition on juice-related terms in the common name remains in force, and editorial corrections to caffeine entries and the L-asparagine entry do not require any product or label changes.
Reviewing Your Formulation Files
Health Canada’s modification to the List of Permitted Supplemental Ingredients is a targeted regulatory update with practical formulation implications for caffeinated beverage manufacturers. Since the change is already in effect and permissive rather than mandatory, there’s no deadline pressure, but companies considering a reformulation under the new 30% juice threshold should still confirm their Supplemented Food Facts table and label records are aligned before making the switch.
For guidance on how this change applies to your specific product portfolio, contact us to speak with a regulatory specialist experienced in supplemented food compliance under the Food and Drug Regulations.
