Health Canada has lowered the permitted level of caffeine and caffeine citrate in cola type beverages from 200 ppm to 150 ppm, with the change taking effect on January 1, 2026. This update is particularly important for manufacturers of cola type beverages that rely on added caffeine.
Because these new limits create clearer expectations for stimulant use in foods, businesses may need to reassess formulas and compliance plans. The updated threshold also influences how certain products are classified and which regulatory pathways apply.
These updates aim to improve clarity and protect consumers. If your products use caffeine or caffeine citrate, understanding what has changed and how it may affect future development and labeling is essential. Keep reading to learn what this means for your next steps as a business.
Health Canada Lowers Maximum Caffeine Levels to 150 ppm
Health Canada announced a targeted revision to the List of Permitted Food Additives with Other Purposes of Use, reducing the ceiling for caffeine and caffeine citrate in cola type beverages from 200 ppm to 150 ppm. Consequently, businesses using caffeine must verify whether their formulations still meet the updated threshold. This update becomes enforceable on January 1, 2026.
The Department confirmed that this change results from regulating caffeine as a supplemental ingredient when total caffeine from all sources exceeds 150 ppm in carbonated water-based beverages. This new threshold places a stronger emphasis on overall caffeine exposure and encourages companies to reassess how they formulate products that rely on caffeine for functionality or flavour.
What This Means for Product Formulation
Understanding caffeine regulations in Canada helps you determine whether your current formulations will remain compliant once the new limits take effect. Furthermore, reviewing each ingredient source early can help you anticipate the next steps more effectively. Since the revised threshold applies to total caffeine from all sources, companies should verify each ingredient contributing to the stimulant profile.
You may also need to consider whether your product falls under supplemental food requirements. This classification shift can influence everything from formulation records to marketing claims. Because timelines for reformulation and relabeling can be lengthy, assessing your portfolio early can reduce disruptions during the transition period.
Why Health Canada Introduced This Change
Health Canada’s revision aligns with its broader objective to strengthen oversight of substances added to foods. Moreover, the updated limit supports a more unified approach to caffeinated product oversight across categories. The new limit supports a more consistent framework for caffeinated products, especially those that resemble energy products in purpose or composition.
By placing cola type beverages with higher caffeine content into the supplemental ingredient category, Health Canada aims to ensure that these products meet the added scrutiny expected from foods that deliver functional or stimulant effects.
This change also provides clearer direction for manufacturers, helping them navigate distinctions between traditional foods and supplemental foods more confidently.
Preparing for the 2026 Compliance Deadline
With the enforcement date approaching, businesses should begin reviewing formulas, documentation, and procurement workflows. In addition, starting early allows you to identify potential reformulation needs before deadlines create pressure.
Early evaluations allow you to anticipate whether minor adjustments or full reformulations are required. So, as you assess your products, consider the following questions:
- Does the total caffeine level exceed 150 ppm when all sources are counted?
- Does the product now fall under the supplemental ingredient pathway?
- Will the change affect label accuracy or marketing language?
If these questions reveal gaps, beginning your compliance planning now gives your team more time to transition smoothly. For additional support, you can reach out to our regulatory experts for guidance as you prepare for these changes.
Key Takeaways
- Health Canada lowered permitted caffeine and caffeine citrate levels in cola type beverages to 150 ppm.
- The update becomes enforceable on January 1, 2026, giving businesses time to adapt.
- Products exceeding the new limit may fall under supplemental ingredient rules.
- Reviewing formulations early helps prevent delays during the transition.
- Understanding caffeine regulations in Canada supports smarter market planning.
Frequently Asked Questions
1. Will every caffeinated product need to change its formula?
Not all products will need reformulation, since many beverages already fall below 150 ppm. Only those that exceed the new limit may require adjustments.
2. Does the change affect foods that naturally contain caffeine?
No. The update applies to added caffeine and caffeine citrate, not naturally occurring caffeine in ingredients like cocoa or coffee.
3. Will companies need new approvals to stay compliant?
Most products will not need new approvals. However, if your formula now falls into the supplemental ingredient category, additional documentation may be required.
4. Is caffeine citrate still allowed in Canada?
Yes. Caffeine citrate is still permitted, but its maximum use level has been revised. Companies should confirm how the new limit applies to their formulas.
5. When should businesses start preparing for this change?
Preparing now is advisable, since formulation updates, label changes, and supply chain adjustments can take time.
Next Steps
Health Canada’s decision to revise caffeine limits signals an important shift for beverage and supplemental food manufacturers. Understanding the impact of these new caffeine regulations in Canada helps you prepare your formulas, update your labels, and avoid costly delays.
If you need support evaluating your formulations or reviewing your ingredient compliance, our Food Compliance Services can help you move forward with clarity. For direct assistance or to discuss your product, you can reach out to our team and we will guide you through the next steps.
