5 replies to this topic

[Emily Xu]

Hi everyone, 

 

I have a question regarding US regulation, if we add guarana extract in beverage, is it mandatory to label the caffeine content of the final product?  guarana extract contains much caffeine...

 

Thankssss.

[mabercro]

Hi Emily,

 

Will your product label have a Supplement Facts Panel or a Nutrition Facts Panel? 

[Emily Xu]

Hi Emily,

 

Will your product label have a Supplement Facts Panel or a Nutrition Facts Panel? 

Thanks Mabercro, it is conventional beverage with Nutrition Facts Panel

[mabercro]

Hi Emily, 

 

I believe because you are labeling it as a beverage product and using a NFP, you are not required to label caffeine content by the FDA. 

 

I found this article helpful 

 

https://ctmlabelings...y-drink-labels/

[matthewcc]

No, you are not required by regulations to list the caffeine content of your beverage on your label (e.g., https://www.ncbi.nlm...s/PMC3777296/).

 

However, I think it is wise to disclose the amount of caffeine in some circumstances and to limit the amount of caffeine.  See for example what American Herbal Products Association requires for its members:  https://www.ahpa.org...ng_products.pdf.  Also, as indicated in the article from mabercro, regulatory changes might happen in the coming years, so it's best to be on the safe side now.

 

Matthew

[mabercro]

Yes, agree with matthewcc. In the article I put in my post, they link to the American Beverage Associations voluntary labeling guidelines for energy drinks which might be helpful to look at as you design your label.