Three shelves in a supermarket full of various energy drink products displaying labels that meet legal requirements.

Important Requirements for Energy Drink Labels

Many people view energy drinks as a great alternative to coffee–functional beverages that help them wake up in the morning and maintain energy levels while offering unique flavors. For others, these drinks are viewed as a health hazard, causing anxiety and health problems while encouraging excessive consumption. 

The clash between these two sides places the energy drink industry in a tenuous position, trying to offer their customers the drinks they want while keeping up with the demands of government regulators and health organizations. How do you negotiate these differences to create energy drink labels that meet regulatory requirements and keep customers informed?

How is Caffeine Regulated in Beverages?

According to federal regulation 21 CFR 182.1180, caffeine up to a level of 0.02 percent (200 ppm or 0.2 ml per l) is Generally Recognized As Safe (GRAS) for use in cola-type beverages. This standard was established in the late 1950s. 

However, concerns over caffeine consumption grew as new research came in, resulting in the U.S. Food and Drug Administration (FDA) investigating its effects through the 1980s and 90s. By 2000, it was determined that no changes were needed. Today, the FDA advises consumers to limit intake to 400 milligrams of caffeine per day.

Caffeinated drink label requirements are still the same after all these decades, so an energy drink product follows the same label requirements as any other soft drink. That means there’s no labeling requirement to state the amount of caffeine on the container or add advisory statements to meet federal guidelines. 

Some manufacturers have also chosen to sell their energy drinks as supplements. These products aren’t as closely regulated as conventional food products, but caffeine labeling is required.

Either way, labeling requirements may change in the future. The FDA is monitoring their own CAERS reporting system for adverse events, as well as caffeine-related cases involving the Poison Control Center and outside research. It’s likely we may see the agency revisit caffeine labeling standards in the next few years. 

What Information Does the FDA Require on Energy Drink Beverage Labels?

Since it’s technically in the food and beverage category, an energy drink label must follow guidelines that are part of the Nutritional Labeling and Education Act (NLEA). This has three main components:

  • Nutrition Facts panel
  • List of ingredients
  • Declaration of allergens, as applicable.

If your company already produces soft drinks, this list should be familiar to you. These are the same guidelines you have to follow with sodas, sports drinks and other non-alcoholic drinks.

ABA Guidance: Establishing Best Practices to Avoid Legislation

When the sale of energy drinks exploded in the 2000s, there was cause for concern. College students were binging on energy drink cocktails, hoping to get drunk without the accompanying drowsiness. There were reports of deaths related to excessive energy drink consumption and parents questioned whether these high caffeine content beverages should be legal for children to drink.

These issues prompted the National Center for Complementary and Integrative Health (NCCIH), a division of the U.S. Department of Health & Human Services, to look into this beverage category. They noticed that most doctor and hospital visits after consuming these drinks involved excessive consumption or consumption in combination with drugs or alcoholic beverages. At this point, it wasn’t a question of whether these drinks should be regulated, but when and how.

The American Beverage Association (ABA) represents the largest companies in the industry, including The Coca-Cola Company, PepsiCo, Rockstar, Red Bull and Monster. (Combined, these companies control 95% of the energy drink market.) 

To avoid government regulations, they decided the best course of action would be to self-regulate. To this end, the group adopted a series of commitments in 2014 called the ABA Guidance for the Responsible Labeling and Marketing of Energy Drinks.” This laid down 6 requirements for labeling on beverages produced by member companies:

    • Labels must list suggested serving size, caffeine per serving, per container, or both. This information is printed separately from the nutrition facts label.
    • The label must include the statement “Not intended or recommended for children, pregnant or breastfeeding women, or those sensitive to caffeine.”
    • Sellers will not promote mixing any energy drink with alcohol, or suggest these products will counteract the effects of alcohol consumption.
    • Labels will not promote excessive consumption. Many brands add a notice that consumption should be limited to a few servings per day.
    • Energy drink manufacturers will follow the Council of Beverage Associations’ Global Policy on Marketing to Children. This policy bans all advertising to children under 12 years of age. This ban includes avoiding advertising in areas that have direct contact with children, and advertising that includes children. Manufacturers also won’t sell or advertise products in K-12 schools.
    • Manufacturers will categorize drinks as beverages, not dietary supplements.

Labeling an Energy Drink That’s Classified as a Dietary Supplement

Energy shot manufacturers mostly choose to categorize their products as dietary supplements. This is either because they exceed beverage caffeine limits, or because they aren’t marketed as a drink. 

The labelling of these shots falls under the Dietary Supplement Health and Education Act of 1994 (DSHEA). DSHEA has been amended a few times since then, adding clearer language about nutrition, as well as statements about added iron and trans fats. The FDA has an online guide for DSHEA labeling, including wording for health claims.

Instead of a Nutrition Facts panel, supplements have a Supplement Facts panel. This combines elements of both a Nutrition Facts and Drug Facts label, listing calories, macronutrients and vitamins along with active ingredients. If an active ingredient isn’t a recognized nutrient, it must be marked with the footnote “Daily value not established.” This includes caffeine, as well as common additions like taurine–an amino acid–and guarana. Inactive ingredients are listed below this panel. Otherwise, the label format is nearly identical to a beverage label. 

Getting Labels Onto Your Energy Drink Containers

Are you looking for a more effective way to label your energy drink containers? See how we helped Birdfish Brewing Company increase production efficiency. The same methods we used for their labeling system can be applied to your beverages.

If you package your drinks in cans, you can definitely benefit from our 360a WR Wrap System. This machine is designed for labeling round containers in a wide range of sizes, and it can save calibration settings for multiple label and container configurations. This lets you use one machine for 250 mL, 12 oz. and 20 oz. cans.

We also make a tabletop wrap labeler that is perfect for small-scale production of energy shots. By changing out the star wheel, you can use this machine to label a range of small, round containers. The hopper on this machine is hand-loaded, allowing for a final inspection before labeling the product.

Make Your Products Look Great with Our Labeling Equipment

When you need product labels that stand out while delivering the information customers need, contact CTM Labeling Systems. Our local distributors can help you set up a labeling system that works with your bottles and cans, no matter the size or shape.