Modification to the List of Permitted Food Additives with Other Purposes of Use to revise the use of caffeine and caffeine citrate
- Notice of Modification – Lists of Permitted Food Additives
- Reference number: M-FAA-25-07
- December 01, 2025
Summary
The purpose of this notice is to publicly announce Health Canada's decision to lower the level of caffeine and caffeine citrate permitted in cola type beverages from 200 parts per million (ppm) to 150 ppm. This change results from the Department now regulating caffeine as a supplemental ingredient when it is added to carbonated water-based beverages and the total amount of caffeine from all sources is more than 150 ppm. This modification will come into force on January 1, 2026, the date on which the List of Permitted Food Additives with Other Purposes of Use will be modified.
Background
The food additives authorized in Canada are set out in the Lists of Permitted Food Additives. These lists are incorporated by reference into Division 16 of the Food and Drug Regulations (FDR).
Caffeine and caffeine citrate are authorized food additives in Canada and appear in the List of Permitted Food Additives with Other Purposes of Use (the List). Caffeine and caffeine citrate are currently permitted in cola type beverages and in non-alcoholic carbonated water-based flavoured and sweetened beverages other than cola type beverages (i.e. other "carbonated soft drinks"), to characterize the product, at maximum levels of 200 ppm and 150 ppm, respectively.
Issue
Health Canada published the Regulations Amending the Food and Drug Regulations and the Cannabis Regulations (Supplemented Foods) in the Canada Gazette, Part II, in June 2022, creating a regulatory framework for the sale of supplemented foods in Canada. Under the regulations for supplemented foods, caffeine or caffeine citrate will be regulated as a supplemental ingredient when added to non-alcoholic carbonated beverages and the total amount of caffeine from all sources is greater than 150 ppm. A Notice of intent to modify the List of Permitted Food Additives with Other Accepted Uses to revise the use of caffeine and caffeine citrate in cola type beverages was published on July 21, 2022, to inform stakeholders of Health Canada's intent make these modifications to the List on January 1, 2026.
Rationale
Caffeine and caffeine citrate are regulated as food additives when used in cola-type beverages at a level greater than 150 ppm up to 200 ppm but as supplemental ingredients when used in other carbonated soft drinks at the same level.
Lowering the maximum level of use for caffeine and caffeine citrate as food additives in cola type beverages to 150 ppm will remove this discrepancy. They will be regulated as food additives when used in both types of beverages at a level up to 150 ppm, and as supplemental ingredients when used in them at a level greater than 150 ppm up to 400 ppm.
Modification to the List of Permitted Food Additives with Other Purposes of Use
Health Canada will modify the List of Permitted Food Additives with Other Purposes of Use by lowering the maximum level of use of caffeine and caffeine citrate in cola type beverages from 200 to 150 ppm, as shown in the table below (in bold font in this notice to illustrate the change), on January 1, 2026.
| Item | Column 1 | Column 2 | Column 3 | Column 4 | Column 5 | Notes |
|---|---|---|---|---|---|---|
| Food additive | Source | Food | Purpose of use | Maximum level of use, maximum level of residue and other conditions | ||
| C.1 | Caffeine |
n/a |
(a) |
(a) |
(a) |
M-FAA-25-07 |
| C.2 | Caffeine Citrate |
n/a |
(a) |
(a) |
(a) |
M-FAA-25-07 |
Corrective modifications
Health Canada is revising certain entries in the French versions of the List of Permitted Food Additives with Other Purposes of Use that contain the term « gazéifié », ensuring grammatical alignment with the food it describes. The use of the term « gazeuse » is also being adjusted to ensure consistent terminology when referring to the same concept, by replacing « gazeuse » with « gazéifiée » where appropriate.
Health Canada will modify the French version of the List of Permitted Food Additives with Other Purposes of Use by grammatically aligning with the food it describes and by replacing « gazeuse » with « gazéifiée » where appropriate as shown in the table below (in bold font in this notice to illustrate the change), on January 1, 2026.
This type of corrective modification is also needed in the French versions of the following lists: List of Permitted Food Colours, List of Permitted Emulsifying, Gelling, Stabilizing and Thickening Agents, List of Permitted Food Enzymes and List of Permitted Acidity Regulators and Acid-Reacting Materials and will be implemented in due course, the next time these lists are modified for substantive reasons.
| Article | Colonne 1 | Colonne 2 | Colonne 3 | Colonne 4 | Colonne 5 | Notes |
|---|---|---|---|---|---|---|
| Additif alimentaire | Source | Aliment | But de l'emploi | Limite de tolérance, limite maximale de résidus et autres conditions | ||
| C.1 | Caféine |
s/o |
b) |
b) |
b) |
M-FAA-25-07 |
| C.2 | Citrate de caféine |
s/o |
b) |
b) |
b) |
M-FAA-25-07 |
| P.5 | Polyéthylène glycol (gamme de poids moléculaires de 3 000 à 9 000 Da) |
s/o |
b) |
b) |
b) |
M-FAA-25-07 |
| Q.1 | Essence de quillaja |
s/o |
Bases de boissons; boissons préparées (gazéifiées et non gazéifiées); préparations pour boissons |
Agent moussant |
Bonne pratique de fabrication |
M-FAA-25-07 |
| S.1 | Saponine |
s/o |
Bases de boissons; boissons préparées (gazéifiées et non gazéifiées); préparations pour boissons |
Agent moussant |
Bonne pratique de fabrication |
M-FAA-25-07 |
| S.31 | Chlorure stanneux |
s/o |
b) |
b) |
b) |
M-FAA-25-07 |
Other relevant information
Food additive specifications
Food additives must meet the specifications set out in the Table of Food Additive Specifications, if they exist. Food additives which do not have specifications in this table must meet the specifications, if any, set out in the latest edition of one of the following documents:
Implementation and enforcement
The modification described in this notice will come into force on January 1, 2026, the day of its publication in the List of Permitted Food Additives with Other Purposes of Use.
The Canadian Food Inspection Agency is responsible for the enforcement of the Food and Drugs Act and its associated regulations with respect to foods.
Contact information
If you wish to submit an inquiry or new scientific information about a food additive permitted for use in Canada, please contact Health Canada's Bureau of Chemical Safety (BCS). If your communication is specific to this notice, please use the words "caffeine and caffeine citrate (M-FAA-25-07)" in the subject line of your message.
Bureau of Chemical Safety
Food and Nutrition Directorate
251 Sir Frederick Banting Driveway
Postal locator 2202C
Tunney's Pasture
Ottawa ON K1A 0K9
Email: bcs-bipc@hc-sc.gc.ca