CRN, AHPA, UNPA update caffeine-related guidelines

In the midst of a caffeine controversy prompting industry organizations to take action, the Council for Responsible Nutrition (CRN), American Herbal Products Association (AHPA) and United Natural Products Alliance (UNPA) all amended their requirements related to the sales and marketing of caffeine.

Today, CRN announced an update to its recommended guidelines for caffeine-containing dietary supplements that discourages the marketing and sale of powdered pure caffeine directly to consumers. CRN has added a section to its caffeine guidelines specifically calling on its members not to market powdered pure caffeine to consumers. The addition clarifies that it is not intended to limit marketing or selling of powdered pure caffeine in bulk form as a business to business transaction.

FDA has faced mounting pressure to ban powdered caffeine after the death of a teenager who had ingested the substance. According to FDA’s December 2014 consumer advisory, these products “are essentially 100-percent caffeine," with “a single teaspoon of pure caffeine [being] roughly equivalent to the amount in 25 cups of coffee." CRN’s updated recommended guidelines for caffeine-containing dietary supplements are available on the association’s website . The original guidelines were released in April 2013 and included recommendations on disclosure of total caffeine content; label advisories for conditions of use; serving size and daily intake recommendations; and restraints against marketing in combination with alcohol. CRN members were expected to comply within 12 months of its release.

The AHPA Board of Trustees also established a trade requirement that prohibits sale by AHPA members of pure caffeine in bulk form at retail (to consumers). Like CRN’s update, this policy is effective immediately, and it has been included in AHPA's Code of Ethics and Business Conduct. The AHPA Board's action came in the wake of recent reports associating serious injury and death with use of pure caffeine purchased by consumers in bulk packaging. These events also prompted several U.S. Senators to urge the Food and Drug Administration (FDA) to ban sale of bulk caffeine. AHPA members agree to comply with the Association's Code of Ethics and Business Conduct, which contains trade requirements adopted by the association.

In addition, UNPA approved the adoption of a new "no-sale" policy for bulk-powdered caffeine (BPC) for retail sales. The policy is effective immediately as a condition of membership for prospective and all current UNPA members. Additionally, UNPA recommends that BPC not be advertised, sold or marketed as a dietary supplement for retail sale or exhibited at trade shows until a final determination is reached by FDA as to the safety and suitable labeling of such products.