As more coffee brands put out energy drinks, FDA asks how much caffeine is too much.
In late June, the US Food and Drug Administration (FDA) added caffeine labeling to its 2026 regulatory priority list. The move, while preliminary, signals that the agency is considering updating guidance on how companies disclose caffeine content. At the moment, companies only need to list caffeine as an ingredient when it’s added separately — products such as coffee and chocolate, in which caffeine occurs naturally, are exempt from this requirement. And there is currently also no legal obligation to disclose how much caffeine a product contains.
But energy drinks are becoming more popular, and FDA has called dietary supplements containing pure or highly concentrated caffeine, another emerging product category, “a significant public health threat” after they contributed to at least two deaths in the US. There has also been growing controversy and scrutiny around the levels of caffeine in some beverages, especially energy drinks marketed to teenagers.
As coffee brands introduce new beverages with added caffeine, such as Starbucks’ refreshers or Caribou Coffee’s energy drinks, any FDA update on labeling guidelines will be closely watched.
“Highlight Industry Best Practices”
FDA’s Human Foods Program (HFP), which is coordinating the 2026 priority agenda, was established in 2024 following a restructuring and consolidation of certain FDA functions. According to its website, HFP oversees FDA activities related to food safety and nutrition, and is a key element of US Health and Human Services (HHS) Secretary Robert F. Kennedy Jr.’s Make America Healthy Again movement.
Alongside a focus on Kennedy’s priorities such as ultra-processed foods and sugar reduction, HFP’s 2026 agenda includes looking more closely at caffeine labeling rules. “With the growing consumption of caffeinated beverages and foods,” the priority document reads, “HFP will highlight industry best practices for labeling added caffeine content in foods in connection with both packaged foods and beverages and at retail and restaurant settings.”
Suzy Badaracco, president of the food industry trend forecasting firm Culinary Tides, sees FDA’s caffeine labeling prioritization as a push for greater transparency by the agency. “It’s also part of a broader shift in how HHS under Secretary Kennedy is approaching food policy,” Badaracco says. “We’re seeing a willingness to reexamine labeling, ingredients, and the information consumers receive about the foods and beverages they consume.”
Caffeine and Controversy
There have been several high-profile deaths linked to highly caffeinated beverages in recent years. The parents of a Texas teenager who died of an enlarged heart in 2025 filed a lawsuit against the maker of the energy drink Alani Nu, which they claim contributed to their daughter’s death. Panera also stopped selling its controversial Charged Lemonade in 2024 after it was linked to several fatalities.
Many energy drinks, including Alani Nu, voluntarily disclose their caffeine content on the can, but it isn’t currently a requirement. FDA currently considers 400mg of caffeine per day to be safe for most healthy adults—that’s roughly two or three 12-ounce cups of coffee.
Public health experts and advocates have long called for stricter regulation of highly caffeinated beverages and better labeling. At the same time, research has linked moderate caffeine intake to a host of health benefits, from fighting dementia to boosting exercise performance.
FDA’s stricter caffeine labeling proposal is preliminary for now, and whether coffee is included in any revamped guidance remains to be seen. Even if coffee itself continues to be exempt, companies that also sell products with added caffeine, including ready-to-drink products, energy drinks, or cafe beverages, may need to pay attention.