Energy Drink Label

Energy drink label rules hang on one choice: is it a beverage or a dietary supplement? Named a drink, sold in a can like a soda to refresh you, it is a beverage with Nutrition Facts. Sold as a measured dose to supplement the diet, it can be a dietary supplement with Supplement Facts. Either way you need a name, net contents in fl oz and mL, the ingredients, allergens and your address. Our tool makes both panels.

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Energy drink label on a 16 oz can of apple black tea energy drink with a Nutrition Facts panel: 1 can, 120 calories
Checklist

What has to be on your energy drink label

Six parts on every can. The numbers match the can on the left, sold as a beverage.

Front label
BREWED BLACK TEA · REAL APPLEApple Black TeaEnergy Drink
16 FL OZ (1 PT) 473 mL
Back label
Nutrition Facts
1 serving per container
Serving size1 can (473mL)
Calories120
Total Fat 0g0%
Sodium 20mg1%
Total Carb. 31g11%
Total Sugars 27g
Incl. Added Sugars 16g32%
Protein 0g
Potassium 260mg6%
Not a significant source of saturated fat, trans fat, cholesterol, dietary fiber, vitamin D, calcium and iron.
INGREDIENTS: Brewed tea (water, tea), apple juice, sugar, lemon juice.
Allergens: none of the 9 major food allergens.
Made by Switchback Beverage Co.Asheville, NC 28801
  1. 1
    Product name21 CFR 101.3(g)
    What it is: "Apple black tea energy drink". A dietary supplement must say "dietary supplement" in its name, or name its type, like "caffeine supplement".
  2. 2
    Net contents21 CFR 101.7
    Fluid ounces and mL in the bottom 30% of the front. A 16 oz can is a pint: 16 FL OZ (1 PT) 473 mL.
  3. 3
    Nutrition Facts or Supplement Facts21 CFR 101.9, 101.36
    One panel, never both. As a beverage, a can under 24 fl oz is one serving: the whole can.
  4. 4
    Ingredient list21 CFR 101.4
    Heaviest first, so water or tea usually leads. Caffeine you add goes in by name. On a supplement, the inactive ingredients sit under the panel as Other ingredients.
  5. 5
    Allergen statementFALCPA
    Milk in a coffee energy drink, milk or soy in a protein version. The sample has none of the 9 major allergens.
  6. 6
    Name and address21 CFR 101.5
    Your business name, city, state and ZIP. Filled by a co-packer? "Distributed by" with your own name works.Co-Packer →
Energy drink rules

Things that are different for energy drinks

DrinkBeverage or supplement: FDA reads the whole canNames with drink, beverage, water or soda, cans that look like soft drinks, words like refresh or rehydrate and directions to drink several bottles a day all present a product as a beverage. A Supplement Facts panel does not change that. Directions to take a measured dose to supplement the diet can point the other way.FDA guidance: Distinguishing Liquid Dietary Supplements from BeveragesBeverage Labeling Requirements →
1.2 LHow much a day you tell people to drinkFDA puts the average person's daily drinking fluid intake at about 1.2 liters (40 fl oz). A serving size or daily amount that covers a big part of that, like three 16 oz bottles a day, makes the product a beverage, whatever panel it carries.FDA guidance: Distinguishing Liquid Dietary Supplements from Beverages
GRASCheck every added ingredientAn ingredient that is lawful in a supplement is not automatically allowed in a drink. In a beverage, each added substance must be generally recognized as safe for that use or approved as a food additive.FDA guidance, section III.D · 21 CFR 170.30
CaffeineNo caffeine line on Nutrition FactsOnly the nutrients FDA lists may sit inside the panel, and caffeine is not one of them. Caffeine added on its own goes in the ingredient list. Printing the milligrams elsewhere on the can is voluntary, and many brands do it.21 CFR 101.9(c) · FDA: Spilling the Beans
1 canOne can, one servingEnergy drinks without juice have a 12 fl oz (360 mL) reference amount. A still drink with fruit juice, like the sample, falls under juices and fruit drinks: 8 fl oz (240 mL). Either way an 8.4 or 16 fl oz can stays under twice the reference amount, so it is one serving: the whole can. A 24 fl oz can lands between 200% and 300%, so it gets two columns, per serving and per can.21 CFR 101.12(b), 101.9(b)(6), (b)(12)(i) · FDA RACC guidance
26%Juice in the can? Say how muchA drink with fruit juice states the percent juice near the top of the information panel. The sample is about 27% apple and lemon juice by volume, so a whole number no higher than that works: "Contains 26% juice".21 CFR 101.30(b)(1), (e), (j)Juice Label Requirements →
Sizes

Cans, shots and the label that fits

The container sets the serving and the number of columns. Find yours, then pick the matching style in the tool.

Cans, shots and the label that fits
ContainerTypical label areaStyle that usually fits
2 fl oz shot bottle1.5 × 2 inSupplement Facts, if sold as a supplement
8.4 fl oz slim can4 × 2 inTabular (wide), 1 serving
12 fl oz sleek can4.5 × 2.5 inStandard (vertical), 1 serving
16 fl oz can5 × 3 inStandard (vertical), 1 servingSample
24 fl oz can5.5 × 3.5 inDual column
Sample recipe included

Start from an energy drink that's already filled in

Brewed black tea brings the caffeine, apple juice and sugar bring the taste. Tick Liquid and set the serving to 1 can (473 mL). Adding caffeine powder or taurine? They are not in our ingredient library, so add them as your own ingredient with the values from your supplier's label.

Start from an energy drink that's already filled in
IngredientAmountUnit
Brewed tea✓ USDA match6cups
Apple juice✓ USDA match2cups
Granulated sugar✓ USDA match1/3cup
Lemon juice✓ USDA match1/4cup
Makes about 4 cans of 16 fl ozServing 1 can (473 mL); reference amount 8 fl oz (240 mL), a still drink with juice
Questions

Energy drink label questions

Only if the product really is a dietary supplement. FDA says a product with a Supplement Facts panel can still be a conventional food when its label says it refreshes or rehydrates. A can named a drink and sold like a soda gets Nutrition Facts.

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