• Impact of Nutrition Label Reform on Coffee

  • Proposed Caffeine Labeling Law

  • Innovative Coffee Products

Impact of Nutrition Label Reform on Coffee

Coffee is a typical part of most American’s days. On average, 62% of American adults consume coffee every day. Coffee is sold to consumers in many forms including ground, whole bean, brewed and can be found on numerous aisles of the grocery store. Specific labeling requirements must be considered when reviewing individual coffee products.  

Key labeling considerations for coffee include:

  • Mandatory nutrients
  • Reference amount customarily consumed
  • Net weight statement
  • Flavor labeling

Previously, most ground and whole bean coffee was exempt from nutrition labeling because it contained insignificant amounts of all mandatory nutrients. The Revision of the Nutrition and Supplement Facts Labels Final Rule was passed in 2016 and changed many food labeling regulatory requirements. Potassium was added as a mandatory nutrient on the nutrition facts panel which impacts coffee. Ground coffee contains on average 174 mg potassium per 12 fl oz brewed coffee or 4% Daily Value which is above the Food and Drug Administration (FDA) level of significance. In turn, coffee no longer falls under the insignificant nutrient exemption for nutrition labeling and requires a nutrition facts panel. 

Some coffee beverages like lattes and cold brew drinks contain added sugars. Added sugars cannot be tested analytically and currently, there are no analytical methods to determine this. Product formulas must be reviewed to determine accurate added sugar values. Any sweetened coffee or coffee beverages would need to be evaluated to determine correct added sugar values. 

The reference amount customarily consumed (RACC) for coffee is 360 mL prepared. Previously, the RACC was 240 mL prepared. Coffee nutrition labeling must be based on the updated RACC. If the coffee is ground or whole bean, the serving size is based on the amount of ground or whole bean coffee needed to make 12 fl oz of prepared coffee. The serving size and preparation directions must align with the reference amount. If the product is sold as a ready-to-drink beverage like a refrigerated latte then the reference amount would be 12 fl oz (340 mL). All nutrition information declared on the nutrition facts panel must be based on the serving size which aligns with the product RACC. 

Net contents statements are straightforward for bagged and bottled coffee packages. Accurately labeling multiunit pods and k-cups with inner and outer packages become more complex. Although certain label requirements are exempt for inner packages, net contents, product name, and any flavor labeling is required on the inner unit pod or cup. 

Many ground and brewed coffees have added characterizing flavors like hazelnut, vanilla, cinnamon, sugar, et cetera. Flavor labeling is required if a product contains natural or artificial flavor that enhances or replicates a product’s characterizing flavor. For example, if a product name is hazelnut coffee and the product formula contains artificial flavor to enhance the hazelnut flavor, then labeling is required. All flavor labeling must be in a type size at least ½ the height of the characterizing flavor on the label. Flavor labeling must be included on both the inner and outer package when the characterizing flavor is described. 

Proposed Caffeine Labeling Law

One of the many benefits of drinking coffee is the caffeine jolt. Coffee naturally contains about 120 mg caffeine per 12 fl oz brewed coffee. Caffeine as a food additive is generally recognized as safe (GRAS) in only cola type products up to a level of 0.02 percent (200 ppm). Adding caffeine to a coffee beverage is not permitted. Caffeine content is not required to be declared on food labels. In August 2021, congress presented proposed initiatives under the Food Labeling Modernization Act of 2021 (H. R. 4917) to add caffeine content to the information as a requirement. Currently, quantitative caffeine content per serving can be voluntarily declared on the label. The information must be truthful and not misleading. We will continue to monitor the evolving landscape of caffeine and food labeling. 

Innovative Coffee Products

A new category for coffee is in the alcoholic hard coffee space like hard coffee malt beverages. Typically, hard coffee is made with alcohol derived from malt. Sweeteners, milk and other flavors like chocolate/vanilla are also often added. 

Alcoholic malt beverages which contain coffee require labeling as defined by the Alcohol and Tobacco Tax and Trade Bureau (TTB). Requirements for labeling are distinct and separate from food labeling and include class designation, alcohol content, name and address et cetera. All new labels must be approved by the TTB. Calorie, carbohydrate, and sugar content can be voluntarily declared on the label. All voluntary nutrition information declared must be truthful and not misleading. Allergen labeling is also voluntary and not required, however must be accurate, truthful, and not misleading.  

Another unique coffee category is coffee with cannabidiol (CBD) added. CBD is not permitted for use in food including coffee. Although coffee with added CBD is common in the marketplace or at your local coffee shop, it is not considered GRAS by the FDA. The FDA has issued warning letters against companies who have not adhered to the requirements of the Food and Cosmetic Act which prohibits the use. On September 10, 2021, California lawmakers passed a bill to allow the use of CBD in food. The bill is before the governor to sign and end the ban against CBD in food in the state of California. We will continue to monitor changes at the state and federal level on the use of CBD in food.  

While coffee may seem like a simple product category there are many nuances including nutrition information, flavor labeling, food additives, and net content statements. All areas must be thoroughly considered to ensure that your product is within regulatory compliance.

Mérieux NutriSciences offers full-service label review to ensure compliant labels, with a Regulatory Compliance team dedicated to food and nutrition labeling. Contact us today to start your food label review.


NCA: https://www.ncausa.org/Newsroom/NCA-releases-Atlas-of-American-Coffee

USDA: NDB Number: 14209 https://fdc.nal.usda.gov/fdc-app.html#/food-details/171890/nutrients

Food Label Modernization Act 2021: (https://www.congress.gov/bill/117th-congress/house-bill/4917?s=1&r=1) (https://www.congress.gov/bill/117th-congress/senate-bill/2586/actions?q=%7B%22search%22%3A%5B%22Richard+Blumenthal%22%5D%7D&r=2&s=2)

CBD: https://www.fda.gov/news-events/public-health-focus/fda-regulation-cannabis-and-cannabis-derived-products-including-cannabidiol-cbd#approved

GRAS: https://www.cfsanappsexternal.fda.gov/scripts/fdcc/index.cfm?set=FoodSubstances

Net Contents: https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=101.7

Flavor Labeling: https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/cfrsearch.cfm?fr=101.22

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