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To: Canadian Medical Association Journal

The Canadian Non-Alcoholic Beverage sector is writing to you to set the record straight regarding several factual errors within the recent CMAJ editorial "Caffeinating children and youth".  We are very disappointed that a prestigious journal would have proceeded with publishing this article in its present form, despite the fact that industry representatives contacted you to correct these errors prior to publication.

We strongly agree that energy drinks should be marketed responsibly. In examining energy drinks it is important, however to understand the Canadian regulatory context for these products, which is already the most stringent in the world. 

In Canada energy Drinks are formulated, labelled and marketed in accordance with Health Canada's Natural Health Products (NHP) Regulation.  They are not regulated or labelled as foods as suggested by your editorial.

Energy drinks are intended for adults and clearly indicate on the label that this category of beverage is not recommended for children, pregnant or breastfeeding women and people who are sensitive to caffeine.  Unlike coffee, tea and iced coffee beverages which contain no caffeine labelling (and in many cases have quantities of caffeine much higher than a typical energy drink) and contrary to your editorial, all energy drinks have quantitative declaration of caffeine from all sources (natural and synthetic).  The consumer has simply to consult an energy drink label to verify this fact, something the industry actively encourages.

In Canada, by volume, mainstream energy drinks have approximately less caffeine than a cup of filter drip coffee (80 - 140 milligrams per energy drink vs. 179 milligrams per 237ml cup of coffee).  There are a few products with higher levels but they fall within the caffeine levels of one to two cups of coffee.  These products advise (on label) to consume only one per day and are a small part of a small market.  No where in Canada are there energy drink products with caffeine approaching the levels you suggest in your article, although Canadians regularly consume some coffee products that come close.

In 160 countries world wide energy drinks are sold as foods and are not subject to the same rigorous standards and requirements as they are in Canada.  This includes Demark and all EU countries where there are no restrictions on sale of these products.  Also contrary to your editorial, in Norway, energy drinks are not restricted to pharmacies. This is a fact that can be verified by contacting the embassies of the various jurisdictions.

Under Health Canada's requirements for the marketing of NHP products, energy drinks must be marketed in compliance with the   Consumer Advertising Guidelines for Marketed Health Products (for Non-prescription Drugs including Natural Health Products).  These guidelines are enforceable by Health Canada and require amongst other things for energy drink Manufacturers to market their products in line with their intended use (therefore if they are not recommended for children, they cannot be marketed to children).

As an industry we do agree that consumer education on the proper use and consumption of this unique product category is important.  It is for that reason that the industry has offered to partner with Health Canada on a consumer education campaign to better inform consumers.  Given that Health Canada estimates that 90% of Canadians' source of caffeine comes from coffee and tea products, this campaign does need to sensitize all Canadians to the sources of caffeine in their diets and to Health Canada's recommended intake levels of 400 mg per person per day and 2.5 mg per kg of body weight for children under the age of 12.

Justin Sherwood
President
Refreshments Canada

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