The FSANZ Board has approved Proposal P1056 — Caffeine Review — bringing the most significant overhaul of caffeine regulation in the ANZ Food Standards Code in years. Gazettal is anticipated for early June 2026, with a two-year transition closing in mid-2028. While the reform delivers welcome certainty for the sports nutrition sector, it introduces prohibitions and restrictions that will materially reshape the caffeinated retail landscape.

Here are the key areas of concern for retail products.

1. Caffeine Locked to Permitted Categories Only

Added caffeine will be prohibited in general foods unless expressly permitted. The only categories remaining open are:

  • Formulated Caffeinated Beverages (energy drinks)
  • Cola-type beverages
  • Formulated Supplementary Sports Foods (FSSF)

Everything outside those categories — caffeinated confectionery, chocolate bars with added caffeine, alertness snacks, caffeinated waters and gums — must reformulate, reclassify as a therapeutic good, or exit the market.

2. The Guarana Extract Loophole Closes

Guarana extract has long been treated by some operators as a permitted “naturally occurring” caffeine source despite often being standardised to 22% caffeine — many times the concentration of the raw seed. P1056 removes the natural-occurrence exemption for guarana extract entirely. Retail sale of guarana extract as a food, or as an ingredient in a food for retail sale, will be prohibited outside permitted categories. Brands relying on guarana for “natural caffeine” positioning will need to rethink.

3. The 200 mg FSSF Cap — Half the TGA Threshold

FSSF caffeine is capped at 200 mg per one-day quantity from all sources — exactly half the 400 mg permitted for TGA-listed medicines. A significant share of pre-workouts currently sit above 200 mg per serve. Options are reformulate, move to the ARTG as a listed medicine, or withdraw. The ARTG pathway preserves higher dosing but brings therapeutic-goods presentation requirements and stricter advertising rules.

4. New Concentration Limits in FSSF

Beyond the daily cap, FSSF face concentration ceilings:

  • 5% caffeine in powdered FSSF
  • 1% caffeine in liquid FSSF

For highly concentrated pre-workout powders with small serve sizes, and for liquid caffeine shots, the concentration limit may bite before the daily-quantity cap does.

5. Labelling Overhaul

FSSF containing caffeine will require a “contains caffeine” advisory, an unsuitability warning for under-15s and pregnant/breastfeeding women, and caffeine declaration in the NIP. Multipacks above 200 mg total face additional outer-pack and individual-portion labelling.

Packaged coffee-containing beverages with ≥200 mg caffeine per serve face equivalent obligations — NIP declaration per serve and per 100 mL, plus the high-caffeine warning. This captures the growing RTD high-caffeine coffee category (cold brews, bottled espresso, double-shot iced coffees). Café-poured coffee is unaffected.

6. Novel Food Risk for Other Plant Extracts

Caffeine-containing plant extracts beyond guarana — yerba mate, kola nut, concentrated green tea extracts — may qualify as novel foods requiring pre-market safety assessment. Brands sourcing such ingredients should audit approval status now.

What to Do Now

The two-year transition compresses quickly once reformulation, stability testing, label redesign and stock rotation are factored in. Priority actions:

  • Audit every SKU containing added caffeine or guarana extract.
  • Identify products exceeding 200 mg/day, breaching concentration limits, or sitting outside permitted categories.
  • Decide pathway by pathway — reformulate, ARTG-list, or withdraw.
  • Engage TGA expertise early for any ARTG candidates.
  • Redesign FSSF labels for the new warning, advisory and NIP requirements.
  • Review caffeine-containing plant extracts for novel-food exposure.
  • Lock transition plans to the confirmed gazettal date.

Bottom Line

P1056 is a deliberate response to the proliferation of caffeinated products in the food supply. For compliant operators in permitted categories it brings welcome certainty. For everyone else, the window to act is short and the strategic stakes are real. The retail aisles will look different in 2028 — the question is which products make it across the line.