The proposal would require:

• Declaration of quinine or caffeine in the ingredient list when used as a flavouring
• The label statement 'high caffeine content' and a declaration of the amount of caffeine when caffeine is used at more than 150 mg/kg or mg/l

The proposal is due to be discussed in the Standing Committee on Foodstuffs on 19 September. The FSA do not expect a vote to be taken at that meeting. If Member States are broadly in favour a vote may be taken at the December meeting of the Committee.

The FSA would be grateful for views on any aspect of the proposal. In particular, the FSA poses the following questions:

• Would this information be of value to consumers?
• Those who are sensitive to quinine will be aware of this. Should quinine declarations be accompanied by any form of warning?
• Should the 'high caffeine content' declaration be accompanied by a warning to sensitive groups? In this context, we note that the Food Advisory Committee discussed this issue in May 1999 and recommended that "soft drinks containing levels of caffeine greater than 125 mg/l should carry a clear statement on the label about the levels of caffeine present and an indication that they were unsuitable for young children or those sensitive to caffeine"
• Are there any other situations where significant amounts of caffeine or quinine might be added to a food without appearing in the ingredients list, apart from their use as flavourings?
• Should similar declarations be required for products which are inherently high in caffeine, such as guarana, coffee and tea? If so how should the legislation deal with the fact that the amount of caffeine in the food as consumed will depend on how it is prepared?
• What would be the costs to industry of introducing these declarations?

Comments are requested by no later than 17 September. Any comments received after that date will also be welcome but will be too late to take into account for the initial discussion on this draft directive.