FDA Citizen Petition: Total Caffeine Labeling for Dietary Supplements

In August 2026, Food Foundations filed an FDA Citizen Petition asking the U.S. Food and Drug Administration to change how caffeine is disclosed on dietary supplement labels. The petition, FDA-2026-P-8648, asks that caffeine-containing dietary supplements give one clear total caffeine amount per labeled serving across all caffeine sources. FDA received the petition on August 3 and posted it to Regulations.gov on August 5.

An FDA Citizen Petition is a formal way for a person or organization to ask the agency to issue, change, or cancel a regulation or take another administrative action. Filing one puts a request before FDA. It does not change a rule on its own. Although anyone can use the process, citizen petitions are much more commonly filed by regulated companies, especially pharmaceutical manufacturers, often with law firms involved in preparing or submitting them. Based on our review of publicly available FDA records, we found only one earlier example of a citizen petition led by a minor, making ours the second such docketed effort we were able to identify.

Why total caffeine can be hard to find

Some supplement labels can tell a consumer that caffeine is present without giving one number for the total caffeine in the serving. This can happen when caffeine comes from more than one ingredient or when an ingredient is part of a proprietary blend.

Under FDA’s current supplement-labeling rules, a proprietary blend can state the total weight of the blend without giving an individual amount for every ingredient inside it. A consumer can see which dietary ingredients are in the product and still not know the total milligrams of caffeine in the labeled serving.

Someone deciding whether or when to take a supplement may want the total caffeine amount before making that decision.

What the petition asks FDA to change

The petition asks FDA to require one total caffeine amount per labeled serving, calculated across all caffeine sources in the supplement. The number would be available as a single total even when the caffeine comes from multiple ingredients.

For a consumer reading the label, that total is the main proposed change. FDA still has to decide what action, if any, to take on the petition.

Preparing the petition

We worked with co-petitioners on the petition’s factual support, citations, regulatory framing, wording, and revisions. The filing had to connect the labeling problem to a specific regulatory request and support that request with sources. Unlike the companies and attorneys who make up much of the citizen-petition system, we submitted the petition while we were still minors.

We also shared the petition with researchers and public-health specialists for independent review.

The public docket

Once the petition was in the public FDA docket, interested people could submit comments that become part of the record. FDA’s citizen-petition rules allow a comment to support or oppose a petition in whole or in part.

A comment from a consumer

One public comment came from Patrick Ciriello, a Vermont consumer who was profiled by The Guardian earlier in 2026. His comment was unsolicited. He explained that knowing the exact caffeine content would help him decide whether and when to take a supplement.

For Food Foundations, the useful part of the comment was its specificity. He named a decision the total caffeine amount would help him make.

After filing

FDA has not accepted the requested change. The petition is still a request before the agency.

So far, Food Foundations has focused mainly on direct nutrition education through workshops and community activities. With this petition, that work now also includes federal food-labeling advocacy.

Thank you to the co-petitioners who worked on the filing and to the researchers and public-health specialists who reviewed it. We also appreciate Patrick Ciriello taking the time to comment. Food Foundations will continue its direct nutrition education while developing its work on food-labeling advocacy.