Sale of High-Caffeine Energy Drinks to Under-16s Banned in the UK

The UK government is preparing to ban the sale of high-caffeine energy drinks to those under 16 starting April 6, 2027. The regulation, subject to parliamentary approval, will cover not only supermarkets but also restaurants, cafes, online food delivery channels, and vending machines. This will transform voluntary sales restrictions into a legal system for which food and beverage businesses will be directly responsible. According to The Caterer, the regulation will be implemented using powers under the Food Safety Act 1990.

Which products are covered by the regulation?

The age limit will apply to drinks containing more than 150 milligrams of caffeine per liter, excluding tea and coffee. In addition to ready-to-drink cans and bottles, high-caffeine powders, tablets, and concentrated drinks that are diluted or reconstituted before consumption will also be included.

Lower-caffeine soft drinks, as well as tea and coffee, will be exempt. Caffeine sachets, gums, and dietary supplements are not included in the definition of "beverage" targeted by the current decision. According to the UK government's consultation outcome, the product definition has been created in line with the thresholds used in existing high-caffeine warnings.

The regulation covers all businesses selling directly to consumers. Restaurants, cafes, fast food outlets, online sellers, and cash-and-carry points selling directly to consumers will be obligated. Sales between wholesalers will be excluded from the scope.

A stricter rule for vending machines

One of the most notable provisions for businesses concerns vending machines. The sale of high-caffeine energy drinks will be banned from all vending machines; the rule will not be limited to machines accessible to children. The person or business managing or controlling the area where the machine is located will be held responsible for the sales.

This provision requires a separate inventory exercise for hotels, sports and leisure facilities, employee break areas, mixed-use buildings, and self-service points. Using age verification technology will not be considered sufficient to continue vending machine sales under the model chosen by the government.

Penalties will vary based on business size

Local authorities will enforce the ban under the Food Safety Act 1990; inspections are expected to be primarily conducted by trading standards teams.

The fixed penalty for individuals and micro and small businesses with 49 or fewer employees is set at £1,500, while for medium and large businesses with 50 or more employees, it is £2,500. Authorities may resort to informal warnings, fixed penalties, or prosecution depending on the circumstances of the case.

Who is responsible for online orders?

The government will not mandate a single method for verifying age at the payment stage or upon delivery for online sales. Instead, the retailer will be responsible for ensuring that products are not sold to those under 16. The rule also applies to businesses that provide online food delivery.

This approach requires restaurants to review product listings, order flows, and courier delivery procedures on both their own websites and third-party delivery platforms.

The regulation may create a new training and compliance burden for businesses not accustomed to selling age-restricted products, such as fast food restaurants. The government acknowledges this operational risk following the consultation; guidance is planned to be published for industry associations, local authorities, and businesses before implementation. The final impact assessment has not yet been published.

Strong health rationale, but careful use of evidence language is needed

The government estimates that around 100,000 children in the UK consume high-caffeine energy drinks daily. Concerns about children's physical and mental health and educational outcomes form the basis of the decision.

The studies underpinning the decision include a 2024 systematic review that compiles research reporting relationships between energy drink consumption in children and adolescents and sleep issues, anxiety, low academic performance, and various physical or mental outcomes.

However, the government's consultation outcome clearly acknowledges that existing studies are largely observational and do not establish direct causality. The beverage industry has also raised objections regarding the proportionality of the regulation and the strength of the evidence.

The British Soft Drinks Association stated that its members have voluntary rules not to market to those under 16 and to use warnings on products indicating they are not recommended for children, arguing that the new legislation should be based on a comprehensive evidence assessment. The government concluded that voluntary measures do not prevent children's access across all sales channels.

What should restaurants and cafes prepare?

The first step should be to categorize the product inventory not by brand name but by the caffeine content on the label. Ready-to-drink and reconstituted products exceeding the 150 milligrams per liter threshold should be marked.

Then businesses will need to:

• add age warnings to POS systems,

• create ID check procedures for cash and table service staff,

• update online product and delivery flows,

• remove products from vending machines,

• document employee training and responsibility distribution

These preparations align with the government's approach of allowing businesses at least six months for implementation and supporting staff training and system updates.

On the menu development side, businesses can increase lower-caffeine or caffeine-free alternatives aimed at young customers. However, the mere presence of terms like "energy," "performance," or similar in the product name is not sufficient for legal classification; the decisive factor will be the product definition and caffeine threshold in the final legislation.

Turkey has stricter age limits

In Turkey, the 2017 Turkish Food Codex Energy Drinks Regulation limits the total caffeine content in energy drinks to a maximum of 150 milligrams per liter and prohibits sales to those under 18. The regulation also prevents the marketing and supply of these products in sports facilities, school canteens, and hospitals.

The official regulation text also stipulates that the product must be presented in a way that maintains packaging integrity in mass consumption venues and prohibits direct or indirect advertising of energy drinks. Product labels must include warnings against consumption by children and those under 18, as well as statements about not mixing with alcohol.

Therefore, the development in the UK does not directly create a new ban model for Turkey but offers an opportunity to compare how existing rules are applied in HORECA operations.

For restaurants, cafes, bars, and hotels in Turkey, the main issue is not to wait for a new age limit but to check whether the existing 18-year rule, closed packaging presentation, advertising restrictions, and label warnings are consistently applied in the field.

Stafflink's view

The UK's decision indicates that the management of age-restricted products could extend to beverage categories beyond alcoholic drinks and tobacco. For HORECA businesses, the main cost will not be removing a few products from the menu but establishing processes that flawlessly apply the same rule across cash, service, delivery, and vending channels.

According to Stafflink, businesses should not view compliance with the regulation merely as the front desk staff "asking for ID." Accurate maintenance of product data, formalizing responsibility sharing with platforms, documenting shift training, and having a clear management policy that supports employees against customer pressure during age checks are necessary.

The success of the rule will be determined more by how consistently these operational details are applied in the field than by the legal text.