
The butterfly effect is crazy because what if soda companies never successfully used the “flavor enhancer” argument with the FDA almost a half-century ago...the almost $26 billion U.S. energy drinks market likely wouldn't exist today! Though, before we get into that FDA decision from 1980, you must first understand that the original recipes of both Coca-Cola and Pepsi included kola nuts, which contained caffeine but also provided a distinctive bitter flavor. Eventually, largely due to concerns about cost and product consistency…the “cola” flavor we recognize today is not the taste of the kola nut itself. Instead, it’s a complex blend of multiple ingredients (including a standardized, isolated form of caffeine). So, with that industry shift in product and supply chain strategy, it no longer mattered if you were a cola beverage or a citrus-flavored soda like Mountain Dew…caffeine became a food additive. And that means…when the Tip Corporation acquired Mountain Dew from its founders in 1960, its decision to revamp the recipe (adding more caffeine than the typical cola) wasn’t just paramount to the beverage’s success but also to our butterfly effect. But throughout the 1970s, health concerns surrounding caffeine intensified…and by 1980, consumer advocacy groups started petitioning the FDA to remove caffeine from its "generally recognized as safe" (GRAS) food additives list. But in response to the FDA questioning the GRAS status of caffeine, packaged beverage manufacurers argued that they used the ingredient as a "flavor enhancer," not for its stimulant effects. Though, in the fall of 1980, the FDA proposed that caffeine be removed from the "Generally Recognized as Safe" (GRAS) list but stopped short of banning it, citing the need for further safety tests. Instead, the FDA made caffeine an interim food additive…and in the meantime, placed a limit on the amount that could be added to carbonated soft drinks. This decision was widely criticized by consumer advocacy groups, who proclaimed the FDA caved to the powerful beverage industry. But maybe even more infuriating, the FDA proposal to remove caffeine from the GRAS list (essentially reclassifying caffeine as a drug), which would have obviously put significant restrictions on its use in foods and beverages, was never finalized. But the ensuing regulatory uncertainty created a new pathway for beverages with high caffeine levels to enter the market under a different category. Under the 1994 Dietary Supplement Health and Education Act (DSHEA), ingredients like caffeine were presumed safe for use in dietary supplements unless the FDA could prove otherwise. This created basically a dual regulatory system where the same ingredient (caffeine) was treated differently depending on the product classification…allowing dietary supplement companies to develop and market “drinks” with much higher caffeine levels. And it resulted in the development of an entirely new beverage category, with modern energy drinks like Red Bull entering the U.S. market about three decades ago. This butterfly effect was crazy, right? If soda companies never successfully used the “flavor enhancer” argument with the FDA in 1980, today’s U.S. energy drinks market wouldn’t be $26 billion dollars in retail sales. Moreover, energy drinks would not have become status symbols…or basically aspirational mixtures, representing lifestyle taste and identity by association, making it arguably the most important beverage category.