1. What is the law regulating Energy Drinks in Bangladesh and in which food/beverage category are energy drinks classified?
Energy Drinks in Bangladesh are regulated by The Pure food ordinance, 1959 and The Pure food Rules, 1967.
As per sub-clause (5) of section 3 of The Pure food ordinance, 1969, “food” means any kind of edible oil, fish, fruit, meat or vegetable or any other article used as food, drinking water or any other drink for human consumption other than any drug, and includes ice, aerated water, carbonated water or any substance whether processed, semi processed or raw or any substance which has been used in the manufacture, preparation or treatment of food and those articles which will be notified by the Government from time to time, and-
(a) any substance which is intended for use in the composition or preparation of food,
(b) any permitted flavouring matter or any spice or condiment, and
(c) any food grade colouring matter, preservative, anti oxidant and other additives intended for use in food;
Though energy drinks are not explicitly mentioned in this sub-clause, energy drinks and soft drinks will fall in the category of aerated water or carbonated water and therefore defined as food.
2. Whether it is permissible to use artificial sweetener “Sucralose” (E-955) in Energy Drinks under Bangladesh Food Laws?
Sucralose is an artificial non-nutritive sweetener. Its molecular formula is C12H19Cl3O8. It is also known under the E number (additive code) E955. Sucralose is approximately 600 times as sweet as sucrose (table sugar), twice as sweet as saccharin.
Rule 26 of the Pure Food Rules, 1967 deals with Non-nutritive constituent in food. Rule 26 states that-
(1) Any article of food to which has been added a non-nutritive constituent, that is to say, a constituent which is not utilized in normal metabolism, in contravention of this rule, shall be deemed to be adulterated-
(2) Any food which purports to be or provides for any constituent which is not utilized in normal metabolism shall bear on its label a statement of the percentage of such constituent along with the name of such constituent and the word ‘non-nutritive’.
(3) If the non-nutritive constituent is saccharin or a saccharin salt, the label shall bear, in lieu of the statement prescribed in sub-rule (1) the statement ‘contains saccharin………. (or saccharin salt, as the case may be), a non-nutritive artificial sweetener which should be, used only by persons who must restrict their intake of ordinary sweets. The blank to be filed in with the percentage of saccharin or saccharin salt in such food.
(4) The following non-nutritive sweeteners may be used in place of saccharin or its slats subject to the same conditions regarding the statement on the label-
(a) Calcium cyclohexyl-sulphamte
(b) Sodium cyclohexyl-sulphamte
(5) The label statement of foods containing non-nutritive sweeteners shall also conform to the requirements of other rules.
(6) Non-nutritive sweeteners and sugar shall not be used in combination in any food.
Therefore, though there is no specific reference of Sucralose in this particular Rule or anywhere else in the The Pure food Rules, 1967 or The Pure food ordinance, 1959, it is apparent that Sucralose is not prohibited in food items. Consequently, provisions of non-nutritive constituents would be applicable to Sucralose.
3. Details of concentration in which artificial sweetener “Sucralose” (E-955) is permitted under Bangladesh Food Laws?
As we said earlier that there is no specific reference of Sucralose in this particular Rule or anywhere else in the The Pure food Rules, 1967 or The Pure food ordinance, 1959, no details of ‘concentration in which Sucralose is permitted’ is available under Bangladesh Food Laws.
4. Are there any labeling issues associated with the usage of “Sucralose” in Beverages?
Sub-rule (7) of Rule 26 provides that-
Saccharin, sucaryl or any other non-nutritive sweetener shall not be sold, unless the package carries a label showing:
(a) The common name
(b) The chemical name
(c) The net weight
(d) Adequate directions for use in foods; and
(e) The address of manufacturer.
Since we mentioned earlier that provisions of non-nutritive constituents would be applicable to Sucralose, the said sub-rule purports to be relevant in case of Sucralose too.
5. Example of other Beverage products sold in Bangladesh which contain “Sucralose”.
The Energy Drink market in Bangladesh has been boosted highly in past few years. Local brands are giving tough competition to the foreign ones. The most popular local brands are Royal Tiger, Black Horse, Shark, Speed, Wild Brew, Big Boss, Crown etc. Simultaneously Blox, Bullet, Commando, Red Bull etc. overseas brands are doing brisk business in Bangladesh.
However, Sucralose is not stated in the labels (showing the ingredients) of any of the said drinks.
The followings are the ingredients used (as stated in the labels) in different energy drinks sold in Bangladesh.
Glucono Delta Lactone
Vitamins (B3, B5, B6)
Citric Acid (Anhydrous)
Mixed Fruit Flavour
Glucono Delta Lactone
Vitamins (B3, B5, B6, B12)
Food Grade color (E102, E110)
Food Grade Flavour
Acidulant citric acid
Colorant E-129 & 133
Vitamins (B6, B12)
Natural mineral water
Acidifier (E 330)
Glucose Fructose Syrup
Acidity Regulator (E 331)
Colouring (E 150C)
Vitamins (B6, B12)
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 Amended by section 2 of the Bangladesh Pure Food (Amendment) Act, 2005 (Act No. XXVII of 2005).
 A non-nutritive sweetener just has sweetness; it has no food value, no minerals, no fiber, and nothing that one’s body will metabolize.