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We welcomed this consultation as there is no evidence that caffeine and other stimulant substances contained in energy drinks have any benefit or place in the diet of children and adolescents.

Children get the energy they need from a healthy and varied diet, sleep, exercise and positive interactions with others. Energy drinks have no clear benefits in terms of providing energy, and there is a small but growing body of evidence to suggest that they can have a detrimental effect on children’s wellbeing. We firmly believe that we must adopt the precautionary principle in order to prevent harm, and that the sale of energy drinks to children should therefore be prohibited.

Our response (in brief)

• RCPCH are concerned that little is known about the safety profile of caffeine in young people.
• We are aware that concerns exist about the effects of caffeine even at the doses deemed ‘safe’ in terms of the cardiovascular system. 
• Evidence is emerging that consumption of caffeinated energy drinks among children and young people is associated with anxiety, depression, sensation seeking, poorer executive function, and increased hyperactivity and inattention. These manifest as increased psychological distress, poor behaviour, risky behaviours (such as substance use), and poorer academic attainment in maths and English.
• Energy drinks often contain a combination of multiple ingredients, including caffeine, sugar and/or sweeteners and amino acids. While there is a lack of evidence for the effects of ending the sale of energy drinks to children and young people, there is a plethora of evidence with regards to the effect of sugar. 
• It is well-known that children and young people in the UK consume more sugar and calories than required, and therefore they do not require the additional metabolic energy provided by the sugar present in caffeinated energy drinks. 
• As with other beverages with a high sugar content, consumption of energy drinks has been shown to be associated with adverse metabolic, dental and renal effects, including obesity, dental decay and kidney disease.
• Energy drink consumption has major adverse implications for oral health. Recent evidence suggests that Wales has the worst dental/oral health amongst the 4 UK nations with 1.7 million patients being treated in the 24-month period ending March 2020. In Wales, 51.4% of adults and 68.6% of children were treated.  Carbonated drinks, both sugar-free and those containing sugar, lead to enamel erosion, and research has linked the high acidity of these drinks to incidence of dental carries.

Our recommendations

• RCPCH believes there is sufficient evidence to act now to protect children. With the twin epidemics of obesity and mental health problems, we cannot afford to allow continued growth in consumption of products shown to worsen obesity and the wellbeing of our children
• In our State of Child Health, we welcomed and supported Welsh Government’s ‘Healthy Weight, Healthy Wales’ strategy, to prevent and reduce childhood obesity in Wales. 
• We called for a ban on advertising, sponsorship, and promotion of products high in fat, sugar, and salt (HFSS) products in public spaces including sporting events, family attractions and leisure centres should be implemented by 2030 which would include the sale of energy drinks
• We acknowledge comments that have been made previously with regard to the consumption of similar levels of caffeine in coffee and tea as in many energy drinks therefore we would support clearer labelling of all caffeinated drinks to indicate the amount of caffeine alongside the recommended levels for consumption
• Energy drinks contain a mixture of multiple ingredients and are usually carbonated; some of these ingredients have a known adverse impact on children’s health. Where the impact of ingredients is not known, RCPCH would fully support the Welsh Government in taking a precautionary approach in order to protect children.
• Energy drinks contain a large amount of sugar whereas tea and coffee do not, therefore there is not strong enough evidence to ban them.
• We know from speaking to almost 200 young people that the imagery and naming used in energy drink branding and advertising is a top reason for their choice in consuming them. Given these associations and concerns relating to energy drinks, we fully support the government in taking action to protect children with a ban on their sale.
• We would welcome further research into the consumption of caffeinated products by children and would suggest that the Welsh Government remains open and committed to reviewing the evidence base as part of the ongoing impact assessment of a ban on the sale of energy drinks to children.
• Use of caffeinated energy drinks has grown rapidly since their introduction in the late 1990s. Continued growth in consumption means that the proposed ban on sale will need further reinforcement through additional action on marketing and advertising, education and labelling in order to protect as many children as possible.
• In order for a ban to be effective it should apply to all food and drink sales outlets, including online sales and restaurants. In a clear commitment to improving the health of all children,
• RCPCH would also recommend that the ban on sales of energy drinks to children includes all healthcare premises.
• We would welcome a clear and consistent message for the ban on the sale of energy drinks to those under the age of 16 across all retail settings and online environments. We call on Welsh Government to lay out plans as to how this principle would be enforced across all settings and how this principle would be applied to the online environment and for delivery services.
• In order for a ban to be effective it should apply to vending machines as this would show a clear commitment to improving the health of all children and young people. We are aware vending machines are an alternative method of sale for energy drinks to children. Banning all sales of energy drinks from vending machines provides the easiest method to ensure under 16’s are not able to purchase energy drinks from vending machines, however, this approach would restrict supply to all age groups.
• An alternative option is to make sales of energy drinks from vending machines subject to age restrictions, to be enforced by the businesses or organisation on whose property the vending machine is located. If it is not possible for a location to restrict sale from vending machines by age, then energy drinks should not be located in their vending machines.
• Among students who reported drinking at least one energy drink per day, 23% receive free-school meals, whereas those who never drink energy drinks just 11% receive free school meals. This disproportionate consumption suggests that the ban may have greater impact and health benefits for children from lower socio-economic backgrounds. We would therefore recommend that potential impact on children from lower socioeconomic backgrounds is closely monitored and reviewed as part of the ongoing impact assessment of the ban.
• We would welcome further research into the consumption of heavily caffeinated products by children and would suggest the government remains open and committed to reviewing the evidence base as part of the ongoing impact assessment of a ban on the sale of energy drinks to children.
• We would recommend that the Government monitors for any unintended impacts of the ban, including potential substitution of energy drinks for other highly caffeinated or high sugar products.