Theobromine, stimulants, and ingredient lists

Does anyone know of theobromine (or other stimulants) have to be explicitly listed in food ingredient lists in the US?

I have these Oreo candy canes that are chocolate flavored. They don’t list caffeine or theobromine, which are ingredients I avoid. But they do include “natural and artificial flavors” in the ingredients.

I tried to find a list of ingredients that can be listed under that, but I could not. I did find a list of all safe ingredients by the FDA, but it didn’t seem to specify which ones had to be explicitly labeled.

The reason I am concerned is that I can’t find any info on a chocolate flavoring that does not contain theobromine. But, at the same time, it seems odd that a stimulant could be listed as a flavoring, since many people need to avoid stimulants like for heart conditions and such.

I’m hoping one of you know, or have better google-fu than me.

Well, there’s this:

Currently, no foods or beverages that contain caffeine are required to include caffeine content on their labels.

I think you can be confident that chocolate flavoring contains caffeine and theobromine, since that comes from the cacao beans. It isn’t some extra ingredient. I’m not even sure you can remove theobromine from chocolate, unless you count abominations like white “chocolate.”

To be clear, the candy does not list chocolate or cocoa or cacao or anything like that.

And caffeine is listed on every ingredient list I’ve ever seen if it is actually added. It just isn’t when it is part of another ingredient. If it weren’t, then I’d expect a lot more people who can’t consume it to be harmed. That is why the FDA is supposed to list ingredients, to avoid causing harm.

The ingredients on these candies is just

SUGAR, CORN SYRUP, NATURAL & ARTIFICIAL FLAVOR, COLOR ADDED (RED 40, BLUE 1, YELLOW 5).

If it actually mentioned anything related to chocolate, then I wouldn’t be asking.

If it says chocolate-flavored on the box, then it must contain cocoa:

It may not technically be chocolate, but it will derive from cacao beans. And since those beans contain theobromide and caffeine, then so does the final product.

On the other hand, if it just says Oreo-flavored… then I dunno. But if it nevertheless contained cacao beans and therefore theobromine, despite it not being on being explicitly labeled.

Now that I’ve checked your source link, it does say that caffeine is required to be labeled on foods with added caffeine. The only thing it lists as not needing it to be specified are naturally caffeinated drinks like coffee.

So I am at least sufficiently convinced these candy canes do not contain caffeine. Logically I’d expect theobromine to be treated the same way, since it is a metabolite of caffeine in the human body, but I know regulations aren’t always logical.

No one’s going to add caffeine to candy canes as an explicit flavor component. Unless they’re “Panera™ brand Charged™ candy canes.” It’s going to come alongside the cocoa. If there is actually cocoa there, which I don’t think you know yet. It could just be one of the “natural flavors”.

Does the box say chocolate-flavored? I’m talking the description here, not the ingredient list.

Fairly sure that cocoa extracts would be considered a “natural flavor”:

The only confidence I’d have is that if it did contain something resembling actual cocoa, they’d probably want to say that explicitly, since it sounds better than the generic “natural and artificial flavor”.

Not exactly an answer, but this is the gotcha under the current regulations.

There are ingredients which (simplifying) are whatever stuffs are poured into the pot to make the product. Then there are constituents, which are the chemical components the ingredients contain. The requirement is to label the ingredients, not the constituents.

The exception being the short list of USDA recognized allergens that have to be listed separately from the ingredients because even at constituent quantities they can be harmful.

Which leads of course to the labels folks like to poke fun at. E.g. a jar of peanut butter where the ingredient list says “Peanuts, salt”, then the allergen list says “contains peanuts”. About the third time the label says “peanuts” on it you’d hope customers figured it out. “No shit Sherlock. Har har”. But of course there is a good reason for each section of that labeling.

The challenge comes in for folks like our OP who apparently has a sensitivity to (or dietary preference against) a constituent that is not a recognized allergen.

And yes “natural and artificial flavors” is a great rug to hide all sorts of constituents under.

Which reminds me of the shenanigans that manufactures will use to avoid listing MSG. Those countries using E numbers will list E 621 on the ingredients for added MSG. But what about “hydrolysed vegetable protein”? Surely that is much less an evil ingredient, it sounds even possibly a natural ingredient. Made of vegetables after all. Well if you cook up the appropriate vegetable matter in the right way, it is about 50% MSG. But since you didn’t add pure MSG to the mix, you don’t have to list it.

Nor do you see MSG listed as an ingredient in hard cheese or tomatoes.

But people are funny. The moment they see it listed in the ingredients they will get a headache. Or just not buy it.

I would just remind you that the binary name of the cocoa tree is Theobroma cacao. Possibly white chocolate doesn’t have theobromine in it, but it is hard to imagine any real cocoa product that omits it. Incidentally theobroma in Latin means food of the gods.

That checks out. Even bad chocolate is better than ambrosia.

White chocolate is made from cocoa butter, which is also called theobroma oil. It’s definitely a cocoa product.

I was, however, surprised to learn just now that it (cocoa butter) contains only trace amounts of theobromine or caffeine.

Well, psychosomatic results are real. If you think that eating MSG gives you a migraine, then is probably will, even tho MSG does not cause migraines or headaches.

Most natural ingredients dont have their contents spelled out, that would be insane. Only added stuff. So, on coffee you would not list caffeine, unless they added extra.

However, I do not think that “natural and artificial flavors” would have theobromine or caffeine. They would have to list those separately, since they are not flavors.

But cocoa extract, which happens to contain theobromine and caffeine, is a natural flavor. They aren’t being added separately. I don’t know if that’s the case here, but I don’t think it can be excluded.