Listen to this post

In an industry full of buzzwords, “adaptogens” and “nootropics” are current standouts within the beverage industry.

The beverage industry experienced a significant shift in consumer preference following the COVID-19 pandemic, as consumers’ proclivity for nutrient-rich foods stimulated a rise in beverages designed to provide added health benefits, such as increasing energy, decreasing stress, and improving overall mental health. The increased popularity of these “functional beverages” (i.e., beverages that provide added health benefits) is more than a fleeting trend, as the industry is projected to reach $62 billion by 2027.

What is a functional beverage?

As previously discussed, there is no legal definition for functional beverages. However, functional beverages are commonly thought of as products that purport to do more than provide fluids and quench thirst—they provide additional “health benefits not found in conventional beverages.” These “health benefits” are often linked to the functional ingredients included in the product. Common functional ingredients include “adaptogens” and “nootropics.”

In this post, we will define adaptogens and nootropics and provide common examples of each type of substance. In addition, we will highlight the different claims brands may make about their products containing adaptogens and/or nootropics.

Before reading further, it is important to understand that the statutes and regulations applicable to your product will ultimately depend on whether your product is categorized as a beverage or liquid dietary supplement. As our free report highlights, a product’s classification may be affected by factors such as health claims and recommended usage.

What Are Adaptogens?

Adaptogens are plant substances (such as roots, herbs, and mushrooms) that help the body manage stress and mitigate fatigue. However, not all plant substances are adaptogens. To be categorized as an adaptogen, a substance must be non-toxic, it must help increase the body’s resistance to environmental stress, and it must help the body maintain a state of homeostasis.

Adaptogens are typically consumed in pill or tincture form; however, the recent rise in the popularity of functional beverages has increased the prevalence of adaptogen-infused beverages.

The term “adaptogen” was first used by scientists in the former USSR to describe plant-originated substances that:

  1. Assisted the body in resisting stress;
  2. Resisted physical ailments caused by external stress; and
  3. Did not harm the normal functions of the body.

Today, adaptogens are more commonly thought of as plants and mushrooms that help the body resist and adapt to physical, emotional, and environmental stressors.

Despite the presence of adaptogens in traditional medicine, adaptogens remain subject to ongoing research to support their purported health benefits. Nonetheless, studies have revealed that adaptogens may have anti-fatigue, anti-depression, and stimulating effects on the body.

Examples of adaptogens commonly found in functional beverages include, among others:

  • Ashwagandha
  • American ginseng
  • Cordyceps
  • Lion’s Mane
  • Reishi

These substances have been credited with stress-relief, boosting immunity, and improving mental clarity, among other health claims.

Adaptogen-infused beverages are becoming increasingly popular alternatives to traditional alcoholic beverages. Additionally, consumers are consuming adaptogen-infused beverages as alternatives to energy drinks that often contain a high level of caffeine. Adaptogen-infused beverages purport to provide a more balanced increase in energy while also calming anxiety and reducing stress.

What Are Nootropics?

Nootropics are ingredients that support cognitive function to improve memory, motivation, attentiveness, and energy levels. Nootropics are commonly referred to as “smart drugs” because of their ability to enhance thinking, learning, and memory. Nootropics work by increasing cognitive abilities by targeting specific aspects of brain functions, such as neurotransmitters and blood flow.

Like adaptogens, nootropics were historically consumed in pill form prior to the increased consumer demand for beverages providing added health benefits. However, unlike adaptogens, which are derived solely from plant substances, nootropics may be synthetically or naturally derived.

While widely available in supplement form, prescription nootropics (such as Modafinil) are also commonplace. Prescription nootropics are typically used to treat Alzheimer’s and ADHD, along with other diseases that affect cognitive functioning.

Examples of over-the-counter nootropics commonly found in functional beverages include, among others:

  • Caffeine
  • Gingko biloba
  • Creatine

These substances have been credited with improving creativity, motivation, and mental stimulation, among other health claims.

While nootropic beverages are not a new development—humans have been consuming coffee and tea for millennia—the functional beverage industry has only recently started adding nootropic ingredients (such as B vitamins) to their products in an effort to meet consumer demand for beverages with added health benefits.

What is the Difference Between Adaptogens and Nootropics?

Simply put, adaptogens are used to ease the effects of stress on the body, while nootropics are used to stimulate cognitive function.

Today, functional beverages containing adaptogens may claim that the product promotes a calmer mind or boost immunity, whereas functional beverages containing nootropics may advertise stronger focus  or sustained energy. Accordingly, it is not surprising that functional beverages have embraced adaptogens and nootropics as brands look to leverage these health-related claims to promote their products.

It is important to note that a product’s classification as either a beverage or liquid dietary supplement will affect the types of claims that may be made about the product—whether on the product label or as part of the product’s marketing. As our free report highlights, there are three categories of claims defined by the Federal Food, Drug, and Cosmetic Act (FDCA) and FDA regulations: health claims, nutrient content claims, and structure/function claims

Functional beverages commonly make structure/function claims—claims that describe the role of a nutrient or dietary ingredient in maintaining the normal structure or function of the human body.

Notably, beverages are limited to making structure/function claims that are tied to a nutrient (not an ingredient) in the product. In contrast, liquid dietary supplements can make broad structure/function claims that apply to the whole product (without focusing on nutritive value).

Whether your product contains adaptogens, nootropics, or both, it is important to ensure that any claims made about your product (whether on the product’s label or through any marketing efforts) are truthful and substantiated (meaning that there is competent and reliable scientific evidence supporting such claim at the time the claim is made).

The Future of Functional Beverages

In light of the growing consumer appetite for functional beverages purporting to provide added health benefits (such as boosting energy, mitigating stress, and bolstering mental well-being), we expect that the demand for products containing adaptogens and nootropics will continue to climb and increasingly dominate the functional beverage market.

In this new era of drinkable wellness, beverages with adaptogens and nootropics not only provide essential hydration but potentially other added health benefits. We anticipate that functional beverage brands will continue leveraging this newfound consumer demand for health-conscious beverages by infusing their products with adaptogens and nootropics as a means to bolster the health claims that are essential to their marketing initiatives.

Therefore, it is important for functional beverage companies to ensure compliance with applicable state and federal law, including FDA regulations regarding the use of any health claims. If a business fails to comply with all labeling and marketing requirements (e.g., ensuring that all claims are truthful and not misleading), then FDA would consider that the product is misbranded and, therefore, illegal.

Husch Blackwell has significant experience advising functional beverage businesses on state and federal regulations, including product formulation, labeling, and appropriate warnings. Contact Megan Beebe for further information.

Law clerk Alexandria Pontious also assisted with the development of this blog post.