On the 28th of September 2023; we received a “letter of improvement” from the Ministry of Primary Industries (MPI) regarding our Supplemented Food Products (our drinks and powders). Since launching our products in 2017, we've worked closely with MPI, regularly updating our packaging. However, MPI expressed concerns that some of our website/advertising communications and our packaging did not adequately convey the benefits in line with the pre-approved Vitamin C health claims of the ANZ Foodcode.
See the statement below:
Alphagen NZ Limited have received Notice from New Zealand Food Safety regarding the health claims we make about our Ārepa products and the labelling of our products. Some of our health claims are in breach of the Australia New Zealand Food Standards Code. Health claims attributed to Enzogenol (pine bark extract) and L-theanine have not been substantiated. Health claims that can be attributed to the vitamin C content do not identify that vitamin C is responsible for the health benefit. We will be working with New Zealand Food Safety to remove or correct the health claims on the Ārepa product labels and advertising material.
We have since updated our packaging and will be rolling this our early 2024. We added a "+" after the product name to further clarify the implied health claim and connect it to the Vitamin C statement on the back, as per the ANZ food code standards. (See below).
Statement on back of packaging
Your Brain is Amazing.
And it's even more amazing when it's full of the polyphenols, vitamin C and antioxidants found in our clinically researched† natural ingredients. Developed by neuroscientists to help support cognitive performance and neurological function. Arepa is the drink for everyone with a brain.
Updated statement on back of packaging
Your Brain is Amazing.
Developed by neuroscientists with clinically researched ingredients, this is a drink for everyone with a brain. †Drinking Ārepa reduces tiredness and fatigue and helps with normal psychological and neurological function thanks to the high Vitamin C content in our Neuroberry® Blackcurrants as part of a healthy and varied diet.
While Ārepa's three main active ingredients — Neuroberry blackcurrant, L-theanine, and Pine bark — currently do not have any “pre-approved health claims” in the ANZ food standards (2016). Ārepa is currently working on submitting multiple self-substantiated dossiers for our ingredients, a process typically reserved for larger multinational corporations. We aim to complete this by early 2024. Until then, we can only link our benefits with the pre-approved health claims under the ANZ food standards (2016).
Our claims will be identified by “+” next to it, this is to clearly link it to the Vitamin C statement until our self-substantiated dossier is complete.
Our dietary context statement:
†Ārepa is a supplemented food for the brain that contains Neuroberry® Blackcurrants that are very high in Vitamin C. Vitamin C is necessary for normal neurological function and contributes to normal psychological function, energy metabolism, immune system function and helps reduce tiredness and fatigue (as part of a healthy varied diet). This can help your brain perform and assists with mental calmness and clarity.
Blackcurrants have polyphenols plus unusually high levels of vitamin C (an antioxidant) for a berry fruit, even higher than blueberries, raspberries and strawberries.
Enzogenol® is an ultra-pure extract from the bark of New Zealand grown pine trees - a broad-spectrum polyphenol extract.
L-theanine (Suntheanine®) is a rare amino acid. It is isolated from green tea via a fermentation process from, allowing it to be caffeine-free.
Our Brain Capsules are regulated under a different standards (dietary supplement) compared to our Drinks and Powders (supplemented foods). For any health benefit claim related to a specific ingredient under the Therapeutic Products Act, we need to be able to provide substantial evidence backed by credible and reliable scientific and medical research.
This means relying on: "Tests, analyses, research, studies, or other evidence conducted and evaluated objectively by qualified professionals, using generally accepted procedures to yield accurate and reliable results."
Led by Professor Andrew Schloey, our formulas only use ingredients supported by extensive peer-reviewed research. This allows us to make more direct claims about the specific ingredients in the Capsules (Neuroberry Extract, L-theanine, and Pine bark). We will now be clearly identifying how we speak about the ingredients used in our capsules to not cause confusion between the Therapeutic Products Act and the ANZ Food Standards.
Since Ārepa’s launch, we have been featured in the media for various achievements and research findings.
2 Nov 2023, an article was published concerning the MPI Letter of improvement as described above. Unfortunately, this process led to misunderstandings and, we believe, misrepresentation of the issues.
Further, an incorrect statement released by Auckland University (later corrected*) stated:
Scientist who ran Ārepa study available for comment:...
Neuroscientist Dr Nick Gant, of the University of Auckland,[1] ran the only randomised controlled trial of the effects of the drink Ārepa , funded by the company[2] in order to support product claims.[3] The study showed no benefits , and[4] he and others involved have voiced concerns about claims made for the drink. Dr Gant is available to comment on the science supporting the marketing and claims behind this and other brain foods, and their impact on consumers.
This statement contained several inaccuracies:
[1] There have been two published and peer reviews randomised controlled studies on Ārepa’s current formula, plus Nick Gant’s trial on a different formula.
[2] The study referenced was a prototype test, not intended for claim support, as Ārepa was not yet in the market.
[3] The study on the prototype did not show benefits, which led us to discard that formula.
[4] We are unaware of any concerns from scientists involved in the two published and peer-reviewed studies on our current formula.
Below is the retraction issued to NZ media 22 November 2023:
A 2 November item relating to Ārepa contained mistakes. Dr Nick Gant worked on a randomised, controlled trial (RCT) of a prototype formula of Ārepa, not the final version of the drink. Also, the study was not the only RCT in connection with the drink.
While this statement doesn't cover any of the incorrect reporting that followed, it does help clarify the truth to our clinical studies. See below for our full study history.
University of Auckland, by Nick Gant, on a PROTOTYPE formula using an apple-based juice and capsules.
The results from this study did not find anything statistically significant. We took these learnings and updated and changed ingredients and improved our formula. - The formula that was tested never made it to market.
Clinical Trial 1 on Ārepa's current formula, University of Auckland by Natalie Gibson, Dane Baker, Alice Sharples & Andrea Braakhuis.
The results indicate that the BC+(Ārepa) drink may be useful for athletes. It was a cross-over design, randomized, double-blind, controlled trial and was peer reviewed and published in PubMed - find abstract here.
Clinical Trial 2 on Ārepa's current formula University of Auckland by Lillian C. Morton, Carl D. Paton, Troy Merry & Andrea Braakhuis
The results indicate that PB supplementation may provide small benefits to performance and reduce cough symptoms during high-intensity exercise in ozone-polluted environments. Was a randomised, double-blind, controlled trial and was peer reviewed and published in the European Journal of Applied Physiology.
Testing cyclist under pollution environments testing cognitive markers in bloods.
Estimated Publish Date: Q1 2024
Study testing Ārepa Performance, testing acute effects of the formula.
Estimated Publish Date: Q1 2024
Study in a range of healthy women testing a range of cognitive measures.
Estimated Publish Date: Q1 2024
Study testing Ārepa Performance on a range of health adults aged above 55 years.
Estimated Published Date: Q2 2024
Estimated: 2025
Estimated: 2025
Estimated: 2025
Estimated: 2026
Please note: nothing on this page of the website should be taken as a health claim relating to Ārepa, and merely is to provide background on current and previous scientific research that we are conducting to further improve our products.