Is Your CBD Product Labeled Correctly?
Updated: Mar 15, 2019
Hundreds of new CBD products are hitting the shelves daily, is your product a food or supplement and what are the differences in labeling.
Is your CBD product labeled correctly?
The hemp and cannabidiol (CBD) Business is projected to grow to 22 Billion by year 2022, and is expected to surpass the tetrahydrocannabinol (THC) business by 2 billion dollars. This surge in growth has entrepreneurs at both a retail and manufacturing level starting up daily.
With all the new start-ups and new forms of CBD from tinctures, edibles, topicals and any form you can imagine there is cause for confusion as to how each product should be labeled. CBD Follow has the following recommendations before you put that product on your shelf for sale.
1) Determining the type of Label
Is your product a supplement or food item? You need to consider the directions for use as well as the intended use of the product. For example if your product is a capsule, soft gel or oral spray then it is considered a supplement. Oil drops with a suggested serving size are also considered supplements.
If it is a food or beverage, then size and suggested serving size will determine the label. If it is a beverage or edible that is meant to be consumed at once then it is considered a food item. If it is a larger serving with suggested servings greater than one then it is more likely a supplement.
All products in the supplement category must follow the following FDA labeling regulations for dietary supplements.
2) The Front of your Label
The front of your label MUST include the following information:
• The NET WEIGHT(Volume if a liquid) OR
• The COUNT (Number of tablets or capsules in the container)
*If your product is being sold in a dispensary then it must also include the total amount of the main nutrient (CBD for example) or active ingredients contents.
Also required is what is called a Statement of Identity. What is the common name for the product being sold ? is it a “Dietary Supplement”, a “tincture” or “oil”, “dark chocolate”.
3) Facts Label
If your product is identified as a Supplement then you must include a Supplement Facts Label. You will need to identify the part of the hemp plant used. The total amount of hemp extract or oil in milligrams per serving.
If your product is a Food or Beverage then you will need to use a Nutritional Facts Panel. You can refer to the FDA Food Labeling Guide.
Bottom Line is if you want to make sure your product is labeled correctly you should follow the FDA’s Labeling Guidance documents for Dietary Supplementsand for Foods, when applicable. Refer to these resources for all the labeling requirements.
If you are only selling your product in-state then you must go by your states labeling laws.
For best results use an experienced agency for your label graphics.
California Labeling DO’s
• Display information clearly and legibly
• Make sure all labeling information is seen on the outer layer of packaging
• Use English and at least a 6 point font
• Include both THC and CBD content on primary label
California Labeling DON’Ts
• Cannot include name of California County anywhere on label unless 100% of product was grown there.
• Cannot be attractive to children- this includes cartoons, imitating candy or even using the words “candy” or “candies” anywhere on the label
• Cannot include false or misleading information – this includes anything untrue or unproven.
• Cannot make unproven health claims – this includes claims of treating a disease. Please note that health related statements are extensively regulated by the FDA.
• Modifications to the Universal Symbol -cannot alter symbol or use a color other than black.