CBD Product Labeling Requirements: Important Considerations
While research into CBD (cannabidiol) is still in its infancy, the benefits of this cannabinoid appear to be promising. In the future, it could prove to be a reliable, safe treatment for epilepsy, inflammation, anxiety and more. Unfortunately, the relative newness of cannabis products also makes regulatory compliance a minefield. United States federal and state regulations sometimes lack clarity, and they don’t cover everything customers need to know about the products they’re buying. This guide will walk you through the steps you need to take to produce compliant, easy-to-understand CBD product labels for your CBD product packaging.
What are CBD Products, Legally Speaking?
Under the Agricultural Improvement Act of 2018, also known as the 2018 Farm Bill, products derived from cannabis—such as CBD oil—are legal, so long as both the plants and the products contain less than 0.3% THC. While marijuana-derived products may be legal in some states, this federal law only applies to hemp products, including CBD, which are regulated by the FDA (Food and Drug Administration).
Section 201(g)(1) of Act [21 U.S.C. § 321(g)(1) defines drugs as anything that diagnoses, cures, treats, mitigates or prevents diseases and/or affects the structure or function of the body. So far, the FDA has approved four cannabis-derived drugs: Epidiolex, Cecomet, Marinol and Syndros. Any other product cannot make claims that would classify it as a drug. (The FDA has already sent out several warning letters to CBD companies regarding marketing that may contradict this law.)
Logically, if something like CBD isn’t classified as a drug, it should fall under the same rules as dietary supplements. However, the FDA does not allow CBD to be sold as a supplement, nor do they permit its use in food products or drinks. The industry as a whole is pushing for CBD to be reclassified as a supplement, mostly to make labeling regulations clear. Currently, CBD labeling requirements fall into a gray area that is closest to cosmetics.
Some states, such as California, have additional CBD labeling requirements. These requirements usually cover contact information for buyers who have questions about the product. Containers must also follow the Poison Prevention Packaging Act of 1970. This packaging can’t be easily opened by a young child.
Still confused? The FDA has a FAQ page on regulations for cannabis-derived products, including CBD.
What is the Required Information for a CBD Label?
Product labeling must follow the guidelines for cosmetic products, and the front of the container must have a principal display panel. This panel covers one side of a rectangular container, or at least 40% of a cylindrical container. CBD product labels should also include the following information:
- Brand name: The manufacturer’s brand name must be displayed
- Product identity: This is what the product is and what it’s supposed to do. If the product container is sold inside a box, the identity only needs to be on the box. However, it’s good practice to put this information on the container, as well.
- Net contents: This is the amount of product in the container. (Contents are measured by weight for solids and by volume for liquids.) A semi-solid, like a topical cream, is measured by weight if it’s too thick to be poured or pumped. This must be printed on the bottom 30% of the front label and the contents must be printed on the principal display panel on the outer container and the principal or information panel on the inner container.
The information display panel goes to the right of the principal display panel. If the side of the container is too small, this information can be printed on the back of the container. It should list the following:
- Ingredient declaration: This is a list of all the ingredients inside the product.
- Dosage: This is the amount of CBD per suggested dosage, i.e. 1 dropper / 5 MG CBD.
- Warning statement: This is not clearly defined like it is for a pharmaceutical label, so it’s up to the manufacturer to determine what goes here. For example, you may add a disclaimer that users may fail drug tests when using the product.
- Name and location of business: The manufacturer or distributor of product must be listed on the outer and inner container. It’s good practice to include a phone number, website or QR code to make it easy for customers to reach the company.
- Disclosure of material facts: This includes other important information the customer may need to know. To keep from violating drug laws, it’s a good idea to state that the product is not intended as a treatment, nor is it approved by the FDA. Other information for this section includes expiration dates, batch codes and other useful information.
Since they aren’t categorized as drugs, health claims cannot be made about CBD products. However, it is legal to suggest uses for products. For example, the product cannot “treat inflammation,” however it can be “for inflammation.”
What Makes a CBD Label Easier to Understand?
The current regulatory gray area leaves out information that consumers will be looking for when selecting a product. Fortunately, there is enough leeway to add this information so that customers can make more informed decisions.
There is some early research that suggests that CBD, terpenes and other cannabinoids may work together in a synergistic effect. However, trace amounts of THC can build up in the body over time, causing users to test positive for marijuana use. Consumers need to know the type of extract and purity to decide if the product is right for them.
- Full spectrum: Contains CBD and cannabis-derived terpenes, including THC.
- Broad spectrum: Similar to full spectrum, but THC is removed while leaving the other terpenes and cannabinoids intact.
- Isolate: The product only contains CBD. While it doesn’t have the synergistic effect, the chance of having a positive drug test is usually very low. At 99.9% purity, there is virtually no THC in the isolate. However, there can still be enough THC in 99.5% pure concentrations to trigger a false positive if the consumer uses the product frequently.
The FDA recently began cracking down on CBD manufacturers over dosages, because they’ve repeatedly found content information to be incorrect. To combat this, manufacturers are having third party labs verify the contents of their products. Printing this test information on the label gives buyers the peace of mind that they’re really getting the product they want.
How Do I Get These Labels Onto My Products?
Our Tabletop Vial Wrap Custom Labeling System is ideal for labeling batches of small bottles, such as those used for oils. It has a magazine that is hand-loaded, giving time for final inspection before labeling. From there, a star wheel moves containers through the machine and labels them automatically. A thermal printer can be used with this labeler to add lot numbers, expiration dates and other information.
If you need to label boxes, consider our Front/Back/Wrap labeler. It can apply separate labels on the back and front of your containers, or it can be configured for wrap labeling. In this mode, labels can be applied around corners, so you can use a single label reel to cover the sides of the container.
Need to add information to labels as they’re being applied? Our Dual Action Tamp (DAT) printer applicator easily prints and applies labels to two adjacent sides of boxes or cases, making it simple to add dates and lot numbers to packaging.
We Can Help You Get Your CBD Products Ready for Retail
If you’re ready to launch or revamp a product line, contact CTM Labeling Systems. Our local distributors are ready to work with you to set up a labeling system that helps you quickly and efficiently add labels to meet CBD labeling requirements for your products.
