Do’s and Don’t of Labeling CBD and Cannabinoids
The art and science of labeling CBD products can be confusing. The confusion is because there is a lack of specific and defined regulations surrounding the non-intoxicating cannabinoid products; however, there is not a shortage of companies being shut down or fined for either misrepresentation, mislabeling, or just making claims that FDA (and banks!) frown upon. Let’s start with the basic what should be included:
Include these Essentials:
- Brand Name – this is the company name or D.B.A marketing name brand.
- Ingredients – weather topical or oral, include full decleration ingredients of the products
- Nutriotial Facts – If the product is oral, include information such as calories, fat, and serving size
- Warning / Caution Statement –
- Include an FDA disclosure that these cannabinoids due to treat or prevent any diseases
- Optional: Include a warming that you may fail a drug test (for full spectrum products)
- Optional: Include a warming that children, pregnant women, or people taking presceription drugs should consult a physician
- Business Contact – Name of business and way to contact that business that distributes the product
- Type of Cannabinoid – If product is full spectrum (under 0.3% THC) or broad spectrum (ND level of THC)
- Qauntity and content — how much CBD or other major cannabinoids, weight and count.
- Type of Product – idenfity the type of product, for exmaple gummies, oral tincture, heating-cooling salve
- Batch or Lot Numbers – and a way to see the COA for the batch or lot.
- Experation Dates
- UPC (Optional) – UPC if you plan on selling in multiple retail locations. UPC can be generated via a central database such as GS1 or ask your white label partner.
No Medical or Health Claims
Let’s start with the obvious – the FDA hasn’t approved CBD to treat any disease or medical condition; therefore, making direct claims that they do treat diseases and conditions is not allowed. With that said, let’s take any of these words off your packaging:
Don’t Say:
- inflammation
- seizures
- anxiety
- healing
Don’t Make Structure Claims Like:
- Elimates Wrinkles
- Fights COVID
- Improves brain health
Don’t Make Claims to Treating, Reducing, or Curing Diseases
- Treats chronic pain
- Prevents alzheimer’s
- Ruduces Acne
- Shrinks cancer tubors
- Prevents Anxiety and Depression
Don’t Imply Claims
If a common person reading the label assumes that this product treats or rids a disease without you actually saying it, you are still liable for the statement such as calling a product “Anxiety-B-Gone” because one, you are trying to fake FDA regulations and two, because FDA could still fine and shut you down because of these implied claims.
What Could be added to a Label
A statement that talks about temporarily relieving something or helping with something instead of treating something.
- Supports uplifted disposition
- Eases stress
- Supports focus
- Targets irritability
- Improved the appearance of skin
- Helps tighen skin
- For dry skin