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United States’s cannabis (CBD) product labeling requirements

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The US cannabis market is growing at an exponential rate and is expected to reach a total value of $40 billion by 2030. Cannabidiol (CBD) — a chemical in cannabis — dominates the cannabis market with a revenue share of 66.3% in 2021 because of its growing acceptance for treating epilepsy, pain, anxiety, and many other conditions. In fact, a recent survey revealed that 60% of US adult respondents have used a CBD product. Most of them use it to improve sleep quality, reduce stress, and relieve pain.

If you want a piece of this growing market by releasing your own CBD product, you need to ensure your product follows CBD labeling requirements. Otherwise, the Food and Drug Administration (FDA) may force you to recall your product. 

Here’s what you need to know to get your CBD product labeling right.

What information must be on the principal display panel of CBD product labels?

CBD products must have their principal display panel on the front of the container. This panel should fully cover one side of a rectangular packaging or at least 40% of a cylindrical packaging. 

Aside from the product’s brand name, CBD product labels must also include the following information:

Statement of identity

The label should declare what the product is and its intended purpose. For example, a CBD oil that promotes better sleep must have a label that shows: “CBD Oil, Natural Sleeping Aid.” The statement of identity should be more conspicuous than the brand name. 

If you package your product in a container then put that container in a box, then you only need to put the statement of identity on the box. But it’s good practice to include this information on the container, too. 

Net quantity of contents

This refers to the amount of product in the packaging. Solid products are measured by weight (in ounces and/or grams), while liquids are measured by volume (in fluid ounces and/or milliliters). Semi-solid products like topical cream are measured by weight if they’re too thick to be pumped or poured. 

If your product is packaged in a container with a box, the net quantity of contents must be on the principal display panel of the box and on either the principal or information panel of the container. This information must be shown on the front label’s bottom 30%. 

What information must be on the information display panel?

The information display panel must be on the right side of the principal display panel. If this is not possible due to the container’s size or shape, then the information display panel can be on the back of the container. It should contain the following details:

Name and location of business

You must list the name and address of the manufacturer, distributor, or packer of the product, and identify them by adding “manufactured by” or “distributed by.” All addresses must follow this format: street address, city name, state name, and zip code. It’s best practice to also include your phone number, website, or QR code so customers can easily reach you. 

For products that are packaged in a container and box, these details must be listed on both the container and the box.

Nutrition labeling

The information display panel must show all the nutrients that a product contains, such as total calories, saturated fats, cholesterol, sodium, total carbohydrates, dietary fibers, sugars, protein, vitamin A, and iron.

Ingredient declaration

This refers to the list of all the ingredients used in the product, including water. If your CBD product contains any allergens, declare them along with the ingredients or use a separate “Contains” statement after the ingredient list. By disclosing all the ingredients, you can help users spot potential allergens and decide whether the product is beneficial for their health. 

The ingredients must be listed in descending order of predominance by weight. This means the ingredient with the largest amount by weight must be first on the list, while the ingredient with the least amount by weight must be listed last. Ingredient declaration can come before or after the nutrition facts and the name and place of business. 

To avoid confusion, use common ingredient terms like “sugar” instead of “sucrose.” If your product uses flavoring, use the term “artificial flavor” or “natural flavor.” For colorings, use their certified name or common name. If there is no certified name, you can declare it as an “artificial color.” 

For products that come in a container with a box, the list of ingredients need only be on the box. 

Dosage

This refers to the amount of CBD per suggested dosage, such as 1 dropper/10 mg CBD.

Disclosure of material facts

This pertains to any information that consumers need to know when buying your product. For example, if your CBD gummy should be used only at night, then you need to indicate that on the product label. 

You should also disclose the type of CBD used: 

  • Full-spectrum – includes all parts of the cannabis plant and contains less than 0.3% tetrahydrocannabinol (THC)
  • Broad-spectrum – includes most of the cannabis plant and contains trace amounts of THC
  • Isolate – contains only CBD and no other cannabinoids like THC

You should also disclose manufacturing and expiration dates, which should be printed on the bottom of the label or stamped on the bottom of the container. This section can also include batch codes, which are a string of numbers and letters that are in your product batch’s Certificate of Analysis.

Warning statement

Since CBD products are not approved by the FDA, they must contain disclaimers like, “These statements have not been evaluated by the Food and Drug Administration. This product is not intended to diagnose, treat, cure, or prevent any disease.”

You must also include a warning statement if your product contains allergens or is unsuitable for pregnant or breastfeeding women.

Abiding by the strict and changing labeling requirements for CBD products can be challenging for any business. That’s why it’s best to regularly check the FDA’s website to stay updated on the latest CBD product labeling guidelines. 

If you need help with applying labels and sourcing containers for your CBD product/s, turn to Pro-Motion Industries. Contact us today at 856-809-0040

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