The CBD industry is one of the most popular trades to be in right now. The consumer landscape is pushing for more organic, more natural, and more transparent products. CBD products are typically well aligned with the trend of health and wellness from natural sources. Just as with any product, CBD has rigorous labeling requirements. Many new entrepreneurs in the CBD industry are running into trouble when it comes to labeling standards. Following the labeling requirements is a must to keep your products on the shelves. Before introducing your new CBD product or products to the public, learn how to properly label your CBD products correctly.
Proper labeling keeps a product compliant with the Food and Drug Administration (FDA)’s regulations and builds trust with consumers. A consumer who can read and easily identify what your product is and does will trust your product over mislabeled products or those that lack accurate or detailed information. The first step in proper CBD product labeling is understanding what type of product you are selling. There are different requirements for different product types. The two most common product types in the CBD oil industry are cosmetic products and supplement products. Below are the basic guidelines for each, although the requirements are constantly evolving with this new industry, so always double-check with the FDA for the most up-to-date requirements and regulations in CBD product labeling.
Cosmetic CBD Labeling Requirements
While there are no labeling requirements specific to CBD products yet, the requirements of all cosmetic products apply to this emerging industry. You cannot make any false or misleading claims about your product. This means you cannot claim your product will treat or prevent disease if it is not proven to do so. The FDA is watching the CBD industry closely for this issue and has sent out many warning letters to companies for violating this issue already. You also are required to display your label information in a legible manner, specifically in a font with a lowercase “o” no smaller than one sixteenth of an inch wide and no more than three times as tall as it is wide. The lettering must also contrast with the background to allow for easy reading. The last major requirement to follow is to not violate the Poison Prevention Packaging Act of 1970, which requires products to be kept in childproof packaging, meaning a child under the age of five, when given a reasonable amount of time, cannot open or has significant difficulty opening the package. What you need to know about this for your label is that if you do not keep your product in childproof packaging, you must put a warning on the label that you do not recommend the product for households with children in them.
CBD Supplement Product Labeling Requirements
Most CBD products are categorized as supplements. Even some food and drink products are supplements in labeling requirements. A basic way to decipher if your product is a supplement and must meet the labeling guidelines for a supplement is by the media of product. If it is a gel, oral spray, capsule, or oil drops, chances are it is a supplement.
Supplements must meet five main labeling requirement to be in compliance with FDA standards:
Statement of Identity
The labeling on your product must include, on the front side, a statement of identity for your product. This means you must state your product’s name or legal designation prominently on the label. This means the name for the product as determined by federal law. If federal law has not determined a name, use the common name of the item. If there is no commonly accepted name for the item, use the most descriptive and accurate term as possible.
Statement of the Net Quantity of Contents
The FDA requires all supplement labeling to state the amount of the actual product. This means the amount of the entire product, no matter the form, without the packaging. For example, 30 capsules or 15 milligrams. This information must be displayed in an easily readable manner in the bottom 30 percent of the product display panel on the outer container. You are also required to display the statement of the net quantity of contents on an informational panel located on the inner container labeling.
Nutrition Labeling
All supplemental products, including CBD supplements, must include a nutrition label that is in accordance with FDA requirements. You must include these main elements on your nutrition label:
- Serving size
- Servings per container
- Information on dietary ingredients
- Total calories
- Calories from fat
- Total fat
- Trans fat
- Amounts of vitamins and minerals
- Amount per serving column for each ingredient
- Percent of daily value of all dietary ingredients
There may be more requirements to include on nutrition labeling depending on the states in which you manufacture and sell, and what exact product you sell. Always check FDA guidelines before designing your product labeling and consult state laws.
Ingredient List
You must include a detailed ingredient list on every label for your product. Supplements require a full and complete list of ingredients to be considered compliant with FDA regulations. Include any and all ingredients in the product. These should be listed in a specific order. The first ingredient listed should be the one that makes up the largest percentage of the product. These should be listed in descending order until you reach ingredients that make up 2 percent or less of the entire product, which may be listed as a group.
Name and Place of Business of the Manufacturer, Packer, or Distributor
You need to include the name and address of your business on your product labels. Consumers need to be able to know where their purchases come from and have a means of identifying your company should there be an issue with the product. It is recommended to include a method of contact, such as a phone number or a QR code leading to your website to aid consumers in informing themselves, although it is not required by law.
If all regulations are met for the FDA, your state of production, and state(s) of sale, your product should stay compliant and safe for consumers. The CBD industry is still emerging, and the government is still deciding how best to protect consumers and businesses, so regulations in labeling are rapidly changing. To avoid losses in your business because of overprint labels that may quickly become outdated, invest in a digital label printer. Using this, you can print the specific number of labels you need and not have to over- or underorder labels when regulations change. You can simply print what you need and customize your labels as the industry develops—and your company alongside it.
