The hemp CBD market is way ahead of the science and regulations. It’s a bit like the Wild West out there, particularly for the plant’s celebrity cannabinoid, CBD. The heaps of challenges range from growing the crop to the point of purchase of a hemp CBD product.
Today’s businesses are often new to either the supplements industry or the food and beverage space, and likely don’t know the related rules and regulations. It makes sense, then, that the biggest labeling mishaps happen on new products from new companies coming to the market. And yes, we at New Hope Network see a lot of products cross our desks that wouldn’t make it past our standards team to make it to a Natural Products Expo show floor.
The rules aren’t simple, and the waters are still very muddy. However, New Hope Network is committed to setting industry standards. We’re basing these standards on the Food and Drug Administration’s stance, despite the agency not yet using much enforcement discretion on product labeling for these products. The standards team’s highest priorities are safety, transparency, truthfulness, reliability and responsibility.
Following the guidelines the FDA has put forth, here are the five pieces of information that absolutely must appear on a hemp CBD product label:
- Statement of identity: Must be on the front of the panel. In the case of dietary supplements, it must include “Dietary Supplement;” however, “Dietary” could also be an ingredient (i.e. hemp). The statement of identity must be on the principal display panel of the dietary supplement (it needs to be seen shelf-facing).
- Net weight: In U.S. and metric measurements on the front panel (at bottom) of label.
- Facts panel: If botanicals are identified, the plant parts used must also be included.
- List of ingredients: If more than one ingredient, in order of weight, or if any excipients were used (in the “Other Ingredients” section).
- Name and place of the business: Customers must be able to contact the manufacturer, distributor or co-packer.
It’s optional to include the CBD milligrams on the front panel of the label. If you choose to, and it’s not the same as what’s identified in the Supplements Facts panel, this must be clarified (for example, per container, per bottle, per “x” ml, etc.).
A solid label will also include a couple of pieces of information, in addition to those listed above. As a best practice, New Hope standards recommends including a couple of warnings regarding use by children, pregnant women and people taking medications.
Also, it’s best to include a warning that consumers could fail a drug test if consuming hemp products. This is especially true for full-spectrum products that contain small amounts of THC.
Finally, to pass New Hope Network Standards Department’s review criteria and be eligible to exhibit at Natural Products Expo, the product cannot be a CBD isolate.
Flip through the gallery to see real product labels that missed the mark (identifying information has been removed to protect the offenders).