10 Tips for Reading CBD Product Labels like a Pro in 2021
Disclosure of Significant Facts
Other Important Pieces of Information for Brand Owners
Federal Cosmetic Label Guidelines
CBD vs. THC
Many people, especially those new to the industry, still struggle to establish a clear and definite difference between CBD and THC., so let's start by explaining the fundamental differences and some similarities.
CBD is a non-psychoactive chemical compound found in the cannabis plant. It provides a calming and soothing effect. On the other hand, THC is a psychoactive chemical compound that stimulates appetite, causes a bit of drowsiness, and may also induce a euphoric feeling depending on the strand of cannabis the user intakes.
CBD stands for Cannabidiol, and THC stands for Tetrahydrocannabinol. Both CBD and THC are cannabinoids. The Cannabis plant has over 100 different types of chemical compounds known as cannabinoids. So CBD and THC are just two of the many cannabinoids found in the plant.
THC, however, can be contained within CBD products but at minimal percentages. Usually not more than 0.2%.It is a minuscule amount, and it is not enough to cause any of the effects that the regular THC concentration in high THC products can produce.
Both CBD and THC affect the endocannabinoid system that all human beings have within, primarily in the central nervous system. CBD, however, does not bind effectively to our endocannabinoid system as THC does. Our endocannabinoid system regulates sleep, appetite, and our immune system.
The endocannabinoid system has two primary receptors, which process the compounds we intake. These primary receptors are CB1 and CB2. CB1 receptors are mainly located in the brain. THC binds quite well with the CB1 receptors. On the other hand, CB2 receptors are found in our immune system. CBD binds quite well with the CB2 receptors.
CB1 receptors are responsible for the feeling of intoxication product of the intake of cannabis high in THC. By intoxication, we mean the mind-altering properties that can impact perception and the moderation of our reaction to pain.
Conversely, CB2 receptors bind to the organic and non-psychoactive CBD.
Cannabinoids vs. Terpenes
Terpenes are taken for granted. We all have experienced them through our whole lives. Terpenes are what give everything on earth its distinct smell or aroma. They are the chemical compounds that determine how things smell.
There are at least 20,000 terpenes in existence, and the hemp plant has quite a bit over 100 of them. Some of the terpenes produced by the hemp plant can also be found elsewhere in nature. But, there are a couple of these terpenes found in more significant amounts in the hemp plant. These are Myrcene, and Limonene. Myrcene is also found in mangoes and is the most abundant terpene in hemp flower. Limonene is also found in many citric fruits, such as lemons, oranges, grapefruit, and such, and is the second most abundant terpene in hemp.
Cannabinoids, on the other hand, are the chemical compounds responsible for the physiological effects they produce in those who consume them.
Most Common Types of CBD Products
CBD Gummies
Gummies are an edible form of consuming CBD. They are an easy, flavorful and discreet way to consume CBD (and THC too). Users report soothing feelings when consuming CBD gummies. CBD gummies come in different variations:
- Full-spectrum CBD contains all the hemp plant's phytochemicals, such as other cannabinoids, terpenes, and oils. It can also contain trace amounts of THC.
- Broad-spectrum CBD, same as Full-spectrum, except for THC.
- CBD isolate, which is just pure CBD.
CBD Oils
As well as gummies and most CBD products, they come in these three variations: Full-spectrum, Broad-spectrum, and Isolate.
CBD oils can be either ingested or applied to the skin. The ingestible CBD oils can be consumed sublingually or directly swallowed on their own. Alternatively, some people to regular foods, like salads, toast, cereals, etc. CBD tinctures (a common name for the sublingual CBD oils) are applied under the tongue in drops. Due to the high blood vessel concentration under the tongue, CBD tinctures are absorbed much faster than by ingesting them directly.
People who apply the CBD oils sublingually typically use some drops under the tongue and leave them there for a minute or two before swallowing it. This way, CBD reaches the bloodstream much faster, and the reported soothing effects may last several hours.
CBD Topical Products
These are CBD products that are applied directly onto the skin. There are moisturizing lotions, shampoos, conditioners, sunscreen lotions, hand creams, skin creams, soaps, patches, lip balms, etc.
CBD Vaping Oils
CBD Vaping Oil is not precisely like the regular CBD oil we explained above. These are specifically designed to be consumed with a vaporizer. Vaping CBD oils is a fast way to feel the effects of CBD. However, such effects tend to last less than with sublingual tinctures.
CBD Label Requirements
The CBD market is expected to reach a mind-wobbling $20 billion in the US alone by 2024. It is terrific news for farmers as the Farm Bill approved in 2018 allows hemp farming in all of the United States of America.
The subject of labeling is of utmost importance, and it is still an area that is not yet 100% clear. Still, in this article, we will try our best to decipher the current legislation regarding this fast-growing industry.
This article will only highlight certain aspects of the US's current legislation and is not meant to replace a careful and thorough reading of the FDA guidelines. We think this may be a great starting point to get familiarized with general regulations, understand how requirements may be different depending on which state the CBD product is sold, and access state, federal, and industry resources to gain a deeper understanding of this complex matter.
Federal lawmakers are still deciding on the guidelines for labels at the time of writing this article. How to communicate new labeling guidelines to business owners is still a work in progress too.
The bottom line is that brands must follow FDA regulations for the type of product they intend to sell and then check their state's specific label guidelines for CBD.
At this time, no CBD products will have FDA approval. However, this doesn't mean that brands cannot sell CBD products. But instead, they must include a CBD FDA Disclaimer on the label. Brands will also need to check the type of product you are selling, whether it is food, cosmetics, or dietary supplement. All labels will need to follow the FDA's guidelines based on the product type.
There is more certainty at the state level than at the federal level. It means that states have jumped ahead of the federal government in providing their guidelines for regulating CBD products and their labels. Make sure you read your state's guidelines, as these vary from state to state.
Ensure the guidelines you are reading about belong to the state where you buy your CBD products, not where they are manufactured. For example, the manufacturing plant is located in Illinois, but the brand sells CBD sunscreen lotion in California. It would be best if you familiarized yourself with California's state guidelines regarding labeling the CBD product.
Let's have a look at the different requirements of what a CBD label should show. It is not a be-all, end-all guide to understanding the labeling of CBD products.
FDA Disclaimer
CBD products are not FDA approved, so an appropriate and clear disclaimer is required on the label. You could have something like: "The Food and Drug Administration has not evaluated these statements. This product is not intended to diagnose, prevent, treat or cure any ailments or any disease."
As a CBD product brand owner or manufacturer, and in addition to the disclaimer, brands could also include the standard warning for pregnant women and children:
Another suggestion is to have a notice that users could fail a drug test if consuming hemp products.
Product Identity
It doesn't relate to the brand name but instead is a statement about what the CBD product is or does, for instance, "Sleep Aid," or "Relaxation," or both, and more if it's the case. It must be shown in the Product Display Panel so customers can find it easily.
Net Quantity of Contents
In the bottom of the Product Display Panel, brands must indicate the CBD amount per serving and the amount of the actual product.
Business Name and Place
Brands must include the name of your business, address, and contact information (such as a phone number, email, QR code) on both the outer and inner packaging of your CBD product. If you don't see it on your product, you might be in for low-quality CBD.
Batch code
All CBD products must have a batch code. Using the batch code, customers can locate independent lab reports. The batch code is printed along with the product's expiration date. If it is a bottled product, simply check the bottom of the bottle. If the product is boxed, the batch code will be located near the ingredients and barcode.
Ingredients List
Brands must declare all the ingredients contained in their CBD product. It doesn't matter whether the product is food, cosmetic, or dietary supplement. A full declaration must be clearly stated on the label, in descending order, depending on the amount or percentage of your product's components.
Besides that, many CBD products require a Nutrition Facts label or Supplemental Facts label. The goal is to provide the customer with extra information about your product. The information brands offer depends on the product type.
The following CBD products will require a Supplement Facts panel, including essential data such as serving size:
- Food and drink products such as CBD-infused drinks or brownies
- Dietary supplements, such as edible oils and gummies
- Cosmetics, such as skin oils and creams (these, of course, will not require nutritional information but must adhere to FDA regulations).
Disclosure of Significant Facts
In general terms, brands must include any information that an average customer would consider necessary when buying CBD products. The data will, of course, vary from product to product, but it's a great idea to guide customers in better understanding the products.
The information you could include is, but not limited to:
- Expiration date
- Manufacturing date
- Whether the product is isolate, broad-spectrum or full-spectrum
- State-specific icon
- Intended or suggested use, or application instructions for the product
- Batch codes
Other Important Pieces of Information
Brand owners must not include any misleading information, therapeutic claims, or unproven medical claims of treating, preventing, or curing any ailment or disease. These claims are not evaluated or verified by the FDA, and publicizing these kinds of claims can mislead customers. The FDA has sent many warning letters to CBD product brands that have made such claims.
Including an FDA disclaimer is just one part of the process. You must make sure and double-check if the packaging displays any of these claims when purchasing your CBD products. Reputable brands would never use such claims.
Some examples of these medical or therapeutic claims could be: "Our edibles relieve insomnia." Insomnia is a medical condition, so brands must refrain from adding this or similar claims that use a medical condition's actual name. To circumvent this legally, brands can use descriptive language that informs customers of the benefits without misleading claims.
You must also pay attention to the label placement. The information panel should be large and prominent enough for customers to see in plain sight. The ingredient fonts (or letters) must be at least 1/16th inch in height and have enough contrast against the background to help customers read the label without any problem.
Federal Cosmetic Label Guidelines
According to the Food and Drug Administration, cosmetics are applied to the human body to beautify, cleanse, and enhance skin, facial, and hair appearance. Cosmetics that contain CBD may include creams, body lotions, sunscreen lotions, skin oils, shampoos, foundations, makeup removers, lip balms, hand moisturizers, among others. Cosmetic products that do not contain any cannabinoids must also follow guidelines, so it is not just CBD products that must abide by such policies and regulations. According to the FDA, all cosmetic products must adhere to their rules, known as Good Manufacturing Practices (GMP). Let's have a look at what these GMP requirements for labels are.
The front panel of the product's packaging must contain:
- The name of the product, and
- Net quantity of contents
The panel immediate to the right must have:
- Ingredient list
- Any direction for safe use of the product
- Name of the manufacturer, packer, or distributor
- FDA Warning (if applicable)
Federal Regulations Regarding Label Design
It is not enough to include all the information above. Still, brands and manufacturers of cosmetics, including CBD ones, must make sure that the regulatory text is visible and legible. If the brand owner includes additional text for marketing purposes, it must also be compliant with regulations. It means that the label must not contain benefits that may be interpreted as medical claims. The CBD product brand owner must work together with their design and marketing teams to ensure the packaging and labels follow all the guidelines and adhere to current labeling regulations. Brands must produce labels and packaging with the right words, fonts, color scheme, and layout, so everything is specified as clearly as possible for any customer to read easily.
- The label must display all details prominently on the product packaging.
- Letters must be at least 1/16th inch in height.
- There must be enough contrast between the text and the background for proper legibility.
- No design elements must interfere with FDA-required statements.
- Labels cannot contain any therapeutic and medical claims.
State Regulations
We mentioned before that CBD product brand owners should look into state guidelines. The state in which a brand intends to distribute and sell CBD products has clear guidelines. In most cases, they go into more detail than federal guidelines, so it is imperative not to overlook this step by relying on the FDA's guidelines alone.
All states have hemp laws in place. However, not all states have thorough guidelines that establish CBD labeling requirements. Like Florida (fdacs.gov), some states will require all hemp products to display an approved hemp logo.
We know how important good design is, especially when complying with government departments' strict and severe regulations. Let's look at some design tips for eye-catching yet compliant labels.
How Brands Create Compliant and Beautiful CBD Product Labels
Uniqueness and Boldness.
Brands can express creativity when it comes to creating labels for their CBD products. Many companies use basic generic templates. The star ingredient of the product is CBD. So brands shouldn't hide it. Display it confidently in front of your product's packaging together with some key components, so when your customer walks the shop's aisles, they can clearly see it from a fair distance. At the same time, the information panel should be placed in a visible area, and within it, you must include all the remaining ingredients and the rest of the compliant text and information.
Many companies see the ingredient list more as an FDA requirement instead of an opportunity to display their products' selling points looking straight at the customer.
Companies like Nu-X stand out from the crowd by designing labels with their key ingredients on the very front of their packaging:
Displaying Key Benefits
No matter how unique the CBD product is and how much value it can add to a customer's life, remember that brands cannot display any medical and therapeutic claims. However, brands can highlight the products' key benefits by using medical terms that are not banned.
Let's say, for instance, that you are buying CBD gummies. Instead of saying that the CBD gummies are highly potent and are infused with melatonin that relieves insomnia (remember that insomnia is a medical term), brands could display this on the label: "CBD gummies with soothing melatonin." As a result, the brand tells you that you could get a great night's sleep without actually and illegally claiming that the product will treat insomnia.
Highlighting Product's Key Differentiators
If the product has value propositions, such as packaging made from recycled materials, GMO-free ingredients, etc., reputable brands will display them prominently. Here are some value propositions brands can display on the packaging, provided they are authentic, of course.
- Made in the USA (or any country if applicable)
- 100% Natural
- Vegan or vegan-friendly
- Responsibly sourced
- Made from recycled materials
- Sugar-free
- Lactose-free
Textures, Fonts, and Colors
Colors are associated with certain moods. Luckily for CBD products, research has shown that, for instance, green is associated with feelings of calmness. Blue is associated with peace and health, yellow with cheerfulness, and so on.