With the CBD boom on the rise, it’s likely that you are designing a new label for a different CBD product each week. Whether you’re marketing hemp-infused dog treats or CBD gummies, it’s imperative to make sure that your CBD label complies with the FDA’s legal requirements.
Surprisingly, the FDA has been pretty tight-lipped throughout the rise of CBD. However, one rule has been made quite clear — do not make any claims that your CBD product will cure, treat, or prevent any medical illness!
Other than that, there aren’t currently any CBD-specific federal guidelines, so you can look to the FDA’s General Label Requirements (link) for guidance during your design process. Lastly, if your state permits the sale of edible CBD products, be sure to also check your state’s regulations for labels and warning requirements.
Classify Your CBD Product
One of the first things you will need to do is correctly categorize your product as a cosmetic product, food product, or a supplement product and follow the FDA’s labeling guidelines for that type of product.
A helpful tip–soft gels, oral sprays, capsules, and ingested oils administered by a dropper generally fall under the supplement category, while food and drinks (consumed all at once) are considered food products. Lotions, creams, and oils rubbed on the skin are typically cosmetics.
If you’ve identified your product as a supplement—you will need a supplement facts panel on the back. Likewise, if your product is categorized as a food, you will need to include a nutrition facts panel.
FDA General Label Requirements
At a minimum, always follow the FDA general label guidelines. By following this basic roadmap for labeling consumer products, you will be on your way to success!
1. Statement of Identity
First, you need to identify exactly what your product is and does. Just a few examples include: hemp extract supplement, herbal supplement, botanical supplement, natural sleep aid. Most importantly, the intended purpose of the product should be abundantly clear and conspicuously placed on the Primary Display Panel (PDP), which is the front of the label.
Pro Tip: In order to clearly separate their CBD-infused products from isolated CBD drug products, many manufacturers and distributors avoid the term “CBD” altogether in their identity statement and opt to use labels like industrial hemp-infused or full spectrum cannabinoid instead. This can help your brand to curtail any confusion about the purpose of your goods and keep you out of the FDA spotlight.
2. Net Quantity of Contents
Your label must display an accurate quantity of the contents as well as the amount of active CBD or cannabinol per serving. This quantity should be shown in volume for liquids, net weight for solids, or numerical count for capsules. It may seem like a natural choice, but the text must be placed in the bottom 30% of the PDP and must be at least 1/16” in height.
To make sure that small text is clearly legible and crisp, we suggest designing your text no smaller than 1/8” in height, and we recommend 100% black in color.
Learn more: Guidelines for Small Text on Custom Labels
3. Declaration of Ingredients
Understandably so, consumers today are highly “health-conscious” and have a right to know exactly what they ingest, inhale, or apply to their skin. List all of the product’s ingredients in descending order of predominance by weight, and always use the common or proper name for an ingredient. If applicable, the ingredients panel must be displayed on the outer packaging. If there is no outer packaging, then the ingredients should appear on the container itself.
4. Business Information
Be sure to include the name and address of the manufacturer or distributor on both the outer and inner packaging. This information can be placed in any position–but it’s highly important that consumers know where to go for more information. This part of your design is your chance to claim responsibility and offer transparency with your audience! Including a phone number or a website can help your brand to build trust and legitimacy with your end-consumers.
5. Caution Statements
When consuming a hemp product, there is a possibility that one may fail a drug test. It is always best to include that warning as well as the standard warnings for pregnant women and children and users taking any medications.
6. Disclose Material Facts
Consider any information here that a consumer would find important to know. Categorize your product as full-spectrum, broad-spectrum, or an isolate. You should also share batch codes and expiration dates to let customers know when your product was manufactured.
7. Nutrition / Supplement Facts
If your CBD product is ingested, a nutritional or supplemental facts panel should appear by way of a prescribed FDA format. Since edible CBD products are only permitted in some states, be sure to check out your state’s regulations as well for any additional information you might need.
The FDA has been loud and clear about one CBD-specific regulation: Do not make any medical claims!
While CBD is widely believed to have medicinal benefits, there is no hard-and-fast scientific evidence to back this claim. If you promote better health or promise a cure for medical ailments, your product becomes an unlawful drug (no dice!). To avoid unwanted interference from the powers that be, make sure to steer clear of this trap.
Label Material Recommendations
All of our plastic or vinyl label materials are waterproof and oil-resistant. Of these materials, you can choose metallic, clear, holographic or standard white. Between these options, there are infinite possibilities for designing for lotions, oils, cosmetics, and refrigerated items.
If eco-friendly is more your niche, there are other water-resistant materials out there that may suit your needs. TerraSkin is a label material made from crushed rocks (80% calcium carbonate and 20% polyethylene resin to be exact). Because of its makeup, TerraSkin is uniquely durable and water-resistant.
If your label does not need to be water-proof or oil-resistant, unlaminated materials like Kraft or Estate Paper can give off an extra earthy vibe.
The label finish can also add a unique look to your overall packaging. Choose either a gloss finish for extra shine or a matte finish for a smooth, understated look.
Ask For a Helping Hand
Our friendly and experienced service team is simply a call away! If you would like expert recommendations on label materials, knowledgeable feedback on your artwork, or even a sample of your printed designs, our Experience Team can make it happen. Happy CBD-ing!