When developing practices for packaging and labeling cannabis products, several major decisions need to be made upfront. Business owners need to decide how to categorize the products they are selling and ensure that they adhere to FDA and State rules and regulations. It's especially important that products adhere to state law as sometimes state and federal regulations can contradict each other.
Regulatory cannabis labeling is an important part of designing a label for the final product.
Mandated labeling can take up too much space when not accounted for and the branding and identity of a product can be lost. It's critical for retailers that salespeople stay informed of where mandated labels need to go so that they do not obscure other important information about the product.
1. Product identity
The description of what your CBD product does or is. This does not include the brand or trademark. This information should be easy to read and locate It is not required but advised that you put label the product identity on the inside of the product's container as well.
2. Net quantity of contents
This is a statement about the amount of product that comes in a package as well as the amount of CBD per serving. Liquids should be measured in volume and solid products should be measured in weight. The net contents must be labeled anywhere on the bottom third of the PDP on the outside of the container as well as on an informational paned on the inside.
3. Name and place of business
The name and address of the manufacturer or distributor have to be labeled on the inside and outside of your product on informational panels. it is a good idea to also include a phone number or QR code that allows customers to learn more about your business.
4. Ingredient declaration
The outer packaging is required to have a full list of all the ingredients in your product on an informational panel. If there is no outer packaging then the ingredient list has to be placed on the product container itself. There is no mandate to put a list on the inside of the container if there is already one on the outside.
5. Warning or caution statements
It is recommended that you include standard warning labels for children, pregnant women, and potential complications for consumers on medication. It is also a good idea to provide a warning that consumers can fail a drug test by consuming hemp products. Another vital factor is to never place any medical or disease-related claims on the packaging, company website, or social media.
6. Disclosure of material facts
Material facts are any piece of information not previously listed that one would deem important or vital when purchasing CBD products. This includes things such as if your products are meant for nighttime use only, expiration dates, batch codes, manufacturing date, or if your product is full-spectrum, broad-spectrum, or isolate. Check with your state guidelines to ensure your labels are not missing any important facts.
While there is plenty of information required by all states, there is a myriad of different rules and guidelines that can be difficult to navigate without the proper research. The problem is compounded by the rapidly evolving cannabis industry and the conflicting nature of state and federal law. Seeking professional assistance with maneuvering this legal minefield could prove vital to the success of any business owners in the Cannabis sector. Otherwise keeping track of this ever-changing ecosystem may become impossible.