The most common mistakes on hemp CBD labels
Getting the label correct on a hemp CBD product is tricky, but here’s how to make sure you’re on the up and up.
![The most common mistakes on hemp CBD labels The most common mistakes on hemp CBD labels](https://eu-images.contentstack.com/v3/assets/blt09e5e63517a16184/bltafc06db067aebac6/64cbf83cdb0bcc7a8de33eaa/NewHopeNetwork_Horizontal_RGB.png?width=700&auto=webp&quality=80&disable=upscale)
1. The statement of identity placement is not quite right; it should be parallel to the base of the packaging. 2. The total container amount is not required to be on the primary display panel, but if you’re going to have it on there, it must be clear to what it is (either matching the per serving amount declared in the Supplement Facts panel on the back side, or, it must clarify if it’s per container/bottle). You don’t want your customer to have to do math when reading your labels so it’s best to spell it out for them right there. 3. The list of ingredients lists only full-spectrum hemp oil. Because most hemp oils use a carrier oil as part of the manufacturing process, it’s unclear what else is in the bottle. 4. The 800 number could be determined to be inadequate because the requirement is the name and place of the business. This product could come in a box with that additional information, which would suffice. However, customers will likely throw the box away, which is why it’s best to have the same information on bottle and box, as much as will fit.
1. A Supplement Facts panel is missing. 2. The information panel, where a Supplement Facts panel would go, is formatted incorrectly. The ingredients shouldn’t be boxed in. 3. The statement of identity is missing. 4. The instructions, while on the front panel, are not easy to read. And, people are expecting them to be in a different place because it’s uncommon to have instructions for use on the front of a package. 5. A company website is listed, but the contact information should go beyond that. If you’re going to include only a website, and not a business address, you should ensure the website is working and there is a place for consumers to contact you. 6. The text "Helps with sleep disorders" is a direct claim, which is not accepted for dietary supplements, per DSHEA guidelines. It needs to be reworded to have an acceptable structure-function claim, such as "Helps promote restful sleep."
1. The Nutrition Facts panel is not appropriate for a supplement. Because this product is a capsule, it’s misbranded. 2. If you call out a nutrient on the front panel you must be specific about what that is. For capsules, this should not be the total amount in the bottle—it needs to be the amount per capsule per serving. 3. The language "Hemp-derived cannabidiol" makes this product appear to be an insolate, not an extract from a plant (full spectrum extract with other cannabinoids). 4. The language "Pure CBD" is more indication that this is an isolate and therefore not allowed at Natural Products Expo.
1. The "Active Ingredients" label is almost right but it can’t be called that; it needs to be labeled as either a Nutrition Facts panel or a Supplement Facts panel. Because this product is capsules, the intended use is as a supplement, so this label needs a Supplement Facts panel. 2. The statement of identity is missing. It needs to state it's a supplement on the front panel. 3. The language “CBD (from Hemp Oil)” indicates it's an isolate and not an extract.
Here’s a brand that is checking all the boxes when it comes to its label. Kudos to RE Botanicals! There are a number of reasons why RE Botanicals won a NEXTY for Best New Hemp CBD Supplement, and this is one of them.
Here’s a brand that is checking all the boxes when it comes to its label. Kudos to RE Botanicals! There are a number of reasons why RE Botanicals won a NEXTY for Best New Hemp CBD Supplement, and this is one of them.
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 “ganjapreneurs” 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.
Further considerations
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.
Flip through the gallery to see real product labels that missed the mark (identifying information has been removed to protect the offenders).
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