B7: Comply with Product Labelling Requirements

1. General Labelling Requirements

In the UK, all consumer products, including CBD, must adhere to general labelling rules set out in the Food Information Regulations. This ensures consumers are provided with accurate information about the product, especially its ingredients, use, and safety.

Key Information to Include on Your CBD Product Labels:

Product Name: Clearly display the name of the product (e.g., “CBD Oil,” “CBD Balm”).

Avoid making claims that suggest your product is a medicine unless you have the necessary licences from the Medicines and Healthcare products Regulatory Agency (MHRA).

List of Ingredients: All ingredients in the product must be listed in descending order by weight.

• If the product contains any potential allergens, they must be clearly indicated on the label (e.g., if your CBD product is edible and contains nuts, dairy, etc.).
• For oils and tinctures, indicate whether the carrier oil is hemp seed oil, MCT oil, olive oil, etc.

CBD Content: Clearly state the amount of CBD in the product, either in milligrams (mg) or as a percentage (%).

For example, “Contains 500mg of CBD” or “5% CBD” should be displayed on the front of the product, so customers know how much CBD they are consuming per serving.

Also, mention the amount per dose, e.g., “Contains 10mg of CBD per dropper.”

THC Content: The UK law mandates that no CBD product should contain more than 1mg of THC per product. Clearly state that your product is either THC-free or that the THC content is within legal limits.

Suggested Labelling Example: “This product contains less than 0.01% THC” or “THC-free.”

Batch Number: Include a batch number or code that corresponds to the batch’s third-party lab testing results. This helps trace the product back to its origin and production in case of a recall or issue with quality control.

Expiry Date or Use-by Date: Include the date by which the product should be consumed to ensure maximum effectiveness and safety.

For oils, edibles, and topicals, the shelf life is essential to give customers confidence that they’re buying a fresh and potent product.

2. Specific Labelling Requirements for CBD Products

CBD products fall into different categories (ingestibles, topicals, cosmetics, etc.), and each may have additional labelling requirements.

For Ingestible CBD Products (oils, capsules, gummies, etc.):

These products are regulated under the Food Information to Consumers Regulation and the Novel Foods Regulation, meaning strict labelling guidelines apply:

Serving Size and Dosage Information: Clearly indicate the recommended serving size and dosage for the product. This is especially important for CBD oils, where drops are commonly used as the dosage unit.

Example: “Suggested Use: Take 1–2 drops up to three times per day. Do not exceed 70mg of CBD per day.”

You can also include a daily recommended amount in line with UK Food Standards Agency (FSA) guidelines, such as “Do not exceed the FSA's recommended 70mg of CBD per day.”

Nutritional Information: If selling ingestible products, you’ll need to display nutritional information, including fat, carbohydrate, sugar, and calorie content (similar to food labelling).

This is particularly important for CBD edibles like gummies, chocolates, or beverages.

Warnings and Safety Instructions: Include necessary safety warnings, especially if the product is not suitable for certain groups.

Examples:

• “Not suitable for pregnant or breastfeeding women, or those wishing to conceive.”
• “Keep out of reach of children.”
• “Consult a healthcare professional before use if you are taking any medications or have any medical conditions.”

FSA Novel Foods Compliance Statement: If your product is an ingestible CBD product (e.g., oils, capsules, gummies), ensure it complies with Novel Foods Regulations.

You should include information about your product’s Novel Foods application status if applicable, such as “This product is awaiting Novel Foods authorisation.”

For Topical CBD Products (creams, balms, etc.):

Topicals are classified as cosmetic products and must comply with UK Cosmetic Regulations. You’ll need to provide slightly different information:

Function of the Product: Clearly describe what the product is intended for (e.g., “CBD Face Cream,” “CBD Muscle Balm”).

Directions for Use: Provide clear instructions on how the product should be applied, e.g., “Apply to the affected area twice daily.”

Precautions for Use: If the product is for external use only, make this explicit: “For external use only. Avoid contact with eyes.”

Any known adverse effects or allergens should be mentioned: “Discontinue use if irritation occurs.”

For Vaping Products (CBD vape oils, cartridges, etc.):

CBD vaping products are regulated as consumer products but must comply with specific safety standards.

Nicotine-Free Declaration (if applicable): If your vape product does not contain nicotine, state this clearly: “This product is nicotine-free.”

Vaping Guidelines: Provide clear instructions on how the product should be used, including the type of device it’s compatible with, and safety precautions regarding battery handling.

3. Comply with Advertising and Health Claims Restrictions

One of the most important aspects of labelling and marketing CBD products in the UK is avoiding any unverified health claims. The MHRA has strict guidelines about what can and cannot be said about CBD products. This is especially important when it comes to making medicinal claims about CBD's effects.

Avoid Unsubstantiated Claims: You cannot claim that your product can cure, treat, or prevent any diseases or medical conditions unless you have a medical licence from the MHRA.

Avoid phrases such as:

• “Reduces anxiety,”
• “Helps with chronic pain,”
• “Treats insomnia,”
• “Cures epilepsy.”

Permissible Claims:

You can make more general wellness claims such as:

• “Promotes a sense of well-being,”
• “Supports relaxation,”
• “Helps maintain balance in the body.”

Include Third-Party Lab Test Results:

To build consumer trust and comply with regulations, you should provide Certificates of Analysis (COAs) from third-party labs. These should be easily accessible, either on the label through a QR code or on your website, linked directly to the batch number.

4. Additional Packaging and Labelling Considerations

Childproof Packaging: If your product may pose a risk to children (e.g., edible gummies or high-concentration CBD oils), consider using child-resistant packaging to prevent accidental ingestion.

Eco-Friendly Packaging: Many consumers are attracted to sustainable brands. Consider using biodegradable or recyclable packaging to appeal to environmentally-conscious customers and align with the growing trend of sustainability in the CBD industry.

5. Regularly Update Labels for Compliance

The CBD industry is rapidly evolving, and regulations may change. It’s crucial to stay updated with the latest laws and regularly review your product labels to ensure they remain compliant with any new requirements.

Subscribe to updates from regulatory bodies like the Food Standards Agency (FSA), MHRA, and Trading Standards.

Conduct regular label compliance audits to check that your products meet the current legal standards.