Month: February 2021

Are you facing certain difficulties regarding CBD product labeling and packaging? Well, of course! CBD is a rapidly growing worldwide market. If you're operating your business in California State and have newly stepped into the zone, our guide for labeling and packaging CBD products will aid you much. 

The below guidelines are sourced from a notification proposed by California Cannabis Agencies dated Jan 16, 2019. If you're operating a licensed cannabis business, you must comply with packaging and labeling regulations to deal with all CBD and CBD-infused products sold within California.

Packaging and Labeling Recommendations by California Cannabis Agencies:

What you must consider during labeling and packaging a CBD product beforehand presenting it to your customers are the regulations put forward by the California Department of Public Health (CPDH). The updated notification holds labeling and packaging recommendations for cannabis (flower rolls and pre-rolls) and cannabis (extract) manufactured goods.

To help individuals further with compliance, the notification holds Master Packaging and Labeling FAQs; just tap on the highlighted bar to review the relevant resources.

General Guidelines for Packaging:

CBD Packaging—Opaque Containers

All cannabis flowers, pre-rolls, and manufactured cannabis goods must be packed in compliance with the following requirements stated by the Medicinal and Adult-Use Cannabis Regulation and Safety Act (MAUCRSA).

There Must Be a Tamper-evident Seal:

A tamper-evident seal reveals whether the contents of the product are initially touched or not it's a plastic seal or sticker around the lid. In case the seal is not attached with the protective cover of the product a consumer has visible evidence of its tempering.

The Product Packaging Must Bear a Resealable Property:

An ideal product packaging design is one that holds a resealable feature (such as lids, adhesive closure, box top closures, etc.), recommended for products with multiple usages. This will ensure its safety from any sort of exterior contamination through light, moisture, oxygen, etc., further, it prevents the risk of child consumption. 

Consider Only Opaque Packaging for CBD-infused Edible Products: 

It is difficult to see the inside contents of the product from opaque packaging unlike transparent. Opaque bottles such as Amber colored are preferred for beverages (e.g. syrups or energy boosters) and oral medicines (e.g. bottles for tablets). Such a type of packaging is designated to aid child-resistance.

The Packaging Property Must Bear Child Resistance:

It means that the package is designed in such a way that it's difficult to open for children aged fewer than 5. Smoking dried hemp and Marijuana flower buds and relevant cannabis products can cause serious hazardous impacts on them thus it must bear a Child Resistant Packaging (CRP).

Child-Resistant Packaging

What's More to Know About CRP? 

The package must say about initial CRP if it is intended for single-use, whereas the initial CRP tag generally implies to flower and flower only pre-rolls, inhaled concentrates (vape and cartridges), and single-serving cannabis products. 

The product must hold a lifetime CRP statement if it facilitates multiple servings 'through a single product'. It means the packaging is child-resistant as long as the product constituents end up. This tag is supported with edibles, orally consumed concentrates (tinctures and capsules, etc.), and suppositories.

The packaging needs to get certified as 'Child Resistant' by relevant authorities (by the PPPA act)

The container's closures or caps must be sealed with a pry-off crown technique.

Further, the packaging needs a 4 mil thicker protective plastic covering, must be perfectly heat sealed with no tab, dimple, or flap that discourages easy opening.

For Every Packaging

It Should Have

Packaging recommendations can be satisfied in any of the layers if the product holds a multi-layered packaging procedure

Make sure the products and their constituents are safeguarded from external toxic elements

It Shouldn't Have

Product packaging must not show any resemblance or identical to marketed children products

The packaging outlook must differ from those of non-cannabis food products.

Guidelines for labeling Cannabis (flower and flower-only pre-rolls)

CBD Pre-roll Packaging

All cannabis flower and flower-only pre-rolls must be labeled properly and all the significant details regarding the product must fall under primary and informational panel categories.

Primary Panel: 

The first and foremost thing that communicates with your regular and potential buyers is your brand identity, which is displayed through the Primary Panel at the front of your packaging. This is the part of the label which includes 3 key features.

The 'principal display panel' must patently display product identity: 

It contains a short description of the product's common or usual name from which a person can easily distinguish the product type, for instance, flower or pre-rolls.

Net weight/ Net quantity of contents must forefront the packaging:

The Net content measurements have to be displayed in metric (say grams) and U.S customary units (say ounces), as per guided by regulations. 

The Universal Symbol of California must associate the PDP Panel:

The Universal symbol of California indicates the country of origin on the cannabis commodities. This has to be mentioned in black and range at least 0.5"*0.5" by size. Tap here to upload the symbol! 

Informational Panel: 

When consumers desire more information they ultimately review the informational panel. This part can be stated elsewhere on the product besides the PDP panel. It generally includes the following data.

It is mandatory to include UID number to this label:

Receive your UID number from the California Cannabis Track-and-Trace system. Once you hold it, this requirement becomes necessary to get included. Moreover, it is prohibited to create a placeholder UID number, instead of leaving a blank place is recommended unless you load your UID number.

Include license name and contact details or website:

The legal business name or the registered DBA of the concerned licensee must be mentioned, along with the phone number or contact details. These worthy details on the informational panel added to your inner packaging of CBD products, will let consumers easily communicate their concerns with the manufacturer or retailer.

Mention caution or warning statement if any:

Explicit if any statement provided by the Government that associates the product say for medical cannabis products highlight 'FOR MEDICAL USE ONLY'. Also, bold and capitalized fonts are recommended.

Depending upon the applicability, a Prop 65 warning must be stated clearly if aware that its chemical composition can cause any serious harm on exposure to certain individuals such as cancer, birth defects, or any reproductive harm. 

Manufacturing date must be disclosed on products exterior:

The date on which the finished product is manufactured significantly impacts its shelf presence. Also, the manufacturing date must be accompanied by month, day, and year.

Cannabinoid content of ingredients needs to be declared on the informational panel:

For all CBD products, there must be a full declaration of ingredients, whereas the cannabinoid contents (such as concentration or amount of THC and CBD) present in the container are generally expressed in percentage (%.

For every label

It shouldn't have:

Do not mention the country name of California unless all cannabis sources relate to inland cultivation.

Any biased or misleading information imprinted regarding the product and its content is prohibited, For instance, labeling a product 'organic' whilst it is uncertified.

The exterior labeling design must not include any cartoon or comic characters, kid's images, or words that interest minors.

Any health claims mustn't be included if it doesn't support the publicly available criteria of peer-reviewed evidence.

It should have:

Use English as a medium with a font that is easily readable; at least 6 points sized font and is recommended.

During labeling, individuals must concern the layout of information in a clear and legit way.

All the essential labeling information must be visible and securely affixed at the exterior layer of the packaging.

It is allowed to add an authentic piece of information other than recommended ones unless it is not misleading. 

Guidelines for labeling Cannabis manufactured products

CBD-infused products range

Any authorized individual must verify these important recommendations included in their CBD-infused edible, cosmetic, and ailments curing product labels.

Like earlier, these basic labeling requirements are placed on the outer layer of packaging, which fall under two below-listed categories, based on the part of the packaging where it belongs.

Primary display Panel:

All the information regarding product identity (for instance, edible gummies), Net weight g or oz. or fl oz. and ml by volume, and Universal symbol have to be displayed typically at the front and top of the outer layer of packaging.

Informational display panel:

For the rest of the details apart from PDP, such as Registered Name and place of business, contact details or a QR code, Ingredient declaration, warning or caution statements, Disclosure of material facts such as health claims or any other desired information are listed on the Information display panel,.

Some additional labeling details regarding manufactured cannabis products:

There might be two key concerns regarding it. 

If your product holds multiple packaging layers, 

The basic PDP requirement apart from mentioning it to the other layers is mandatory to be infused on the inner container which is in direct physical contact with the product. 

Any inhaled Cannabis product layout (such as cartridges, vape, shatter, or wax) must exhibit the Universal symbol, whereas for Non- inhaled Cannabis products ( such as edibles, tinctures, topical, etc.) the word Cannabis-infused must be included along with the product identity, a universal symbol, and net weight or volume details.

If your product packaging holds too little space to get listed all the required information on the outer layer.

Suppose your tincture bottle is too small to fit in all the required details, to fix this it is recommended for the leftover information to be presented using a leaflet, hangtag, peel-back labels, and inserts. It is important to note that QR codes, websites, and other methods are not part of supplemental labeling; they just serve as a source of contact to deal with product complaints and inquiries.

For every label

It should have

Make sure you display all the information in a readable format with clear and legit wordings using English as a medium language along with a 6 point font size or more.

Confirm all suggested labeling requirements are displayed on the outer layer of Packaging, whereas an insufficient package space could be supplemented by hangtags and inserts etc.

It shouldn't have

You cannot state California as the products place of origin unless all of its constituents are sourced by the country

Any inappropriate and unauthorized statement regarding products such as false health claims is considered as an act of violation of the labeling requirements, which could even lead you to federal prosecution

You must confirm that each of your edible cannabis products does not hold any sort of picture; rather it comes in an opaque covering. This initiative is an attempt by the state to reduce the risk of children's attraction towards the product.
There goes a label restriction that you cannot market your product as an alcoholic beverage, as notified by the Bureau of Cannabis Control regulations.

Note: Our blog is listed in the Top 100 Packaging Blogs on Feedspot, which helps to keep up with multiple websites in one place.

What's your experience in the CBD market running in Florida? Well, after a bumpy start some will be at ease and some at not. We understand your ignorance of Florida’s Packaging and hemp labeling essentials. Fret not! This Ultimate Guide about CBD Packaging and Labeling Requirement will aid you much throughout your CBD journey.

Thanks to the Florida Division of Agriculture and Consumer Service's new hemp-programs. It has welcomed consumer wellness through addressing safety limits, testing requirements, and labeling issues. Earlier before these, you might not realize your product’s legal existence. But now make no mistake! Review our guide on FDACS recommendations for labeling CBD hemp-infused products both for pets and peoples.

How Florida describes Hemp and Hemp Extract?

Hemp is among the Cannabis Sativa plants with a THC concentration of less than 0.3%. It can be any part of the plant along with seeds. Hemp is unlike its cousin plant Marijuana which has comparatively more THC ratios, creating a ‘high’ feeling upon ingestion. Hence, the cannabinoids from hemp plants is generally a safer option, what we refer them as ‘Hemp-extracts’

Here is How Florida State Defines it:

“Hemp extract means a substance or a compound intended for ingestion or inhalation which that is derived from hemp and which that does not contain other controlled substances”

Florida stands by those states which care for its consumer wellness. Thus allowing licensed CBD marketers for the only hemp made products. If you want to deal in hemp products for human ingestion, consult The Division of Food Safety. 

For Hemp inhalation (such as smokables), body topicals, and animal feed products the individuals have to discuss the relevant divisions directed by the FDACs official page.

Let’s get to an integral part of our discussion! 

We have fragmented our guide into two main sections. One will help you with the hemp products made for human consumption (supplements only). Others will highlight Florida’s animal feed hemp labeling requirements. There's good news for hemp smokable sellers too! Now it carries a legal status in Florida. But our guide doesn't cover this section as regulatory bodies are busy in the rulemaking process.

Hemp-Food Labeling Requirements For Human Ingestion

Florida’s hemp-extract guidelines are in effect from January 1st, 2020, till now. For the Floridians selling their CBD brands at stores this guide applies to you.

Hemp-extract Food Products Labeling Requirements: 

For a hemp extract, the product must hold a packaging that contains the following labels:

Quick Response Code or QR Code:

Technology is now a part of food labels as well through this scannable barcode or QR code. By scanning it customers can review the makers and the relevant product info. Furthermore, this QR code is linked to a ‘Certificate of Analysis’ (CoA). This certificate is the evidence of your product’s regulatory compliance, issued by an independent laboratory.

Here’s some further information for you! You can either directly QR code with the CoA or you can attach it to a website as well. Whereas the website might require a batch number to enter. This batch number can be easily obtained from the product number as it is also a labeling requirement itself.

The Batch Number: 

Assigning a batch number to a product is an essential step during the manufacturing process. This applies to the product label as well. All the product history with the relevant control and manufacturing issues can be easily traceable with the help of the batch number. By this, we mean that if an item is found faulty the whole batch will be rechecked thoroughly.

The Internet Address of a Website: 

The label must display the web address of the URL. This serves as a means to obtain batch information.

Expiration Date: 

The expiry date should be enclosed on the label by month and year. This can be determined by third party shelf life or by stability testing. It is the date until which the ingredients of the products are safe for consumption after which degradation starts to occur. Furthermore, the shelf life must be maintained to the stated expiry date by proper storing and handling measures.

The Number of Milligrams Per Serving: 

Each of your cannabis product labels must mention the number of milligrams per serving. The measurement should be available in volumetric units such as ounce. It is applicable to only products that specifically advertise a particular Cannabinoid most commonly a CBD. Whereas it does not apply to products labeling as ‘hemp’, hemp oil’, and ‘hemp extract’.

Note: Adding any false ‘health claim’ unapproved by State regulatory bodies can put you under serious sanctions.

Basic Prepackaged Food Labeling Requirements:

The prepackaged food either serving a purpose for selling to manufacturers or by manufacturers to consumers must comply with the following essentials:

Statement of Identity: 

Every hemp food, beverage, or supplement must bear the Statement of identity. By Statement of Identity we mean, the product should be labeled by its name along with basic descriptions such as the nature of food. It gives the user an understanding of what the product is about. This is the first thing that brings your product a brand image in the eyes of a consumer.

To add above, it must be in bold and clear fonts with an appropriate description. The placement should be at front of the label. For example, a pack of hemp made crackers must show below the core ingredient or flavor such as chocolate. If cocoa isn’t the core ingredient rather just flavoring then it is considered a misbranded product.

Product Weight and Measurements: 

Product weight or net quantity is the sum of individual ingredients the package holds. The Net content measurements have to be displayed in metric (say grams) and U.S customary units (say ounces), as per guided by regulations. Furthermore, this description must forefront the packaging. 

Why this is essential is so because through this customers can easily compare the relative values of similar products. This helps them much in decision making while buying. 

Contact details of Manufacturers or packer or distributor: 

Here’s a common issue addressed while product labeling. Every product must show the registered business name of the maker or seller along with other details. These are the official address and a valid phone number. Sometimes it is added by a URL featuring the product label. All of these descriptions are worthy for your customers. This information supports a way to communicate their concerns and exchange feedback regarding your brand.

List of core and sub-ingredients: 

The product label must list down all the ingredients. The Order of the ingredient must be from most to least prominent. To add this, the core ingredients which top the constituent products by concentration or weight should stand first. Later the sub-ingredients follow the same pattern ranging down the list. Some individuals might have concerns about additives or flavorings. Hence, the purpose of this is to provide consumers an informational background of the components involved. 

An allergen or Prescribed Warnings: 

Customers must be informed of any allergens or prescribed warnings. These must be stated clearly if aware that the product constituents can cause any serious harm on exposure to certain individuals such as cancer, birth defects, or any reproductive harm.        

Nutrition Facts Panel or Supplement Facts Panel: 

A nutritional Fact labeling to your products will ease your consumers in their buying decisions. It consists of serving size, calories, fats, carbohydrates, added sugars, and key vitamins. A supplement fact panel is nearly the same as a nutrition facts panel with a slight difference. It focuses more on serving size and key vitamins and less emphasis on others.

Note: Adding any false ‘health claim’ unapproved by State regulatory bodies can put you under serious sanctions.

Hemp-Food Labeling Requirements For Animal Consumption:

HEMP-FOOD LABELING REQUIREMENTS FOR ANIMAL CONSUMPTION:

You must consider how Florida describes ‘pet food’ pet treats and other categories (specialty pet food and specialty pet treats), before dealing with products. These are meant to serve as snacks, chews, cookies, and bones to cats, dogs, rabbits, and other specialty pets. Note that these are the supplements to support an animal diet, rather than a core source of nutrients.

Almost the same labeling requirement follows the hemp-based animal feeds besides some slight variations.

The Hemp-extract Animal Feed Labeling Requirement

Besides complying with basic requirements, makers and sellers have to consider the following additional ones as well: 

• The label should bear a scannable QR code that directly links the Certificate of Analysis. This report is generated by an independent testing laboratory. A hemp extract batch experiments on the basis of THC concentration ratio lower than 0.3% and presence of any contaminants. A positive report suggests approval of your CBD product ready to sell in the market.

• It is essential to mention the batch number to which your hemp product belongs. Further upon entering this batch number to the linked URL, one can easily view product details.

• You must not forget to add the web address to your product packaging. Note that batch number and web address are complementary to each other for an appropriate product labeling and to obtain batch information.

• The expiration date is another essential for legit hemp product labeling. It serves as a stance for your consumer safety. 

• To guide your customers for appropriate dose measurement, let your labels state the number of mg of each of your CBD product holds per serving.

• All of your hemp-extract animal feed needs a special statement to be noted on the packaging. Florida hemp laws recommend the THC concentration which must not exceed 0.3% on a dry weight basis. 

• To distinguish it from human ingestion, your pet food label must mention the purpose as “NOT FOR HUMAN CONSUMPTION”. 

Note: You cannot add any health claim unless not approved or guided by the Government food and health regulatory bodies.

Basic Animal Feed Labeling Requirements:

Cater the following basic prerequisites in your product labels: 

• Do mention the name and principal address to direct the company’s location.

• Display your brand name along with product name in any. This should be at the top front of your packaging. 

• There must be a statement of guaranteed Analysis on the label. This significant information lets the buyers know the product's potential to fulfill their pet’s nutritional requirements. It has to be illustrated by 3 nutrient types by Min% crude protein, Min% Crude Fat, and Min% crude Fiber. 

• Further, you have to jot down all the ingredients the product holds. Make sure you list them in descending order considering their weight of the formulation.

• You have to show the net weight of the ingredients or simply the quantity your hemp feed item holds. Placement for this specification is usually at the front, right to the bottom of the label.

What Else you ‘Must know’ While Food Labeling: 

Your hemp-derived CBD food and supplements require the application of labeling rules if you are producing them within the state of Florida or importing them for the purpose of sale within the state.

If the product has multiple packaging layers, the hemp general recommendations must apply to the core packaging which basically contains the ingredients. For outer packagings such as boxes or any external container hemp-food, labeling requirements will be followed.

Fonts and language must be used as recommended by State labeling regulations. All the information is to be presented in English with a legit font size of at least one-sixteenth inch in height.

Must mention the word ‘supplement’ for all the products produced for human ingestion.

Your products must be preserved from any sort of contamination. To prevent and minimize heat and light exposure, you must consider recommended room temperatures.

Upon violations of the above guidelines, you simply won’t be forgiven. Serious sanctions may apply from issuing fines to even suspending permits.

If you need any assistance regarding hemp labeling and Packaging recommendations, the FDACS business center is readily available for help. You may also visit www.fdacs.gov/Cannabis/Hemp-CBD-in-Florida for further details.