CBD Product Requirements for food supplements
General labelling requirements:
The provisions of the Food Labelling Regulations 1996 (as amended) govern food labelling in the UK (apart from Northern Ireland, which has similar parallel legislation). These regulations lay down detailed requirements for the labelling of most foods to carry:
Any medical claims
The term “food supplement” must appear on the label and can appear stand- alone as stated in the Food Labelling Regulations 1996 6(1), which requires the name prescribed by law to be used. However, Regulation 6(3) of this regulation allows a qualification of this with other words to make it more precise e.g. “Food Supplement –containing vitamins and minerals”. Manufacturers would be encouraged to use the more descriptive option
The name of the category of any vitamin or mineral or other substance with a nutritional or physiological effect which characterizes the product or an indication of the nature of that vitamin or mineral or other substance;
Recommended daily dose: the portion of the product recommended for daily consumption; (For drops this could be: Recommended use: Take 1 or 2 drops, twice daily. Do not exceed 20 drops per day/in a 24hr period. For capsules: Take X capsules twice daily or as required. Do not take more than X capsules per day/in a 24hr period). Ensure that these amounts do not exceed 200mg of CBD until we have clarification from the MHRA.
Ensure that these amounts do not exceed 200mg of CBD until we have clarification from the MHRA.
Do not exceed 20 drops per day/in a 24hr period.
For capsules: Take X capsules twice daily or as required. Do not take more than X capsules per day/in a 24hr period).
This Food Supplement should be taken as part of a varied diet and healthy lifestyle
(Keep out of the reach of children)
Food supplements have their own labelling requirements, laid out in the Food Supplements (England) Regulations 2003 and equivalent regulations in Scotland, Wales and Northern Ireland.
http://www.legislation.gov.uk/... term “food supplement” must appear on the label and can appear stand- alone as stated in the Food Labelling Regulations 1996 6(1) , which requires the name prescribed by law to be used. However, Regulation 6(3) of this regulation allows a qualification of this with other words to make it more precise e.g. “Food Supplement –containing vitamins and minerals”. Manufacturers would be encouraged to use the more descriptive option. (Stating that the product is a food supplement and precisely that it is not intended to be used as medicine, whilst not a requirement by law, when MHRA are making a final determination, it may be beneficial for us to have this statement)
It is a requirement that Food Supplements are marked or labelled with the following particulars:
(Amount of CBD in mg prominent on the front of the label. For capsules, this should be CBD mg per capsule)
Food supplements are exempt from the requirements of the Nutrition Labelling Directive (90/496/EEC as amended). However, the Food Supplements (England) Regulations 2003 requires, in the case of vitamins and minerals, the information in point (f) above, to be accompanied by the percentage of the relevant Recommended Daily Allowance (RDA) as set out in the Annex to Commission Directive 2008/100/EC:
You must label pre-packed food products with nutritional information if:
you make a nutritional or health claim on the packaging (for example ‘high in fibre’ or ‘good source of calcium’) vitamins or minerals have been added to the food (This should only be relevant if your product contains additional listed vitamins or minerals)
Ensure that this does not indicate a medical/health claim
You must list the ingredients by weight from the most to the least that your product contains (based on the ingredient weights at the time of manufacture)
(state the amount of CBD present in the product in mg and to avoid confusion, state the cannabis content in mg within the ingredients list only
(Best before or Use by) We recommend a 12-month period.
E.g. store upright in a cool, dark place
You must include a business name and address on the packaging or food label of pre-packed food products. This must be either:
(E.g. Liquids: Place X drops under the tongue and hold for X amount of time or take drops sublingually; see below for pure extract)
if failure to give it might mislead. (The place of origin means. Manufactured in EU or you can say the individual EU country, i.e. Spain, or Manufactured in USA.)
External packaging should contain the same information as the label requirements.
Below the ingredients list it is best practice to state ‘Allergens are listed in Bold’ even if there are no allergens present.
If the raw materials are organic in origin there must be certification evidence provided to support this. In order to make an organic claim on a label, a food manufacturer must be registered with a recognized organic control body.
Summary information on the labelling of food supplements approved UK organic control bodies; please contact the Department for Environment, Food and Rural Affairs (DEFRA)
Similar to organic ingredients, certification of evidence needs to be provided.
Nutrition and Health Claims:
(Under no circumstances should you make any medical claims)
COA’s, THC and other Cannabinoids:
All hemp-based materials should have an independent 3rd party Certificate of Analysis (COA) for every batch stating the full cannabinoid profiles.
Mandatory purity tests per batch are required for any hemp products extracted using chemicals and/or solvents.
Periodic purity testing is required for hemp extracts using other extraction methods (CO2, Pressure, alcohol etc). These should show analysis for heavy metals, microbiological contaminants, mycotoxin screening and herbicide/pesticide residues (if not organic certified).
Minimum text size:
Labelling from outside the EU:
If you are importing products from outside the EU for resale, check that the labelling meets all of the labelling requirements for the UK/EU.
Many products from the USA are not compliant with UK/EU requirements. Dietary Supplement is non-compliant.
Some products may only need simple modification such as a sticker stating Food Supplement and a disclaimer.
Feedback from consumers has shown that many people are confused by the measurements of active compounds stated in CBD products. Labelling for food supplements cannot be misleading to the consumer. Some examples of misleading measurement information can include:
Finished products should clearly state the mg of CBD on the label. Examples:
The information within this document is for advice/guidance only. The CTAUK cannot guarantee accuracy in any part of this document and we will not be held responsible for any action taken against a company who have depended on any part of this document. Companies are wholly responsible for their own marketing materials and should read all the relevant UK/EU legislation to ensure conformity. If in doubt, please contact the relevant authorities.
If you notice any discrepancies, inaccurate and/or outdated information within this document, please contact the CTA Compliance Officer so that corrections can be made.