Trying to find specific CBD packaging requirements is difficult. CBD isn’t in the food or dietary supplement sections of the Federal Food, Drug, and Cosmetic Act (FDCA), so there are no concrete FDA requirements. Most labeling regulations are also suggestions from the FDA, as selling CBD hasn’t been wholly accepted on a Federal level. In 2018, the updated U.S. Farm Bill did legalize hemp-based products on a Federal level provided they contain less than .3 percent of the CBD cannabinoid chemical. Some states have legalized the selling of cannabis products for medical and recreational purposes, and have developed their own laws about packaging. With the increase in the cannabis industry as a player in the pharmaceuticals and other health and wellness industries, the FDA has taken note. The FDA will be holding a meeting in May 2019 to discuss legal ways to market products containing cannabis with growers, manufacturers, and cannabis industry leaders. The goal is to gather responses to help set further regulatory standards for packaging and labeling all current hemp and cannabis-based products, regardless of strain. The FDA also intends to continue to take actions against unsubstantiated claims on packaging.

How to Package CBD Supplement Products to Avoid Federal Warnings

For CBD oils, capsules, and tablets, follow all State regulations for CBD packaging and labeling. If you intend to sell out-of-state follow the acceptable State and section 21 CFR 111.455 of the FDA packaging regulations for food and dietary supplement products. The FDA doesn’t recognize CBD products under the FDCA, but they will notice if your packaging or labeling is unacceptable. Packaging for the food and dietary supplements of your State, any receiving States, and the FDA will help avoid receiving warnings on your products from the FDA. Many of the packaging laws are the same between States, some based on FDA regulations for like products.

Choosing Packaging for CBD

Child-resistant packaging is the best option for any ingestible hemp or cannabis-based CBD product, including herbal supplements containing CBD. In addition, packaging has to help ensure product quality under section 21 CFR 111.455(a) of Federal regulations for herbal supplements. The best packaging for cannabis products is airtight green, blue, amber, or violet glass jars and bottles, with child-resistant caps. Glass doesn’t absorb oils and colored versions help prevent product deterioration from UV-rays or artificial light. Other acceptable options for packaging CBD products include:

• Colored plastic jars and bottles
• Metal tins
• Locking bags
• Wooden boxes

Use child-resistant closure for products like push-turn dropper caps for CBD oils, or squeeze-turn caps for capsules to help prevent accidental ingestion. The type of packaging your product requires can vary by State, so check State packaging regulations often for changes.

Quality Control Procedures

Store in-process materials, ingredients, and finished product in an organized way to avoid mixing or contamination. Labels and packaging need to be stored under conditions that help prevent material deterioration, print fading, and strength breakdown. As per 21 CFR 111.455 (c) the manufacturer is responsible for tracking product manufacturing history and control of any labeled and packaged supplement throughout distribution.

Labeling CBD Product Packages

CBD supplement products need a Supplement Facts Label (SFL) on the back, along with secondary ingredients, warnings, storage instructions, and the manufacturer's address. The front must contain, at least, an identity statement and the quantity or volume of the container. Manufacturers will need to do quality control for label production and review all labels before and after placement, and before shipping. Check for any discrepancies in labels for each batch of product, and make changes as necessary. Machines can perform quality control for labels in most instances, if applicable to criteria listed under 21 CFR 111.455 (c). To learn more about specific labeling requirements for different CBD products click here.