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Labeling & Claims Compliance

Clear, compliant labeling is the foundation of trust in THC-free CBD. This guide explains what must appear on labels, how to describe “THC-free” accurately, and how to handle claims without crossing into disease or drug claims.

Because CBD regulation evolves and differs across jurisdictions, use this page as a practical checklist. For deeper legal context, see our Legality hub rather than duplicating it here.

What regulators focus on (high level)

Labeling and marketing are primarily evaluated for truthfulness, non-misleading presentation, and adequate substantiation. In the U.S., the FDA focuses on labeling and product classification, while the FTC enforces advertising truthfulness. For details, please see: Legality and FDA Policy on CBD. State and international rules can add requirements.

Essential label elements for THC-free CBD products

  • Statement of identity: clearly describe what the product is (e.g., “CBD hemp extract oil” or “hemp-derived broad-spectrum extract”). Avoid implying drug status.
  • Net quantity of contents: amount by weight/volume and total servings (e.g., 30 mL / 1 fl oz, 30 servings).
  • Ingredients: list in descending order; identify carrier oils, flavors, and potential allergens. For topicals, INCI names are recommended.
  • Facts panel appropriate to category: Supplement Facts (if marketed as a dietary supplement in jurisdictions that allow it), Nutrition Facts (foods), or cosmetic ingredient panel for topicals. Consult counsel because FDA federal policy currently restricts CBD in foods/dietary supplements (see FDA Policy on CBD).
  • Amount of CBD: per serving and per container; clarify if it refers to cannabidiol specifically (e.g., “CBD (cannabidiol) 25 mg per serving”).
  • Manufacturer/distributor name and place of business: include a domestic address or phone/website for consumer reports.
  • Batch/lot number and expiration/best-by date: ties product to testing and quality records.
  • Storage, use instructions, and applicable warnings: keep from children and pets; not for use during pregnancy or lactation; consult a professional if you have a medical condition or take medications.
  • QR code or link to a current COA: connect each batch to a third-party ISO/IEC 17025-accredited lab report covering cannabinoids, residual solvents (if applicable), pesticides, heavy metals, and microbes.

“THC-free” statements, LOQ, and COAs

“THC-free” must be backed by credible testing and precise wording:

  • Use non-detect (ND) language tied to a lab’s limit of quantitation (LOQ). Example: “ND THC at LOQ 0.01%.”
  • Avoid an absolute “0.0% THC” unless your method and LOQ truly support a zero reading; even then, consider “ND/Below LOQ” to reduce risk of misleading claims.
  • Match label claims to the exact batch COA and keep COAs accessible via QR and URL.
  • Choose formats with low THC risk (e.g., CBD isolate or broad-spectrum validated ND for THC).
  • Include a drug-testing caution: trace contamination in supply chains is possible, and testing methods vary.

Claims compliance: FDA/FTC basics

Both labels and ads (websites, social posts, emails, influencer content) must be truthful, not misleading, and substantiated. Avoid disease claims that imply diagnosis, cure, mitigation, treatment, or prevention of conditions.

Structure-function claims for CBD

Where permissible, structure-function style statements should be general and non-disease, for example: “supports a balanced mood,” “helps manage everyday stress,” or “supports recovery from exercise-induced soreness.” Ensure you have competent and reliable scientific evidence for any claim. If marketing as a dietary supplement where legal, include the standard DSHEA disclaimer and any required notifications; note federal FDA policy currently restricts CBD in supplements and foods (see FDA Policy on CBD).

What to avoid

  • Explicit or implicit disease terms (e.g., anxiety disorder, depression, arthritis, epilepsy, insomnia as a disease, PTSD, cancer).
  • Drug-like claims for topicals (e.g., “pain relief,” “anti-inflammatory”) unless the product legally qualifies under applicable drug frameworks. CBD is not an approved OTC active.
  • Testimonials that mention diseases; reposting them can create your own claims.
  • “Clinically proven” without robust, product-specific evidence.

Substantiation and presentation

  • Keep a claims matrix mapping each marketing statement to supporting evidence.
  • Use clear qualifiers (e.g., “may,” “helps support”) and avoid overpromising.
  • Disclaimers help provide context but do not cure unlawful disease claims.

Digital labeling: websites, emails, and social media

  • Your website, product pages, blog posts, QR-linked COAs, and landing pages are “labeling.” Keep them consistent with packaging.
  • Influencers and affiliates are extensions of your advertising; provide them with compliant talking points and monitor content.
  • Ensure pricing, potency, serving size, and “THC-free” phrasing match the physical label and COA.

Category-specific notes

  • Dietary supplements/foods: Federal FDA policy currently restricts CBD in these categories; some states allow it with conditions. Coordinate federal and state rules; see USA State Laws (Overview) and US State-by-State THC-Free CBD Laws.
  • Topicals/cosmetics: Cosmetic claims relate to appearance or cleansing, not physiological effects. Avoid analgesic/anti-inflammatory claims unless adhering to applicable drug requirements (CBD is not an approved OTC active).
  • Inhalable products: Additional age and shipping restrictions may apply in certain jurisdictions.
  • California Prop 65: Evaluate if a warning is required based on potential exposure to listed chemicals (THC is listed). “THC-free” supported by ND/LOQ may reduce risk but evaluate case-by-case.

International considerations (brief)

Rules vary widely across the EU and elsewhere. Avoid duplicating details here; see EU Laws (Overview) and EU Laws by Country.

Common pitfalls

  • Label says “THC-free” but COA shows detectable THC.
  • Using disease terms anywhere (label, blog, FAQs, testimonials, hashtags).
  • Inconsistent CBD amounts across front panel, facts panel, and website.
  • Missing firm address/contact, lot number, or COA access.
  • “0.0%” claims without method/LOQ context.

Quick compliance checklist

  • Accurate identity, net contents, ingredients, and appropriate facts panel.
  • CBD amount per serving and per container clearly stated.
  • Lot number, date, firm contact, storage/use directions, and applicable warnings.
  • QR/URL to batch COA from an ISO/IEC 17025-accredited lab covering cannabinoids and contaminants.
  • THC statement tied to LOQ (e.g., “ND THC at LOQ 0.01%”).
  • Only non-disease, substantiated claims; consistent messaging across label and digital.

Disclaimer

This page is informational and not legal, medical, or regulatory advice. CBD may interact with medications. THC-free products are tested to non-detectable limits, but testing variability and supply chain factors mean drug-test outcomes are not guaranteed. Consult qualified counsel and your regulator before launching products.

FAQ

Is “THC-free” the same as 0.0% THC?
Not necessarily. “THC-free” should mean non-detectable at a stated LOQ on a batch COA. “0.0%” can be misleading if the method cannot detect below a threshold.

Can I call CBD a dietary supplement?
FDA federal policy currently restricts CBD in dietary supplements. Some states allow it under conditions. Consult counsel and see FDA Policy on CBD and USA State Laws (Overview).

Do I need a QR code to the COA?
Many states require it and it’s a best practice. Make sure the QR links to the correct batch COA and that the COA is readable on mobile.

Can I repost customer testimonials about specific conditions?
Testimonials become your claims. Avoid reposting content that mentions diseases or drug-like effects.

What does LOQ mean?
Limit of Quantitation. It’s the lowest concentration the lab can reliably quantify. Pair your “THC-free” statement with the LOQ from your method.

Call to action

Explore third-party tested THC-free options supported by current COAs at Cannagea: shop THC-free products.

Summary

For cbd labeling compliance, align every label and ad with verifiable COAs, precise “THC-free” language tied to LOQ, and conservative, substantiated non-disease claims. Keep categories straight (supplement, food, cosmetic), maintain batch traceability, and ensure consistency across packaging and digital content. When in doubt, review our legality resources and consult qualified counsel before making or repeating any claim.

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