Food Supplement Guidelines for CBD Products
If you are selling CBD products as food supplements you are subject to the guidelines set out by the EFSA (European Food Safety Authority).
Avoid Medical Claims
You must avoid Medical Claims (unless you product specifically allows this – read more about our CBD product range that can include certain claims)
Directive 2000/13/EC generally prohibits the use of information that would mislead the purchaser or attribute medicinal properties to food.
The EFSA explains on their website that:
“Food supplements are intended to correct nutritional deficiencies, maintain an adequate intake of certain nutrients, or to support specific physiological functions. They are not medicinal products and as such cannot claim to exert a pharmacological, immunological or metabolic action. Therefore their use is not intended to treat or prevent diseases in humans or to modify physiological functions.”
Food supplements are regulated as food, and must therefore adhere to all other legislation that is applicable to foodstuffs. This has consequences for labelling and for the ingredients that are allowed.
Directive 2002/46/EC sets out specific labelling requirements for food supplements.
- the names of the categories of nutrients or substances that characterise the product or an indication of the nature of those nutrients or substances;
- the portion of the product recommended for daily consumption;
- a warning not to exceed the stated recommended daily dose;
- a statement to the effect that food supplements should not be used as a substitute for a varied diet;
- a statement to the effect that the products should be stored out of the reach of young children.
Your packaging is required by law to contain the words “Food Supplement” and can also contain more words to make it more precise eg “Food Supplement – containing vitamins and minerals”
Nutrients and other ingredients
A wide range of nutrients and other ingredients might be present in food supplements, including, but not limited to, vitamins, minerals, amino acids, essential fatty acids, fibre and various plants and herbal extracts.
The Term CBD or Cannabidiol can be included on the label. Other phyto-cannabinoids like CBDA or CBG can also be listed.
Cannabis can be referred to as Cannabis, Cannabis Sativa L. or Hemp.
We advise to clearly state the amount of Cannabidiol in mg and the botanical source i.e. cannabis/hemp.
Recommended Daily Dose
Include the recommended daily dose eg. take 1-3 drops twice a day or do not exceed 20 drops in 24 hours. Adjust the recommended daily dose according to the strength of your CBD product.
Since cbd is being marketed as a food supplement you can include individual servings in mg
Warning not to exceed recommended daily dose
Include a warning that tells consumers not to exceed the recommended daily dose.
For example – Do not exceed the stated recommended daily dose, or
Do not exceed 200mg of cbd per 24 hour period.
Include a statement about about a food supplements not be used instead of a healthy varied diet
Food supplements should not be used as a substitute for a varied diet, and a statement to this effect must be included on the label.
Child Safety Warning
Include a statement explaining that the products should be stored out of the reach of young children. eg. “Keep out of the reach of young children”
Avoid any product names that contain direct medical claims, or can otherwise be seen as misleading for the consumer.
List of Ingredients
A list of all ingredients contained in the product must be included on the label.
The amount of ingredients used
Include the amount in mg or ml or grams. Include the amount of mg of cannabidiol
Include best before date or use by – for most CBD products 12 months is adequate. However, alcohol based tincture can have a much longer shelf life.
Keep refrigerated or store in a cool dark place.
Name and address of manufacturer
Include the name and address of the manufacturer or producer. The address needs to be a physical address within the EU where your business can be contacted by mail. You can’t use an e-mail address or phone number.
Instructions for use
For CBD oil drops – Place drops sublingually under the tongue and hold for at least 60 seconds before swallowing.
Place of origin
Include the place of origin in your labeling and packaging.
- product of the EU, Manufactured in Holland
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.
The code number of the national certification authority should also be on the label next to the EU organic logo.
AB – ISO code as specified in Article 58(1)(a) for the country where the controls take place CDE – three letters term that establishes a link with the organic production method as specified in Article 58(1)(b) such as “öko”, “org”, “eko”, “bio”, etc.
999 – reference number, indicated in maximum three digits, to be attributed, as specified in Article 58(1)(c)