How many times have you wandered down a vitamin store or beauty store aisle and paused to stare at a beautiful label? How many times did you buy the product just because the colors, textures and words resonated with you?
The importance of a well-designed product cannot be understated because up to 70% of purchases are made at the shelf level, and a product’s label is what the customer sees first. But food, drugs and cosmetics labels aren’t just blank canvases for creativity; they must also display regulatory information required by the FDA.
So how can you create an appealing Hemp-CBD label while remaining compliant with state and federal labeling requirements?
In this post:
- Federal regulations
- Dietary supplement guidelines
- Cosmetic label guidelines
- How federal guidelines affect design
- State regulations
- Tips for compliant CBD labels
- Before you hit print
Federal Regulations for CBD
The consumer CBD industry is a bit like the wild west right now due to lack of written federal rules, but that’s about to change very soon. In 2018, the Farm Bill legalized industrial hemp, which opened up hemp-derived CBD products to state and federal regulations. As of today’s post, The Food & Drug Administration (FDA) is still researching CBD to determine safe daily usage and establish rules for product labeling.
While the FDA investigates CBD, the best you can do is reference the current federal rules for dietary supplements and cosmetics. Then, check to see if your state has an established hemp program with other labeling guidelines.
If you proactively design your CBD labels with today’s compliance in mind, you can help prevent costly product recalls that may require you to redesign and reprint thousands of labels down the line. The potential cost in damages and harm to your brand’s reputation is not worth the risk.
Federal Dietary Supplements Guidelines:
According to the FDA, dietary supplements are defined as products that can add onto your diet or contain one or more of the following ingredients: A vitamin, mineral, botanical or amino acid. Dietary CBD supplements may include ingestible oils, tinctures and gummies. Below is a quick recap of labeling requirements for all dietary supplements. For the full list click here.
What Does the Label Need to Say?
- Name of the supplement
- The net quantity of contents
- Nutrition information
- Ingredient list
- Name of manufacturer, packer or distributor
Where Does All This Info Go on the Labels?
- The product name and net quantity must be on the front display panel
- All other statements must be placed either on the front panel or directly to the right (the information panel)
Federal Cosmetics Label Guidelines:
According to the FDA, cosmetics are applied to the body for the purpose of cleansing, beautifying, promoting attractiveness or altering appearance. CBD Cosmetics may include skin oils, creams, body washes, and shampoos. Certain cosmetic ingredients are restricted by regulation, but that is not the case for CBD or other cannabis derived ingredients.
All cosmetic products are expected to adhere to FDA regulations known as Good Manufacturing Practices (GMP). Below is a snapshot of GMP requirements for labels.
What Information Do I Need to Have on the Front Panel?
- Name of the product
- The net quantity of contents
What Information Do I Need to Have on the Information Panel (Panel Immediately to the Right)?
- Ingredient list
- Name of manufacturer, packer or distributor
- FDA 740.10 warning (where applicable)
- Any direction for safe use of product.
How Federal Regulations Affect Design
Not only do you need to include the information above, you must also ensure that regulatory text is clearly visible. Additionally, the remaining content that you add to the label for marketing purposes must be compliant as well.
That means your label cannot include benefits that may be misconstrued as medical claims. Your design and marketing team must work together to carefully choose your label’s words, font, and layout.
- Panel Size. The label must be large enough so that all required details are prominently displayed.
- Font style & size. Letters must be at least one-sixteenth (1/16) inch in height.
- Label background. The background must be sufficiently contrasted with text for easy reading.
- Label design. FDA required statements cannot be obscured by any design elements
- Label content. Label content cannot make any therapeutic claim that indicates your product works at the physiological level.
State Regulations for CBD Labels
In addition to federal supplements and cosmetics requirements, you may also need to look at your state’s laws for final labeling guidance. All states have hemp laws in place, but not all states have comprehensive programs that establish CBD labeling requirements. The best way to find out if your state requires additional label elements such as QR codes or state approved seals is to search your state’s Agriculture Department, like Florida’s fdacs.gov.
According to Florida’s Agriculture Department representative Maux Flugrath, Florida’s state-regulated hemp products will eventually need to include an approved hemp logo. It is in this environment of state and federal regulations that you must find a way to design an eye catching label that engenders trust and separates your product from competitors. It’s not simple, but it’s definitely possible.
Tips for Eye Catching & Compliant CBD Labels
Be Unique. Be Upfront.
Most companies design their labels with the same basic template: Product name or key ingredient like “CBD” is featured on the front panel while the remaining ingredients and nutrition details are placed on the side information panel. That’s because most companies see an ingredient list as an FDA requirement rather than an opportunity to differentiate their brand.
But what about looking at ingredients (and other regulatory content) from a different perspective? Companies like Upfront Foods and RX Bars are setting themselves apart by designing labels with ingredients at the forefront of their packaging. This is a unique approach to label designs that can draw attention to your CBD product and inspire trust through transparency.
Creatively Display Key Benefits
Regardless of the amazing benefits that CBD is known to deliver, you cannot claim that your product produces therapeutic results.
For example, you cannot say that your highly potent CBD gummy infused with melatonin relieves insomnia because insomnia is a medical condition. But you can design a label that highlights your product’s key benefits and ingredients without using banned medical terms. These key call-outs will help explain how your product works without claiming to cure medical conditions.
In the gummy example above, you might add a phrase like “CBD with soothing melatonin” to the front of the label. You might also get creative with your product’s name to hint at the benefits without making any direct health claims. You can tell customers why they may want to try the product, but don’t falsely promise a cure.
Highlight Your Brand’s Key Differentiators
Make sure that you prominently display your brand’s value propositions, like packaging that’s made from recycled materials or sugar-free gummies. Below are a few ideas to help you think about call-outs that you can add to your label.
- GMO Free
- Responsibly sourced
- Made from recycled materials
- Free of sugar
- Made in America
Use Colors, Textures, and Fonts to Your Advantage
Colors textures and font styles can all help your product stand out on shelves. According to research published in the Journal of Marketing and Consumer Research, color can affect a customer’s mood and attract interest.
Green is associated with nature and elicits feelings of calmness (perfect for Hemp CBD!) Blue is associated with health and peace. Yellow with cheerfulness.
Products with brighter colors also have an advantage over darker colors, according to a psychological study from Avery UK. Another notable finding from Avery was that labels with bold lines, borders and stripes were viewed 42% more than plain labels nearby.
Educate Your Customer
CBD products are everywhere, so it’s easy to forget that the industry is still SO new and filled with confusion. In a survey by Know Instant Insights, 70% of respondents said they had never tried CBD and only about half said they knew the difference between THC and CBD. This provides an amazing opportunity for you to design a label with concise, conversational language that explains what CBD is and how to use it.
For instance, you may want to feature content that explains CBD is a “natural” “non psychoactive” substance extracted from hemp. You can also make it clear that your product is THC-Free.
Advertise Your Product’s Quality
Customers may not understand the benefits of CBD, but they’ve probably heard some of the recent negative headlines related to vaping illnesses and labels with false potency claims. Unfortunately, negative information is what sticks in people’s minds, and it can be difficult to overcome mistrust stemming from a few bad actors.
While the FDA has not issued testing requirements for Hemp CBD in supplements or cosmetics, you can guarantee that your product will stand out if you decide to test with an accredited third party provider, like ACS. Once your product is proven safe, you can add the QR code or testing badge to your label as proof of the results. Adding a testing seal to your uniquely designed label can make all the difference in determining whether or not a customer will trust your product enough to try it.
Before You Hit Print
OK, you’ve designed a beautiful label that stands out and contains all federally required information, in the right font sizes. You’ve also checked to see if your state has any additional labeling requirements. Maybe you even tested your product with ACS and added a QR Code for proof.
Your product will likely stand out above the crowd without any risk of compliance issues, but we still recommend you take it a step further. Before printing any labels, you may want to hire an attorney who is familiar with state and federal regulations. Only then can you sleep easy knowing your product is compliant and retail ready.