Mascara. Tinctures. Candy. You can’t shop wellness or beauty categories (much less scroll through Instagram and its 10 million #CBD posts), without being bombarded with cannabinoid-infused products. And with benefits said to span everything from anxiety and pain relief to minimizing inflammation, it’s easy to see why. But with growing popularity can come confusion and some misunderstanding, especially considering the lack of regulation on the rapidly rising sector. In fact, experts say mislabeled CBD products are much more common than you'd think.
CBD’s sudden ubiquity comes thanks, in part, to the 2018 Farm Bill, which federally legalized cannabinoids derived from hemp plants grown by licensed growers and in accordance with the bill, associated federal regulations, and association state regulations. The Farm Bill preserved the FDA’s authority to regulate CBD products under the Food, Drug, and Cosmetics Act and the Public Health Service Act. But to date, only one CBD product on the market has been evaluated and approved by the FDA (a prescription drug approved to treat two pediatric epilepsy disorders).
The agency is still working to catch up with an exploding market: It’s developing a risk-based enforcement policy for cannabidiol products and has issued dozens of warning letters to companies that have made drug claims or misbranded their CBD products. (Such claims run the gamut from CBD gummies marketed as a treatment for kids to tinctures tied to coronavirus relief.) That said, it’s hard to really know whether the stuff inside actually represents the product as labeled.
In a 2017 study, researchers who purchased and tested 84 CBD products found a shocking 69% of them were mislabeled, with 26% containing less CBD than marked. Meanwhile, the FDA has done its own content testing for CBD products; in a report issued in July 2020, the agency found some 30 percent of 147 products tested did not contain the amount of CBD indicated on the label. What’s more, formulations may contain higher levels of heavy metals (like arsenic or mercury) than are deemed safe by an independent lab or state regulatory agency. Then there are cases of bootleg CBD, with dozens of people getting sick from fake CBD made with a synthetic compound called 4-CCB in one case alone.
But here’s the good news: There are still plenty of reputable brands that deliver honest products. But until the FDA makes more regulatory headway, it’s up to the consumer to make sure a product is legit. Here's how you can do your due diligence.
Reading CBD Product Labels: Source A COA
The first step in verifying CBD labeling claims? Get your hands on a Certificate of Analysis or COA. These certificates provide details on CBD potency in a product; whether the CBD used is full spectrum (containing trace amounts of THC up to 0.3%), broad spectrum (THC-free and extracted with other cannabinoids and terpenes), or from an isolate (THC free and contains CBD extract only); and the levels of contaminants within, including pesticides, metal, bacterial, mycotoxin, and volatile organic compounds (VOCs). In other words, honest and clearly reported COAs can give consumers much-needed peace of mind in a landscape blurred by mislabeling and hazy regulation.
Sourcing COAs for your favorite CBD product should be easy. Several brands, like tinctures and topicals line Physician’s Grade, offer scannable QR codes and on-site URLs that allow COA access by entering a product’s batch code. Others, like body care and supplement brand Prima and Kush Queen (which makes gummies, lube, and bath bombs, among other products) provide access to current lab test results for every product they sell via product pages or website footers, allowing shoppers to kick the tires before point of purchase. If a CBD brand doesn’t provide a specific COA for a particular product, you might want to rethink the purchase, given all the labeling issues in the industry.
Reading CBD Product Labels: Verify Lab Credentials
How do you know if a COA comes from an independent lab run by qualified scientists who conduct sound methodology with well-calibrated instruments? Look for ISO 17025 accreditation, which should be stamped on the COA next to the name of the lab that issued the analysis. “There are several accreditations out there, but ISO 17025 accreditation gives you a lot of confidence that the product has been reviewed by a third-party lab that is practicing good analytical science,” says Jessie Kater, senior vice president of manufacturing at Curaleaf, the world’s largest cannabis company. “If a lab doesn’t have that accreditation, then your guess is as good as mine as to whether the lab results are accurate.”
Kayleen Sabino is the vice president operations at Cannalysis, a California-based ISO-accredited lab that tests CBD and hemp-based products. She sees firsthand the rigor that ISO-accreditation requires and agrees it’s a gold standard in CBD lab testing. “ISO certification holds us to a very high standard. It’s also a requirement by the Bureau of Cannabis Control (BCC),” she notes. Though hemp and CBD-based products don’t fall under the purview of the BCC — the agency that regulates commercial cannabis licenses for medical and recreational cannabis in California — Sabino sees value in carrying the bureau’s laboratory standards over to the hemp and CBD category.
The BCC is known for being one of the most stringent regulating bodies in the cannabis industry, so adopting its approved lab standards is a surefire way to elevate the degree to which hemp-derived products are tested, she reasons. “There aren’t any regulations around CBD testing,” Sabino says. “We treat all of our testing with the same quality standards [that the BCC mandates], even though it’s not necessarily a requirement for CBD or hemp-based products.”
Finally, it doesn’t hurt to place a quick call to the lab that issued the report to verify its contents are correct. “A lot of consumers don't know that some COAs can be doctored or faked,” Sabino notes. She says her lab regularly fields calls from consumers looking to confirm that Cannalysis issued a report stamped with its name. “As a lab, we don’t release COAs directly to a consumer, but if a consumer already has a COA and is calling to confirm that the numbers on the report are correct, we will definitely verify that for them,” she says.
Reading CBD Product Labels: Compare Batch Numbers
“I can't tell you how often a lot or batch number of a CBD product does not match the lot or batch number of the COA,” says Kater. You read that right: Some lab results shared by a company don’t even reflect the product or product batch that it’s purported to. To make sure the COA is actually representative of the product purchased, match the lot or batch number stamped on the product packaging to the lot number in the header of the COA that the company provides. The most clear and transparent COAs will also include a photograph of the product tested within the top section of the document for easy cross-checking.
Reading CBD Product Labels: Measure CBD Potency
There’s no ideal amount of cannabinoids to look for within any category of CBD products (variables include whether the product is designed to be taken internally or topically and for what therapeutic value the product is made), but every product should contain the quantity of CBD labeled. Compare the on-label CBD claims (how many milligrams of CBD are in the bottle and/or serving) to those listed on the COA.
Typically, CBD potency is the first panel of results listed on a COA for a hemp or CBD-based product (look for a list of cannabinoids, like CBD, CBG, and/or CBN). Do the percentages per product and/or per serving align? Make sure to check out the units of measurements used — if they don’t match, you may need to do a bit of conversion to verify what’s on the report backs up the label claims.
Reading CBD Product Labels: Confirm Broad- & Full-Spectrum CBD Versus CBD Isolate
There’s plenty of flexing in the hemp and CBD space about “full-spectrum” or “broad-spectrum” CBD. Some studies have shown broad- or full-spectrum CBD extract may pack higher therapeutic value than CBD isolate alone, while other research shows the opposite. But there’s one thing we know for sure: Full-spectrum or broad-spectrum CBD products — which are distilled with other cannabinoids and terpenes — tend to come with higher price tags, so it’s important to check COAs for the presence of other cannabinoids (like CBC, CBN and CBG) to prove the CBD used is not an isolate.
“These days, there’s a marketing push in the hemp industry toward big broad- and full-spectrum CBD. Maybe there's some credibility to it and maybe there's not, but you’re paying more for products believing that it's broad- or full-spectrum, then having access to the full panel of cannabinoids goes a long way to verify that claim,” Kater says.
Reading CBD Product Labels: Test For Terpenes
Those ponying up for a broad- or full-spectrum CBD product can also prove its validity by checking for terpene profiles in a COA. Terpenes are the organic compounds in plants that are responsible for aromatic and flavor characteristics, some of which have been shown to offer their own therapeutic value as well. Those looking for a CBD tincture to induce relaxation, for example, might benefit from one that shows presence of the terpene linalool, which is also found in lavender and has been shown in studies to help with sleep.
But you don’t need a Ph.D. in phytochemicals to interpret terpene profiles in COAs: Just seeing the presence of terpenes represented on a COA will help verify whether your product is indeed full or broad spectrum. What’s more, seeing terpene profiles listed in lab results is an indicator of a brand’s commitment to transparency. Sabino estimates some 30 percent of the companies that test at the Cannalysis lab offer this information, with the majority leaving it off of COAs (likely because running this panel rings up additional costs).
Reading CBD Product Labels: Get A Chemical Read
Heavy metals, mycotoxins, pesticides, pathogenic bacterial contaminants (like E. coli and salmonella), yeast, and mold — like with any plant-based product, CBD can wield some pretty unsavory elements. And it pays to check the numbers to see how much of this stuff was detected in the CBD used in a formulation. For instance, a COA for one CBD product on the market shows it had tested over the suggested parts per million limit for arsenic.
While it’s natural for some of these trace elements to show up in a panel test, the best CBD contains fewer contaminants than what the most stringent of regulating bodies deems safe. The most transparent COAs will list the parts-per-billion detected along with the threshold the State of California deems safe, so readers can see not only if a pass or fail has been issued but exactly how far below the limit a trace element was found.
In all, expect a learning curve when getting a good read on what your CBD is really made from — including learning some heady units of measurements and chemical names. But as it turns out, taking a deep dive into what you’re consuming offers far more than sheer data: It’s a window into the power of traceability.
Because after reading a COA, you can’t help but think: If we can see the exact makeup of CBD through information shared via a scannable QR code or site link, then why not for other ingredients we put in and on our bodies? In a weird way, the CBD industry may be the thing that triggers a new wave of product transparency and brand accountability for consumers and a future in which we can track ingredient sourcing, environmental impact, and more.
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