CBD packaging requirements in the US, UK and EU

CBD is one of the hardest categories to package, not because the design is difficult, but because the rules are unsettled and differ widely between markets. A label that works in one US state may not work in another, and the UK and EU treat CBD food very differently from cosmetics. This guide explains how CBD is regulated in the US, the UK and the EU, what that means for packaging, and how to design CBD packaging that can adapt as the rules change.

It is general guidance as of the review date shown above, not legal advice. CBD regulation changes often. Before you finalise any packaging, confirm the requirements for your product type and market with a qualified adviser.

Why CBD packaging is complicated

CBD (cannabidiol) can be sold in many product types: oils and tinctures, capsules, gummies and other edibles, drinks, cosmetics and topicals, and vapes. Each product type can fall under a different legal framework, such as food, dietary supplement, cosmetic, medicine or tobacco-like products. On top of that, cannabis and hemp laws determine which sources and THC levels are allowed.

So the first question is always: what is the product, and where will it be sold? The answer decides which rules apply.

United States

Federal position

The 2018 Farm Bill removed hemp, defined as cannabis with no more than 0.3% delta-9 THC on a dry weight basis, from the federal definition of marijuana. That made hemp cultivation legal under federal law, but it did not make all CBD products lawful.

The FDA regulates CBD in foods, dietary supplements, cosmetics and drugs. The FDA's stated position is that it is currently unlawful to add CBD to food or market CBD as a dietary supplement under federal law, because CBD is an active ingredient in an approved drug. In 2023, the FDA said existing regulatory frameworks for foods and supplements were not appropriate for CBD and that it would work with Congress on a new approach. The FDA has also issued warning letters to companies making medical claims about CBD.

CBD cosmetics are not subject to the same prohibition, but they must meet cosmetic rules, including labelling and MoCRA requirements, and cannot make drug claims.

State rules

In practice, CBD products in the US are mainly shaped by state law. States vary on:

• whether CBD food and drinks are allowed
• testing and certificate of analysis (COA) requirements
• labelling requirements, such as CBD content per serving and per package, batch numbers, QR codes linking to COAs, and warnings
• child-resistant packaging for some product types
• age restrictions and marketing limits

If you sell in several states, you may need different labels or a label that meets the strictest set of rules.

United Kingdom

In Great Britain, CBD food, drink and food supplements are regulated as novel foods. The Food Standards Agency (FSA) keeps a public list of CBD products that are linked to novel food applications and can remain on the market while those applications are assessed. Products not on the list should not be sold.

The FSA has also issued consumer advice on CBD intake, recommending that healthy adults limit their daily intake. Many brands include this advice and the dose information on pack. Check the FSA's current guidance for the latest figure and wording.

CBD cosmetics in the UK fall under cosmetic rules. They must use permitted ingredients, have a safety assessment and carry standard cosmetic labelling. Products must also comply with UK laws on controlled drugs, which are strict about THC and other controlled cannabinoids.

European Union

In the EU, CBD extracts in food are treated as novel foods, which require authorisation before they can be sold. The European Food Safety Authority's assessment of CBD as a novel food was paused in 2022 pending more safety data. As a result, there are currently no EU-wide authorisations for CBD as a food ingredient, and enforcement varies between member states.

For cosmetics, CBD can be used if it meets the EU Cosmetics Regulation's rules. The European Commission's CosIng database distinguishes between CBD that is synthetic or derived from permitted parts of the plant and preparations from parts of the plant that are not permitted. Check CosIng and your adviser's guidance on your source.

Member states also have their own rules on THC limits and cannabis products.

What CBD packaging typically includes

Requirements vary, but many CBD packs, especially in the US, include:

• product name and form, such as "CBD Oil Tincture" or "CBD Gummies"
• CBD content: total per package and per serving
• serving size and number of servings
• ingredient list, with allergens where relevant
• batch or lot number
• a QR code or URL linking to a certificate of analysis from an independent lab
• warnings, such as for pregnancy, breastfeeding, medication interactions or keeping out of reach of children
• "Not for sale to minors" or age statements where required
• name and address of the responsible business
• net quantity
• nutrition or supplement-style panels where required by the relevant framework

Claims: the biggest risk

Medical and health claims are the most common reason CBD brands get into trouble. Statements that CBD treats, cures or prevents any disease, or helps with specific medical conditions, are generally not permitted on CBD products outside of approved medicines. Even softer claims about anxiety, pain or sleep can be treated as medical claims.

Keep front-of-pack copy to the product, its form and its strength. Have every claim, including those on your website and social media, reviewed by your adviser.

Designing CBD packaging that can adapt

Because the rules change often, CBD packaging should be designed to adapt:

Separate brand from regulated content

Keep the brand, product name and strength on the front panel. Put regulated content, such as warnings, serving information and COA links, in a defined area on the back or sides that can be updated without redesigning the whole pack.

Plan generous space

Leave more space for mandatory text than you think you need. Warning statements tend to grow over time, and new requirements are added.

Use stickers or variable panels for markets

If you sell in several states or countries, consider a base design with a market-specific sticker or panel, rather than separate full print runs.

Make strength and testing easy to find

Customers want to know how much CBD they are getting and whether it has been tested. Give total CBD, CBD per serving and the COA QR code a consistent, prominent place on every product.

Child-resistant packaging

Where required, choose certified child-resistant containers and design labels and outer boxes around them. See our child-resistant packaging guide for more detail.

A CBD packaging checklist

Before artwork goes to print, check with your adviser that:

1. The product type and its legal framework are confirmed for each market.
2. The CBD source and THC levels meet the rules where the product is sold.
3. CBD content per package and per serving is stated in the required format and matches the certificate of analysis.
4. The batch number and COA link or QR code are present and working.
5. Warnings required in each market are included, word for word.
6. Claims have been reviewed, on the pack and in your marketing.
7. Age statements and child-resistant packaging are in place where needed.
8. The responsible business name and address are correct for each market.
9. Space is left for future changes, such as new warnings.

Planning for change

CBD rules have changed several times in a few years and will keep changing. Build that into your packaging plan: order smaller print runs at first, keep artwork files organised by market, and set a regular review date, at least every six months, to check that labels are still current.

How we help

We design CBD packaging and make printed and rigid boxes in our own factory. We lay out the regulated text you supply, plan space for market-specific content and design packaging that looks credible and stays clear. We do not decide what your packaging can claim or confirm compliance; final regulatory review stays with you and your adviser.

See our CBD packaging design and supplement label design services, or get a free quote for your CBD range.

Official sources

• FDA: Regulation of cannabis and cannabis-derived products, including CBD
• Food Standards Agency: Cannabidiol (CBD) guidance
• European Commission: CosIng cosmetic ingredient database

Need this on your packaging?

• CBD & Hemp Packaging Design →
• Supplement & Nutrition Packaging Design →

Popular box styles: Tuck End Box, Mailer Box, Magnetic Closure Box

Get a Free Quote

Questions

Can CBD be sold as a dietary supplement in the US?

The FDA's position is that CBD products cannot currently be lawfully marketed as dietary supplements or added to food at the federal level. State rules vary.

Is CBD food legal in the UK?

CBD food and drink is a novel food in Great Britain. The FSA keeps a public list of products that can stay on sale while their applications are assessed.

Can I make health claims on CBD packaging?

Medical and health claims are high risk in every market. Discuss any claim with your adviser before it goes on pack.

What should CBD packaging show?

Commonly strength, total CBD, serving, batch number and a route to lab results, plus whatever your market requires. Your adviser confirms the list.