With the passage of the 2018 Farm Bill, which legalized hemp throughout the United States, CBD emerged as the latest health & wellness craze. While the FDA is currently working on industry standards for CBD products, these regulations have yet to be enacted into law. Hence there’s no quality control on those CBD products available for sale. This, in turn, means that consumers need to do their own research before purchasing any CBD product.
- Is CBD product labeling regulated?
- CBD Lab Accreditation
- What is a Certificate of Analysis?
- CBD product composition
- What constitutes a good COA?
- How to read a COA
- In summary
A US study, for example, showed that seven out of ten CBD oil products did not contain the amount on the label and one in five contained THC when the product was labeled as being THC free. Another study done in 2017 showed 70% of products to be mislabeled.
Is CBD product labeling regulated?
Examples of organizations that can provide oversight of CBD COA quality control
International Laboratory Accreditation Cooperation (ILAC)
The standards for CBD accreditation are put out primarily by the International Laboratory Accreditation Cooperation or ILAC. ILAC stresses international consistency for performing CBD/THC analysis and lists the responsibilities of the manufacturer in producing what is called a Certificate of Analysis. The organization also calls for greater standardization of methodology and conformity to a standard of quality. While other organizations exist for accreditation, ILAC is by far the most credible accreditation facility.
InterAmerican Accreditation Cooperation (IAAC)
The InterAmerican Accreditation Cooperation or IAAC is one of the largest corporations responsible for ensuring the consistency of lab testing and equipment calibration procedures.
Currently, testing is not regulated or standardized despite the encouragement to get accredited. This leads to variability in testing results from lab to lab even with the same sample. Not only is this a safety concern for citizens it is a legal issue for those companies who must remain in compliance with the THC level restriction. These two are just two examples of several groups encouraging standardization and calibration.
CBD Lab Accreditation
Labs can go through an accreditation process that involves a mandated core training program, a documented quality assurance program, and the payment of a fee. ILAC has long been advocating for a standardized training program with all labs using the same testing procedure and quality control procedures for equipment calibration. Equipment calibration involves ensuring the equipment is testing a sample correctly according to a predefined “test sample” and that all equipment parts are in working order according to the manufacturer’s guidelines.
What is a Certificate of Analysis?
This is a quality assurance document that indicates that a regulated product contains what it says it contains and meets product specifications. For CBD a Certificate of Analysis (COA) should contain the contents of the product including total cannabinoids, microbiological levels, terpenes, and possible contaminants such as pesticides, solvent residue or heavy metals. This information does not always come conveniently packaged in a single report but is often shown on several reports.
CBD product composition
Every CBD product on the market is made from one of three kinds of CBD: full-spectrum CBD, broad-spectrum CBD, and isolate CBD. These extracts and isolates can be sold as a standalone product or combined with other ingredients to produce a particular product.
A CBD isolate is an extract where all other compounds have been removed to the point where the product contains only CBD. While an isolate does not contain all the benefits found in hemp plants, it can be a good choice for people who want a product that doesn’t have a hemp taste or with guaranteed zero THC.
THC vs. CBD
Both full-spectrum CBD and broad-spectrum CBD are thick, oily extracts. The key difference between these two extracts is that broad-spectrum CBD contains no THC, while full-spectrum CBD can contain up to 0.3 percent THC in the US and up to 0.2 percent in the EU. Full-spectrum CBD extract contains all the cannabinoids and other compounds found in the plant, such as terpenes, carbohydrates, vitamins, and amino acids. In a broad-spectrum extract either cannabinoids, flavonoids, and terpenes are added back to a CBD isolate or THC is removed from a full-spectrum CBD extract. Broad-spectrum CBD is ideal for those who want the benefits of hemp, while also enjoying a product with no THC present.
What constitutes a good COA?
In an email exchange with Daniel Luebke, Head of Brand and Education for Seattle based Heylo Cannabis, he noted, “A good COA should contain the top cannabinoids and terpenes, as well as microbial and pesticide testing.”
The cannabinoid portion of a COA contains the THC (tetrahydrocannabinol) and CBD (cannabidiol) percentages within the product. This potency is often presented as a percentage of weight or mg/ml. For example, if the COA says a bottle of CBD gel caps contains 200 mg of CBD, and that bottle contains 20 gel caps, each gel cap should contain 10 mg CBD.
Also, the COA should list the minor cannabinoids that may be present, including CBC (cannabichromene), THC, THCA (tetrahydrocannabinolic acid), CBDA (cannabidiolic acid), CBG (cannabigerol), CBN (cannabinol), and THCV (tetrahydrocannabivarin). In particular, consumers should check to ensure their CBD product does not contain more than 0.3 percent THC in the US and 0.2 percent THC in Europe. If the product contains more than this percentage, it’s viewed as cannabis and can only be purchased at a licensed dispensary.
Also, if the product is labeled as hemp seed oil and not hemp extract, the COA will not indicate the presence of CBD. The difference between these two is often misunderstood and consumers looking for the benefits of CBD should take care in choosing products that contain hemp extract and not hemp seed oil.
Most common cannabinoids (aside from THC/CBD) to know about
|CBG||Analgesic, anti-inflammatory, bone stimulant, anti-bacterial, anti-parasitic|
|CBC||Analgesic, anti-inflammatory, anti-bacterial, anti-fungal, anti-depressant|
|CBN||Analgesic, antispasmodic, anti-insomnia|
Terpenes (terpenoids) are the aromatic oils found in cannabis. They interact with cannabinoids and other contents of an extract to create the Entourage Effect, which magnifies the therapeutic benefits of the plant’s individual components—so that the medicinal impact of the whole plant is greater than the sum of its parts. The presence and concentration of particular terpenes in a given product are often measured on a CoA as parts per million (PPM).
Screening for undesirable elements
Luebke states, “The microbial analysis and pesticide test results for a COA reveal the parts of the product you don’t want to be there.” The microbials included in a lab analysis include searching for mold/mildew, yeast, E-coli, and salmonella. Also, labs can verify if a sample is free of mycotoxins, which are the toxic substances produced by fungi.
When the COA indicates your product is pesticide free, this confirms that the hemp source was grown using pesticide-free and organic methods in clean soil. Consumers should be mindful that in some states, pesticide testing is not required for cannabis products. However, those companies concerned about producing a quality product tend to screen for pesticides anyway.
Since hemp is a very hearty plant, it will absorb everything in the soil including heavy metals like arsenic, cadmium, mercury, and lead. A quality lab can test for the presence of these heavy metals.
Extraction methods used to create hemp extracts use chemical solvents. Any residual solvents that remain after extraction will be displayed on the CoA. Solvents like Ethanol are safe for consumer use while any form of glycols like polyethylene glycol (PEG) or propylene glycol (PG) can break down into formaldehyde and other carcinogenic aldehydes.
How to read a COA
At present, there is no one uniform COA form for all hemp products. However, a good COA product should contain the following elements:
- Name of Testing Lab. The name of the lab should not be the same name as the company that made the product. This indicates it is an independent, third-party lab.
- The name and address of the company selling the product.
- Batch Number, also called Lot Number. Be sure the batch number on the COA and product is the same.
- The date the sample was tested. This date also lets the consumer know the approximate age of the product. Properly stored, CBD should last 12-18 months without losing any potency.
- The cannabinoid profile of the sample which lists the cannabinoids detected and their concentration.
- The heavy metal analysis chart notes those metals that were tested. Conc. stands for the concentration of the metal measured, and the unit references the measurement size. ‘Use Limits’ signifies the amount of this product that the by the state Department of Public Health and US Pharmacopeia has determined is safe to ingest daily. MDL signifies the lower limit of detection by the lab instruments.
- The pesticide analysis lists those common pesticides that were tested in this sample. LLD states the lower limit of detection based on each specific pesticide, while the Limits states the maximum amount of a given pesticide that can be consumed based on safety regulations for a particular state.
- The terpene profile analysis notes those terpenes that were detected in the sample, as well as the relative amount of each terpene by weight percent.
ND means there was not enough of a particular item for it to be detected by the laboratory instruments. PASS means that the sample is within the legal limit for any harmful elements, while NO PASS means the sample is above this limit.
Finally, consumers need to know that at present, as no testing is required for CBD products, some companies will not have CoAs available because they do not test their products. However, reputable companies who put out a quality CBD product ensure that their products have been reviewed by a reputable third-party lab to ensure their product meets the quality standards stated on their labels. As Luebke notes, “Companies that publish these test results to the public are going above-and-beyond the law, at their own expense, to provide consumers transparent and verifiable third-party information.”