The CBD Industry’s Mislabeling Crisis & How to Overcome It

Home Blogs The CBD Industry’s Mislabeling Crisis & How to Overcome It

The CBD Industry’s Mislabeling Crisis & How to Overcome It

As the markets for cannabis, hemp, and CBD continue to grow (no pun intended), the industry must contend with a new set of challenges: inconsistent product labels.

Introduced at the CBD Summit at Expo West, one presenter brought up a study conducted by the Journal of the American Medical Association called the Labeling Accuracy of Cannabidiol Extracts Sold Online.

Researchers used purchased CBD products from online retailers and replaced the labels with individual generic labels to carry out a blinded study. These products were then sent to a laboratory for testing and analysis. The lab rigorously tested and analyzed the composition and potency of each product against its generic label. Surprisingly, of the 84 products tested, results were all over the board.

Products were broken down into three types: oils, tinctures, and vaporized liquids (e-liquids) and their results placed in three categories: accurate, over labeled, and under labeled.

Here’s a breakdown of the results:

  • Most of the 84 products were incorrectly labeled
  • Vaporized CBD was the most inaccurately labeled
  • Oils were the most accurately labeled
  • THC levels were all over the place, and sometimes well above the 0.3% THC threshold

Takeaways from JAMA:

Overall, mislabeled products represented a good percentage of products tested to the point of mitigating therapeutic benefits of CBD. In such a competitive industry, brands must ensure that customer experiences are consistent and associate quality with a product. Not only associating quality and consistency with customer experiences, but companies are also able to leverage this as a competitive advantage.

Additionally, CBD products exceeding 0.3% THC run afoul of most state regulations. In other industries, mislabeled products are subject to action by the Food and Drug Administration (FDA). To combat mislabeled products, the cannabis; CBD; and hemp industries need more oversight than state reporting systems. Manufactured or processed products require separate standards fall outside the scope of a state system.

GMPs to the Rescue

You might be asking; how can my company address mislabeled products? The answer lies in a relatively new concept for these markets: Good Manufacturing Practices (GMPs). You may have heard the term before.

GMPs are the minimum standards companies must comply with in FDA regulated industries. Specific GMP requirements vary from industry to industry. Pharmaceuticals have very tight controls, whereas dietary supplements have somewhat looser parameters. The FDA does not regulate cannabis; hemp; or CBD (yet), but adopting GMPs can eliminate mislabeled products and normalize consistency.


Here’s another technical concept: Specifications. These are standards for characterizing materials and ingredients. Meeting specification is a major tenant of GMPs.

After setting up specs, companies conduct tests for incoming ingredients from vendors. Ingredients that meet or exceed standards are available for use in batches, whereas those that do not meet standards are rejected. Another important thing is to source materials from quality vendors. Ideally, companies qualify vendors to get a sense of the ingredients’ quality. Standard Operating Procedures (SOPs) provide guidance on how to qualify a vendor.

Through specifications, companies set their standards for things such as purity, quantity, etc. This data, along with conformance to those standards, provide accurate labeling information. The consistency created by use of specs ensures that a consumer’s experience is the same whether they bought it on a Tuesday or repurchased it in another location the following week. Companies like Coca-Cola provide a consistent product batch to batch – and specs are the key.

Once a completed, batches once again tested against specs – much like materials, batches that meet quality standards can go right out the door and into a customer’s hands. The product quality will speak for itself.


Specifications represent a solution to the ever-growing problem of mislabeled products. Adding a solution to create and manage specs is a secret weapon to not only improving a brand’s quality and consistency but also eliminating labeling errors.

InstantGMP™ MES provides the workflows necessary to create a foundation built on GMPs and is set up akin to Turbo Tax for ease of use. Get in touch to learn more about how specs are set up in InstantGMP™ MES through a live demo.