In the absence of clear regulation around hemp CBD products, these certifications and standards are helping quality brands stand out.
Amidst the growing number of products in the hemp-derived CBD marketplace, certifications and manufacturing standards are quickly becoming one way for products to differentiate themselves from competitors. On Hemp Products Connect, users will be able to view and filter based on key industry certifications, indication of third-party testing and disclosure of ingredients, methods and quality control measures.
Increasingly, it is common to see products highlight attributes in the form of a list or using icons, to offer clarification to consumers as to what that product may or may not contain. These attributes include callouts such as: organically grown, organically farmed hemp, THC free, lab tested, third-party lab tested, non-GMO, pesticide free, made in USA, vegan and cruelty free. It’s important to note that while these statements may be accurate, they have not been evaluated by the FDA. There are, however, some baseline measurements to assess if a company is producing quality products.
Assessing hemp quality
Certificate of Analysis
A company should be able to produce a Certificate of Analysis (CofA). This is a document that verifies a product and its ingredients, its specifications and testing methods. It basically verifies that a product is what it says it is, contains what it says it does and is made to consistent specifications. A Certificate of Analysis should verify the amount of cannabinoids in each product as well as the level of THC (if there is any). A Certificate of Analysis also will detail levels of heavy metals, pesticides and other toxins found in the product. Some hemp companies do currently provide access to a Certificate of Analysis online. At the very least companies should be able to produce one when asked for one. Retailers should be asking for these and it is common for consumers to ask to see them as well.
Just like quality dietary supplement companies, companies making hemp-derived products should be conducting batch testing for traces of contaminants such as metals and other toxins. Retailers and consumers should be aware that true batch testing is done on each new lot of material used in a single SKU. Some products may seem to have batch testing by use of QR codes, but be aware that a QR code does not actually guarantee testing is done on each new lot. Some companies that are “testing” do not actually test every new lot.
Current Good Manufacturing Practices
Facilities producing hemp products should be FDA-registered and follow current Good Manufacturing Practices (cGMPs). cGMPs are typically enforced by the FDA and they are designed to support systems that “assure proper design, monitoring, and control of manufacturing processes and facilities” (fda.gov). Dietary supplement and pharmaceutical companies adhere to these standards to ensure products are produced consistently to high standards to minimize risks. Current Good Manufacturing Practices are considered a minimum standard for high quality finished product safety. Adherence to Current Good Manufacturing Practices is self-reported and not necessarily verified by the FDA. It’s best to look for a third-party cGMP certification to ensure the manufacturing facility is indeed compliant. Some common third-party cGMP certifiers include: NSF International, Banned Substance Control Group (BSCG), Eurofins, NPA and Validus.
In addition to these standards, there are a few certifications that retailers and consumers can look to as a sign of quality.
Hemp CBD certifications to look for:
USDA Organic Certification
Qualified industrial hemp producers can receive USDA Organic certification. This long-standing certification is well established in other sectors. To attain this accreditation a farm or business must adopt organic practices and then apply to a USDA accredited certifying agent who will subsequently inspect the applicant’s operations to ensure it meets organic standards. For a product to be considered USDA Organic, it must meet organic standards from seed to sale. The hemp must be grown using certified organic standards, as well as all ingredients used in the final product (such as oils) must meet organic standards as well. Organic CBD products must be manufactured in a USDA certified organic facility and all steps of processing must meet organic standards. While many companies tout that they are organic, if the USDA organic seal is not on the product then they may be using organic ingredients, but they are not certified organic. To attain USDA Organic certification, ingredients and the end product must comply with one of the four labeling options for U.S. organic standards. These options are based on the percentage of organic ingredients in a product and the processing practices a company uses. The four options for products include:
100% Organic—It has been produced using exclusively organic methods and only organic ingredients.
Organic—This is for products that contain at least 95% organic ingredients, the remaining 5% can only be natural or synthetic if they are not available in organic form and have been approved by the National Organic Standards Board.
Made with organic—These products are made with 70-94% organic ingredients.
Ingredient panel—For products containing less than 70% organic ingredients they can list organic items in the ingredient panel but they cannot make any mention of being organic on the front of the label.
NSF International/Quality Assurance International (QAI)
NSF International offers testing and certifying services in other industries such as food, sports nutrition, dietary supplements and beauty and body products. NSF is now offering independent testing, verification, auditing and certification services to manufacturers of consumer products containing hemp and hemp-derived CBD products.
NSF is also a USDA-accredited organic certifier and offers organic certification of hemp and hemp-derived CBD products. QAI falls under the NSF International umbrella. It offers USDA Organic certification of hemp crops, products containing hemp or hemp-derived CBD for U.S.-produced hemp products or those using lawfully imported hemp.
For hemp, and hemp-derived products, both NSF and QAI offer, among other services, USDA Organic certification, NSF’s non-GMO certification, NSF’s certified gluten-free certification, GMP audits, raw ingredient verification, raw material and single ingredient finished goods testing of hemp products to quantify CBD and confirm permissible levels of THC.
Glyphosate Residue-Free Certification
This certification is relatively new, arriving in the marketplace in the spring of 2019. It was developed and is managed by the Detox Project. Glyphosate is more commonly known as the chemical found in the glyphosate-based weed killer Roundup. If you were following the news in the spring of 2019 then you might be familiar with the lawsuits facing the German chemical company Bayer AG, owner of Monsanto, which makes Roundup. Bayer AG is facing thousands of cases alleging that glyphosate causes cancer. To date, juries have agreed that the company failed to give users ample warning of the cancer risks associated with this herbicide.
In relation to hemp, the hemp plant is a bioaccumulator, meaning it readily soaks up everything in the soil in which it is grown. If synthetic fertilizers are used to grow it, and if there are toxins and heavy metals in the soil where hemp is grown, it will soak up all of these toxins. When CBD is extracted from these hemp plants, there is a good chance the resulting product will contain glyphosate, among other toxins.
While many companies say their product is clean or grown on organic soil, without any method of validating this to be true, the Glyphosate Residue-Free certification is one recognized method to verify that a product is clean.
To attain this certification, a third-party ISO 17025 accredited laboratory will test products to make sure they do not contain glyphosate residues. Products attaining the certification must “have no glyphosate residues down to government-recognized limits of detection (LODS) for food, commodity and supplement samples (usually 0.01 ppm)” (detoxproject.org).
LegitScript CBD Certification
This is a third-party certification that verifies manufacturers and merchants of legally compliant CBD products. It verifies that the hemp used in the product is from legally cultivated hemp. This certification can only be used on products that are currently legally compliant with USDA, FDA, FTC and DEA regulations, such as topicals, cosmetics and soaps.
U.S. Hemp Authority Certification. This certification is used by growers, processors/manufacturers and brand owners and is currently designed for hemp food, hemp dietary supplements and hemp cosmetic companies. To attain this seal, companies must successfully pass the stringent standards set out by the U.S. Hemp Authority and pass a third-party audit by Validus (known for its certification and verification services in the food industry), which verifiers that participants meet cGMP and/or GAP standards among other standards and best practices. This certification is aimed to help build consumer confidence around products that are self-regulating in the absence of tight industry regulation. This program is funded by the U.S. Hemp Roundtable and supported by other organizations such as the Hemp Industries Association. While Guidance Procedures 2.0 found on the Hemp Authority site outlines in detail how to attain certification, the certification process takes into consideration the following:
Quality management systems
Master manufacturing records
ISO quality standards
Current good manufacturing practices
Employee training for best practices
Good agricultural practices
In the absence of clear regulatory guidelines from the FDA, consumers, retailers and quality manufacturers need to be their own watchdogs. In doing so, it is necessary to confirm that even with the presence of transparency tools like QR codes that a company is producing what it says it is and testing each batch of product along the way. Certifications and associations can help with the vetting process but should not be relied upon entirely to guarantee a product’s quality.