You may have seen that the FDA recently reported that the agency has issued a number of additional warning letters to 15 companies for selling products containing hemp-based CBD in ways that violate the U.S. Food, Drug, and Cosmetic Act (link; also see my partner’s related post at link). These come at a time of heightened risks for the industry as CBD product litigation mounts (discussed by my partners in link) while businesses wait for word from the FDA on its regulation of certain CBD products. This all highlights the need for careful and thoughtful attention to how CBD products are marketed, something my FDA regulatory partner and I recently discussed on a webinar (which you can watch here: link). As I noted in a recent Cannabis Musings, compliance cuts a broad stroke (link), but particularly when dealing with a keenly-focused federal government agency.
December 3, 2019
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