Ironically, the only four states where you can be absolutely sure that the CBD content claimed on the label is the CBD content in the bottle are Colorado, Washington, Oregon, and Alaska, where adult-use cannabis is legal and regulated. That’s because the CBD products available in licensed retail cannabis stores must pass state-mandated lab tests to assure their purity and potency. In fact, if these products haven’t gone through state testing, they’re liable to be seized, as happened recently in Alaska.

Unlike THC, which primarily binds to CB-1 receptors located in the brain, CBD works in the body by manipulating receptors throughout organ tissues, the immune system, the pain response system, the hormonal system, and other whole-body regulatory systems. Basically, since its receptors have been found to exist in virtually every cell and tissue type in the body, CBD is believed to work on every aspect of human health and behavior – from the subcellular level to the whole-body leve and beyond.
Your product is not generally recognized as safe and effective for the referenced uses and, therefore, the product is a “new drug” under section 201(p) of the Act [21 U.S.C. § 321(p)]. New drugs may not be legally introduced or delivered for introduction into interstate commerce without prior approval from the FDA, as described in section 505(a) of the Act [21 U.S.C. § 355(a)]; see also section 301(d) of the Act [21 U.S.C. § 331(d)]. FDA approves a new drug on the basis of scientific data submitted by a drug sponsor to demonstrate that the drug is safe and effective.
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