Episode 21 – What’s Behind the Letters?



Joe: This episode of the "CBD University Podcast..." So many letters, CBD, COA, FDA, THC, QR, QC, cGMP, and that's just some of them. We're going behind all the letters that consumers, distributors and retailers should be familiar with in the industry when shopping for CBD products. We're giving you the DL on this episode of the "CBD University Podcast" that starts right now.

I'm Joe Agostinelli, the host of the "CBD University Podcast." If you're a returning listener, we thank you once again for tuning in. And if you are watching us on our YouTube channels, thank you for also watching the full video episodes on our YouTube channel. If you are a new listener or viewer, we welcome you to the podcast and we hope that you will subscribe on your favorite podcast app or on our YouTube channel and get notifications when new episodes are published.

There are so many acronyms in the CBD industry and that industry is not alone, but consumers, retailers and distributors need to be familiar with all of these. And to help us go through the alphabet and what you need to know about each, I welcome back to the podcast our chief compliance officer, Margaret Richardson. We gave Carl, the Compliance Camel, the day off. Margaret is here flying...flying solo. You usually have your companion.

Margaret: I do. Well, we figured he needed a little bit of a break. He's tired.

Joe: Yeah. Give him a day off, so. So let's start with some of the most common acronyms in the, you know, in the industry. And I think obviously the most familiar one when we talk about CBD is the differentiators between CBD and THC.

Margaret: Sure. So, yeah, certainly if you're a consumer in the marketplace, you probably spend a lot of time Googling. And CBD is one of the most commonly Googled terms. It just really points to a specific cannabidiol that is derived from industrial hemp. So you really have to go back just one step further between THC and CBD. Most people are probably familiar with marijuana. Industrial hemp and marijuana are very similar plants. The big difference is marijuana produces THC, which is the chemical that provides the psychoactive effect or the high, whereas industrial hemp does not have the THC component. And that's where we derived CBD or the cannabidiol from in our extraction process and what we add to our infused CBD products.

Joe: And when we discuss government entities and we've talked about this on past episodes, obviously there's no specific regulations yet at the federal level. We continue to wait on that. So let's talk about the USDA, the FDA, the EPA, the FTC. First let's talk about the USDA and their role.

Margaret: Yeah. So the USDA really kind of led the way to be honest with you in terms of making industrial hemp and the extracts like CBD legal in the U.S. So in 2018, December 2018, the Farm Bill was passed. The Farm Bill has lots and lots of things in it. One small component was the allocation of allowing growers to produce industrial hemp and industrial hemp extracts. That was really what kicked off the CBD industry. So the USDA continues to be actively involved in industrial hemp. They approve all of the industrial hemp plans that are submitted by each state. So every state can regulate their industrial hemp program as they want to. That program gets presented to the USDA and the USDA either approves it or disapproves it. Just generally speaking, they approve them and they're all pretty much the same, kind of cut and paste that.

Outside of the USDA, when the Farm Bill was passed, it also contained a component that said that the FDA was going to be responsible for regulating the extract CBD or CBG or any of the other extracts. And so the FDA, the Food and Drug Administration, people are probably really familiar with it, if you buy prescription drugs, you know that the FDA is the group that approves those. But the FDA regulates lots and lots of products that we come in contact every day, dietary supplements, food, beverages, cosmetics. And so the FDA is theoretically, once they decide their guidance will be who really regulates the industry from a federal perspective.

The other two, so the EPA, the Environmental Protection Association really that was how to do pesticides. So in this case, the USDA has not said which pesticides or herbicides are okay to use on industrial hemp. The EPA has to make that decision. And so the EPA is the group that theoretically will decide which pesticides you can use on industrial hemp. Right now you can't use any pesticides on industrial hemp. And I'm sure in the future, once they get some testing data, they will allow some pesticides to be used.

And then, you know, outside of those regulatory agencies, you have the Federal Trade Commission and the Federal Trade Commission really deals with labels. Even though the FDA regulates labels specifically for prescription products, the Federal Trade Commission can actually come after companies for mislabeling, saying things that they shouldn't say or for instance, if they don't label them with things like weights. And they have a lot of other requirements in terms of ingredient list that they like to see on labels. And if you don't do them properly, then the Federal Trade Commission can take you to court.

Joe: And then on our most recent episode, we profile the products in our new product line of premium hemp-derived CBD products for pets. So that leads us to the AAFCO. How does that come into, yeah, how does AAFCO come into play now?

Margaret: Well, AAFCO is really...it's not a government agency. It's basically a non-government entity. They have for years come up with regulations that the states then adopt and implement for a variety of different products. One of them is pet food. And so they, and the FDA kind of co-regulate pet food and pet products. The FDA approves any product that is designed to, you know, cure or treat a disease in animals. Whereas AAFCO, as I said, is really a non-government entity that creates regulations and then the states adopt those and implement them at the state level. And so you can have different label requirements depending on the particular state that you're selling in.

Joe: And let's shift first to the manufacturer distributor role here that we play. And as a manufacturer and distributor of premium hemp-derived CBD products, how does CFR and CGMP come into play for us?

Margaret: Yeah, so CFR really is an acronym for the Code of Federal Regulations. The FDA is the group that implements the Code of Federal Regulations. So for us on the CBD side our organization really follows two different CFRs. One is part 117, which is for food and beverages. And the second is 111, which is for your dietary supplements and OTCs. So those are basically a set of rules that the FDA then implements and they implement them through the good manufacturing practices or what we commonly call CGMP. And the little C is really just current. They change all the time although the actual written documentation doesn't change all the time. What happens is, you know, companies get smarter, testing becomes more accurate. And so the industry as a whole makes changes to their rules internally, their standard operating procedures to make sure that they are following the current requirements in their industry. So it'll be different changes in test methods and stability studies, those kinds of things.

Joe: And on the consumer side, we talked about the QR code. That leads us down a whole path of some acronyms because the QR code will tie into QA, QC, and ISO. So what does that QR code do and how do they all play together?

Margaret: Yeah, so the QR code again, one of the... As a consumer, you should definitely be looking for QR codes on all your products. The QR code is designed really to provide a link to information for consumer so they can see what that product has been tested for. So in this case, the QR codes, most of the states require that you create a full panel, which is a test or a set of results that tell you, for instance, the potency of your product, that it doesn't have any kind of bacteria or pathogens in it. You know, what are the components of the CBD? Is that CBD just by itself or CBG? Are there terpenes in it? Are there any pesticides, residual solvents, those kinds of questions? So you get what's called a certificate of analysis, or as we shorthand call it, the COA. That's what you're gonna see when you do your QR code.

The real important issue is with the testing whether or not the lab that's doing the testing and it's a third party, so it's not the manufacturer of the product, but that that third party has been certified to test CBD or hemp products. And that testing and certification process is ISO which is just International Standards Organization. It's another non-government entity that creates standards that people adopt. And so ISO-certified means that you have adopted the appropriate standards to test product and the states and the federal government recognize those as appropriate for CBD.

Joe: And I know we talked about this on a recent episode, maybe not in a recent episode but you know, a few episodes back, we broke down exactly what that COA is.

Margaret: That's right. We did.

Joe: Is there any difference? A reminder for those who maybe have not listened or watched that podcast, is there any difference between the COA for distributors that they would see as opposed to a consumer or is it all the same?

Margaret: It's absolutely the same. It should be. Whenever you have the QR code and you scan it, it should bring up that full panel and that full panel would be available to anyone that scans the QR code regardless of where they are.

Joe: And I'm trying to think, is there anything we left out of the alphabet here that we did not cover as we break down all the acronyms and why they're important to consumers and retailers and distributors?

Margaret: Well, I would just say, you know, most importantly as a consumer, you know, you want to make sure that A, your product has a QR code on it. You know, even if you can't remember lots of the other things that we've talked about and that it links to a full panel so that you can know that your product's safe and effective. And really, what that full panel does is it shows you that there aren't any problems with the product. And it also proves to you that that company is following quality control requirements or what a lot of people think of as QC, which is just a fancy word for saying you know how you're making your product, you're testing it appropriately. You have process checks along the process of making the product at the beginning when the raw materials come in, during the actual manufacturing and then of course the finished good.

And so no matter what product you're buying, those are the things you wanna keep in mind. A lot of the... You don't have to memorize things like CFR and Federal Trade Commission and those kinds of things. Focus on making sure that your trusted CBD partner and whoever you're buying the product from has those basic elements, that QR code, it links to a full panel, and that they're making sure that that full panel is with a lab that's ISO-certified

Joe: And just a reminder, for more information on all the topics that we talked about on this episode of the "CBD University Podcast," you can certainly go back and listen to past episodes as we've covered some of these before, but if you wanna see exactly how to read that QR code on products, you can visit our brand websites and there are blogs on each of those websites that discuss about this. There's also a compliance blog written by Margaret Richardson, my guest today and our co-owner Kevin Collins that you can find on the Global Widget website, which is where you can also find all the past episodes of the "CBD University Podcast." Margaret, I thank you for breaking down... I think we went through the whole...

Margaret: Whole alphabet.

Joe: ...alphabet except for X, Y, Z.

Margaret: We can come up some for that.

Joe: We'll come up with something. Yeah, we'll come up with the letters we left out. We'll have to come up with something for them. So I thank you once again for being a guest on the podcast. Thank you as always for taking time out of your busy day to join me.

Margaret: Thanks.

Joe: And once again, that was Margaret Richardson, the chief compliance officer here at Global Widget. We invite you to subscribe to the "CBD University Podcast" on your favorite podcast platform of choice, or on our YouTube channel where you can watch full video episodes as I wave to the camera, and subscribe also on YouTube to get notifications when there are new episodes published each week. I'm Joe Agostinelli, the host of the "CBD University Podcast." Thanks for tuning in.


These statements have not been evaluated by the Food and Drug Administration. CBD products are unintended to treat, cure, or prevent any disease or condition. Always consult your personal physician about CBD and using CBD products. CBD should never be used by anyone under the age of 18. This podcast is not intended to provide legal advice regarding the legal status of CBD and CBD products.