UK Guidance on Limits for Controlled Cannabinoids in CBD Products

Extracts or isolates containing Cannabidiol (CBD) are used in cosmetics and food supplements supplied to the UK market. A new guidance on analytical limits for controlled cannabinoids in CBD products provides information on how to interpret the 1 mg UK limit for controlled cannabinoids. In addition, the guidance lists minimum required detectable concentrations for cosmetics (e.g. body lotion, face wash, lip balm) and food (e.g. gummy bears, oral spray, oral liquid, nutritional capsules), depending on the container size.

Implications of the 1 mg UK limit for controlled cannabinoids

The UK Misuse of Drugs Act (MDA) prohibits in general the supply of psychoactive cannabinoids depending on which part of the cannabis plant has been used. In relation to the supply of CBD products a "Drug Licensing Factsheet-Cannabis, CBD and other cannabinoids" has been published. The factsheet explains that "some products may, in limited circumstances, be considered ‘exempt’ from control, …provided no one component part of the product or preparation contains more than one milligram of the controlled drug…"

However, the amount of 1 mg for the "controlled drug" (CD) in a product or preparation presents the following difficulties in interpretation:

• The CD could comprise one or more prohibited psychoactive cannabinoids,
• Determination of content is made indirectly by measuring concentration (e.g. mg/mL or mg/g).

The new guidance explains that the applicable unit of measure for the 1 mg threshold is the container (i.e. bottle or pack) and not the typical dose. Moreover, the CD may not consist of a single compound but could include several psychoactive cannabinoids that when summarized may exceed the 1 mg threshold. Thus, each psychoactive cannabinoid requires detection at a lower concentration. Combining these effects with varying quantities of products provide different LOQs /LODs (Limit of Quantification / Limit of Detection) for an analytical procedure (i.e. increasing sensitivity as the container size increases).

For more information please read the UK Guidance on analytical limits for controlled cannabinoids.