CBD UPDATE — POLITICAL MEMORANDUM FOR UNPA MEMBERS
Aug 21, 2023
Dear Colleagues,
I forward the following update from UNPA’s Senior Political Advisors, Patricia Knight & Peter Reinecke.
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MEMORANDUM FOR UNPA MEMBERS
FROM: Patricia Knight and Peter Reinecke, UNPA Senior Political Advisers
RE: CBD Update
DATE: August 21, 2023
In July, in an unusual move, four senior, bipartisan, bicameral Members of Congress issued a “Request for Information” or “RFI” asking 26 questions about cannabidiol which is expected to lay the groundwork for consideration of how CBD sales should be regulated.
The letter was authored by the heads of both the key committees with jurisdiction over the FDA and dietary supplement regulation: House Energy and Commerce Chair Cathy McMorris Rodgers, Ranking Democrat Frank Pallone, Senate HELP Committee Chair Bernie Sanders and Ranking Republican Bill Cassidy. We cannot recall a similar bicameral request.
UNPA initiated discussions on a joint response with the other DS trade associations, believing a unified industry response would be more powerful. We are pleased to share with you the comments of UNPA, AHPA and CHPA in response to the Request for Information which are linked here.
The main theme of our comments is that current law is adequate to regulate sales of CBD dietary supplements. The RFI addressed sales of CBD and hemp derivative products, some of which (such as inhaled and topical products as well as those that may have “intoxicating” qualities) do not have the established safety safeguards and regulatory pathway that dietary supplements have.
In addition, our reply underscores that congressional development of a new regulatory “harm reduction” pathway for CBD, as sought by FDA, is both unwarranted and unnecessary.
There are issues that we believe will have to be addressed with more scrutiny if legislation is developed. For example, safety must be assured in view of reports that high servings (doses) of CBD could result in reproductive or liver problems. We also believe a pathway that allows for short-term use of CBD should be explored and it is not clear whether current law allows FDA to allow labeling as such.
We will continue to keep you posted and are excited by this new development.
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The U.S. Food and Drug Administration (FDA) published a draft guidance on the submission of new dietary ingredient notification (NDIN) master files. The
