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CBD in bath products. Legal or Not?

I know there have been many posts about CBD and I've had several ocustomers inquire about adding CBD to formulations (we can't since CBD is still considered a Schedule 1 substance in OH where we are located, our insurance won't cover it and banks still will not accept funds from CBD products).

For me personally, CBD is still a risky additive for cosmetics due to the lack of federal oversight. I also think that regulation will be coming down the pike for small cosmetics manufacturers ,like myself, who are using CBD, if not for the entire cosmetics industry.

The article below is from The National Law Review. Its a good read if you're considering CBD in your cosmetic products.

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"While the legality of CBD as a product and as an ingredient is still in flux at the federal and state levels, there are a few things we can glean from recent government action relating to CBD products.

First, FDA does not consider adding CBD as an ingredient of food products or dietary supplements permissible under the law. Indeed, before 2018, FDA issued 18 Warning Letters relating to drug claims associated with dietary supplement products containing CBD. However, since October 2018, FDA has not taken any enforcement action against CBD product manufacturers.

Second, FDA has taken no enforcement action against manufacturers of cosmetic or topical products containing CBD and has not made any public statement about the possible safety risks of using CBD cosmetic products. Since FDA has not taken a policy position on CBD in cosmetics, such products remain in a regulatory gray area for now. However, FDA is still likely to take enforcement action if a manufacturer makes drug claims regarding a cosmetic product with CBD as an ingredient.

Third, while the Agriculture Improvement Act of 2018 (the "Farm Bill") legalized the production of industrial hemp and products derived from hemp, it did not legalize all uses of and products containing hemp derivatives (such as CBD)."

So for now CBD just isn't an option for Double D, but hopefully in the future we will be able to move forward in new product formulations. Thanks!!!! 

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