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Formulating with CBD

Formulating with CBD

CBD an overview

The legalisation of cannabis and cannabis-based products is currently one of the most frequently debated topics in the media. However, unlike THC (which was only legalised for medical use in November 2018), CBD is not a controlled substance in the UK and can be used in cosmetic products as long as they follow the various pieces of relevant legislation.

CBD or Cannabidiol is one of 113 known cannabinoids found in the cannabis plant and can account for up to 40% of the plant material. It is non-psychoactive unlike the other well know component of cannabis plants Tetrahydrocannabinol (THC) which cosmetic grade CBD should not contain.

Clinical research is currently underway into the medical benefits of CBD by several governments and independent research groups, and currently, it is understood to be beneficial in the treatment of arthritis, diabetes, alcoholism, chronic pain, PTSD and epilepsy amongst others.

Since 2017 when the WHO released a report [1] revealing CBD’s possible use in the treatment of these illnesses its use has skyrocketed.  A report, issued by the Cannabis Trade Association, showed a rise in the number of people using CBD from 125,000 in 2017 to 250,000 in 2018[2].


CBD in Cosmetic products

This legitimising of CBD’s medical properties has now opened up its use in many new types of products beyond the oils it was mainly used in up to this point.

Although it is not fully understood how CBD works when applied as a topical product, it has enticing properties for the cosmetic market including anti-inflammatory properties which help combat acne and signs of ageing, pain relief for joints and it has been shown to help with eczema. CBD has also been found to be a good vegan alternative for beeswax and helps with conditioning properties in hair care. Scientists are increasingly finding evidence of its ability to treat several skin disorders by regulating oil production [3] and due to this endorsement and its potential to help manufacturers go vegan, it is now appearing in many new face crèmes, serums and body lotions.

This is a big step for consumers who want to avoid more extreme treatments for acne like Accutane which causes several side effects which can be painful like skin redness and peeling.

However, the companies wanting to move into this growing market must be aware of the rules that dictate its use in the UK. It is also important to be aware that these properties are not traditionally part of cosmetic product function and brands must be careful when writing product claims not to stray into the medical borderline an example of this is, “Prevents Acne” is classed as a medical claim, however “controls spots” is a cosmetic claim. It is also possible that further research into the therapeutic properties of CBD will result in the reclassification of CBD into a medical product.


Rules for using CBD in consumer products within the UK

CBD for use in cosmetics must originate from sources which are not controlled by the Misuse of Drugs Regulations 2001(MDR) [3]. There are several sources of CBD each of which has its own rules under this act.

  • Hemp Seeds – Hemp seed oil is not prohibited by Annex II of the Cosmetic regulation and is not controlled under the MDR
  • Hemp leaf extract – As long as the leaf is used without the flowering top and cannot be readily converted to a harmful substance which could constitute a health risk. If the leaf is used it must be shown to contain less than 1mg of a controlled substance.
  • Synthetic CBD – Pure CBD is not a controlled substance as long as it is in its pure form and does not contain any controlled substance e.g. specific cannabinoids
  • Plant-derived CBD – Plant-derived CBD can be used as long as it is not produced from the flowering tops of the plant and it is pure containing no controlled substances according to the MDR 2001


What can MSL do to help?

Here at MSL we can help manufacturers register their new products on the UK, EU and US markets, acting as your Responsible Person we will ensure your artwork, product claims and testing are all correct and fall with all bounds of the regulations and law. With MSL’s services, we can ensure you have a smooth route to market to provide new and unique products to potential users already interested in this ingredient.

For further details about what we can offer please contact our cosmetics team



[1] CANNABIDIOL (CBD) Pre-Review Report – WHO

[2] Cannabis Trade Association -

[3] Cannabidiol exerts sebostatic and anti-inflammatory effects on human sebocytes (Oláh et al., 2014) – Journal of Clinical Investigation