July 2, 2019 @ 2:02 PM

 

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The demand for CBD skincare products in the aesthetic market are enormous. If one reads the numerous websites with CBD skincare product claims, one will notice companies who market their CBD serums, creams, lotions or other CBD skincare products with these benefits :

 

  • stimulates collagen 
  • reduces inflammation
  • provides anti-bacterial properties for acne
  • treat and controls acne
  • provides powerful anti-inflammatory benefits for rosacea skin
  • alleviate eczema, rosacea and sensitive skin rashes
  • alleviating acne, scars, eczema, psoriasis and wrinkles
  • repair tissue damage
  • promotes healing and reduces symptoms of acne and rosacea
  • It has anti-inflammatory and anti-allergenic properties that can help reduce the redness and irritation of sensitive or damaged skin.
  • Stimulates new skin cell production; increases collagen and elastin production
  • Reduces inflammation on a cellular level
  • Reduces sebum production clinically
  • Reduces redness and suppress itch

 

Did You Know?  These are all Drug Claims   

 

According to the FDA, these above marketing claims would be considered drug claims, referred to as “misbranded drugs”.

The FDA would determine that the above marketing claims about a CBD skin care product are drugs under section 210(g)(1) of the FD&C Act because they “are intended for use in the diagnosis, cure, mitigation, treatment, or prevention of disease and/or intended to affect the structure or function of the body.” 

The FDA has been issuing warning letters to companies who are making these CBD skin care product claims. As the market grows into the billions, there will be more skin care internet companies, and social media sites making CBD skincare " drug" claims and receiving FDA warning letters.

 

  Avoiding Drug Claims   

Although CBD may contribute to an anti-inflammatory effect on the skin, one should not market their CBD Skincare product(s) with the word "anti-inflammatory" on their website, product label, marketing materials, or social media sites. 

To avoid making drug claims:

  • Refrain from making any health, therapeutic or medical claims.
  • Avoid calling CBD extract an "active ingredient" on your product label, marketing materials.
  • Avoid making any references to treating or healing diseases or conditions( ie.managing conditions such as eczema, psoriasis, and rosacea).
  • Avoid stating that your product "prevents" any condition.

 

One may want to consider these cosmetic phrases;

smooths the appearance of the skin

purify the skin

soothe problem skin

soothes skin

moisturizing for the skin

youthful and glowing

skin feels hydrated and appears luminous

improved appearance of skin clarity

renews the skin

helps complexion feel softer and smoother

lessening the appearance of fine lines and wrinkles

more youthful

 

Thoroughly reviewing labels and packaging, marketing copy, and websites for these types of claims will be crucial for every skincare company offering topical CBD products for sale.

Author: Rita Page, CIDESCO, Master Aesthetician