The HFMA has raised concern at the moving goalposts on CBD and the practical and financial difficulties it creates for suppliers after the FSA issued new guidance around recommended limits on consumption.
The Food Standards Agency (FSA) has issued new precautionary advice on CBD, recommending healthy adults should limit their consumption of CBD from food to 10mg per day, which is about four to five drops of five per cent CBD oil.
It has prompted concern to be raised by the Health Food Manufacturers’ Association (HFMA), with Chair, Steve Mann, commenting: “Our members yet again find themselves managing moving goalposts on CBD, all of which have huge implications for manufacture and retailing of CBD products in the UK. Our role now is to assess the impact of this new FSA development on CBD and navigate our way through the practical and financial difficulties that it creates. We are here to support the membership, which is our number one priority.”
HFMA Director General, Martin Last, added: “Over many years, we have actively engaged in stakeholder meetings with utmost tact and diplomacy. Our industry has a right to be understood and consulted, and the HFMA are determined to be heard, where the interests of our members, on CBD, are concerned.”
In terms of why the change has occurred, the FSA says it published consumer advice in February 2020, recommending healthy adults not to take more than 70mg per day. This was based on limited evidence where CBD was studied as a medicine, and where dosage is determined by balancing the benefit of the drug with potential side-effects. Since then, it asked the CBD industry through the Novel Foods process to provide data specific to CBD use in food. The updated advice is based on the review of this evidence by our independent scientific committees.
In a statement, the FSA said it continues to advise CBD is not taken by people in vulnerable groups, including children, people taking medication (who have not consulted a medical professional), those who are pregnant or breastfeeding and those trying to conceive.
Emily Miles, FSA CEO, commented: “We have always advised the public to think carefully about taking edible CBD products and as with all foods, we continue to review our advice based on the evidence we gather from industry. We understand that this change to our advice will have implications for products currently on the market that contain more than 10mg of CBD per serving. We will be working closely with industry to minimise the risk, to ensure consumers are not exposed to potentially harmful levels of CBD.”
The HFMA says it is now assessing all elements of the new recommendation, and HFMA Scientific Adviser, Dr Michele Sadler, advised: “The collective, toxicological data submitted in support of CBD novel food applications is enabling a new overall assessment of the safety of the CBD category of 98 per cent purity CBDs and this has resulted in the change to the FSA’s consumer advice. It is right that we thoroughly understand and carefully assess the scientific justification for the big drop in the recommended maximum daily intake from 70mg down to 10mg.”
The HFMA also highlighted issues around potential confusion; it said that it firmly believes any reference on safe intakes must be given with absolute clarity, however, the FSA announcement carries messaging that appears confusing to consumers; they state, for example, that consumers are encouraged to monitor their daily consumption by checking the CBD content of the product and consider if they wish to change it, whilst at the same time writing that there is no adverse safety risk with consuming more than 10mg of CBD a day, based on the data the FSA has assessed to date.
Professor Paul Berryman, Technical Advisor to the HFMA, added: “It will be interesting to see if this much reduced Acceptable Daily Intake (ADI) of CBD will affect the many Novel Food applications that have been validated but not yet authorised by the Food Standards Agency. It’s clear that the HFMA has a strong part to play in helping to bring clarity to their membership about how, exactly, this FSA announcement, affects their recommendations and sales of CBD.”
The HFMA highlighted that the announcement from the FSA will have a significant impact on the CBD market as a whole, with Last adding: “We will continue engagement at all levels with members, our experts, and the FSA, to work through these issues and to seek workable implementation measures for our industry.”
Also responding was the Association for the Cannabinoid Industry (ACI), which acknowledged the updated consumer advice, adding, “we understand the importance of evidence-based recommendations to protect public health”.
The ACI statement went on: “Our scientific panel will examine the scientific evidence released today to better understand how the FSA have come to their conclusion. We will make further comments once our experts have completed their review. We urge retailers to take this as guidance, which it is. Nothing will change immediately in terms of products included on the FSA’s public list. We highlight to consumers that this guidance demonstrates the FSA still considers CBD to be safe and their advice relates to lifetime consumption of daily high doses of CBD.
“In light of this updated advice, the ACI trusts that the FSA, after considering the implications of their announcement, will find a suitable solution for companies that have invested heavily to submit Novel Foods authorisation applications for their products. We remain committed to engage with the FSA to support our members who have acted in good faith throughout the Novel Foods process so far.”