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2. KEY ELEMENTS OF COMPLIANCE

Any manufacturer interested in using a hemp raw material in their cosmetic product must take into account the below elements:

As still for 2022 THC Content: 0.2 % max in raw material (following EU Industrial hemp definition); uprising to 0.3% from 1st January 2023

Source of Cannabis extract - Ideally derived from EU industrial hemp certified seeds varieties. Other hemp-certified seed sources can be accepted. However, particular attention must be paid to the actual total THC content in the raw material

3. PRACTICAL IMPLICATIONS

Following the Kavanape judgment, it is now clear that all hemp-based raw materials are allowed, provided that the restriction on THC content is fulfilled.

To verify compliance, CoA of raw material shall be consulted:

  •  Tetrahydrocannabinol Acid (THCA)
  •  Delta-9-Tetrahydrocannabinol (Delta-9-THC)

If not listed, it is crucial to request a statement from your supplier confirming that the THC content is <0.2% in raw material unless the country of interest accepts a different level- for products intended to be placed on the market in 2022

National differences in THC content:

•Documentation of raw materials has to be precisely verified for national compliance regarding THC content, particularly when the extracts come from another country, as the allowed THC levels may differ from one EU Member State to another.  

  •  All hemp-based raw materials are allowed for use in cosmetics.
  •  All non-psychoactive cannabinoids (such as CBD & CBG), which are not listed in any national legislation on narcotics, may be used in cosmetics.
  •  Extraordinary attention must be given to THC content in the raw material. Always verify CoA for compliance!
  •  The THC content limit in industrial hemp will be raised to 0.3% in the EU as from 1st January 2023
  •  Finished products should not contain any THC to prevent drug laws from applying. 
  •  In the UK, a 1 mg threshold applies to all psychoactive cannabinoids per product container.

Conclusions