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Reasons to Submit Comments on CBD to the FDA

By March 16, 2020 No Comments
Reasons to Submit Comments on CBD to the FDA

Why should you take the time to submit comments on CBD to the FDA? It’s not just doctors, scientists and CBD manufacturers that the FDA wants input from – they want to hear from everyone. If you work in the CBD industry, use CBD or know someone that uses CBD and has had any result at all (positive or negative), the FDA wants to hear about it.

They’ve extended the deadline to submit comments on the Regulations.gov website.

A Recent Notice from the FDA Regarding Public Comments on CBD

The initial public comment period was set to end in February. Given all of the confusion surrounding CBD, the public comment period has been reopened by the FDA. There is no set deadline as they have noted that the reopening for comments would be “indefinite”.  The notice was issued on March 11, 2020.

Does your Comment Really make a Difference?

Every comment matters. The FDA, and CBD industry, understand that CBD isn’t going to work for everyone. Millions upon millions of people around the globe use CBD daily. Even if you think your comment won’t help much, it’s still a good idea to submit it anyway.

Every bit of information that the FDA can receive regarding CBD, whether it’s from a scientist, chemist, someone in the medical field or just a common person helps. The FDA wants to know what’s working and what’s not. They want to know what size doses people are using as well as the frequency of the dose.

listening ear

What Should your Comment Say?

When it comes to composing your comment, just be honest. Even if you just have an opinion regarding CBD, submit it anyway. Think about your personal use of CBD. What are you using it for? How often are you using it? What type of CBD product are you using? Did you research multiple CBD manufacturers to determine which brand and product were right for your individual needs?

It is important to note that the length of your comment doesn’t matter. You can write them a couple of pages and it’ll be viewed. The more detailed your comment is, the more it will help the FDA in moving forward with determining proper regulations for the industry.

Here are some more things to consider including in your comment:

  • Include a personal story – whether it is your actual story or a loved one’s story. Discuss how CBD has helped a specific symptom. Include what changes you’ve personally noticed. Include how the use of CBD has improved your overall quality of life or the life of a loved one.
  • If CBD has been beneficial for you, discuss how.
  • Has banning CBD in food items had a negative impact on you? Some CBD brands make different types of CBD food items and beverages, but due to the current regulations in place, they can’t be shipped interstate.
  • If CBD did not work for you, explain what products you tried, the dose and the dose frequencies. Explain your experience well.

These are just a few examples of what types of comments to submit, but really – your comment can be about anything pertaining to CBD.

Can you List Brands that You’ve Used?

Yes, you can absolutely include the CBD brand and product that you’ve been using. This helps the FDA learn what effective CBD products and brands are available on the market.  While you can’t be specific on a CBD brand’s website about relief or improvement of a specific condition or symptom, you can be specific with the FDA in this situation. CBD brands are not permitted to make claims or publish anything making a claim – which is why rules for reviews vary on CBD brand websites and many do not offer the option.

If you’ve used a Canna Trading Co. product that has provided positive support, let the FDA know that you’ve used a specific product. All of our ingredients are natural, we do test and are compliant with current FDA rules.

The FDA also needs to be made aware of products that you’ve used that did not work. If you’ve had any CBD product tested yourself, shoot them over a copy of the results.

Canna Trading Co product line

How to Submit your Comment to the FDA Regarding CBD

There are a few ways that you can submit your comment to the FDA regarding CBD. The preferred method is online at the link provided in the beginning of this article for the Regulations.gov website. There is also a link in the memo posted by the FDA to help guide you to the right area to submit a comment online. The online portal to submit comments does allow for attachments to be included as well. This function will allow you to attach photos, copies of lab reports and other information.

Search for HFA-305 to find the appropriate place to leave your comment online.

Please note that public comments made using the portal are viewable by the general public. Some of your information could be visible.

If you wish for your comment to be private or confidential, there are other options available.

You can type out your comment on your computer, print it out and mail it in. You can also handwrite your comment and mail it in.

When sending your comment in via postal service, use the following address:

Dockets Management Staff (HFA-305)

Food and Drug Administration

5630 Fishers Lane

Rm. 1061

Rockville, MD 20852

The FDA can be instructed not to include your personal information when publishing the comment. This includes your name, location and email address. If you’ve included your telephone number, you can also instruct the FDA to keep that information confidential as well.

Closing Thoughts

Since many of you may not know that you can submit comments on CBD to the FDA, we thought we’d help you with information to do so. It is important that they receive as much input as possible. The FDA is struggling to determine proper regulations indicating that they want to create a “policy based on science”. There is a lot of science available, but the FDA still needs more answers. These comments will at least help them start to put the proper regulatory structure in place.

If you need any additional help submitting your comment, please don’t hesitate to reach out to us. We’re happy to help you!

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