NSF International (Ann Arbor, MI) has announced it will provide independent testing, verification, auditing, and certification services to consumer products containing hemp and hemp-derived cannabidiol (CBD), including food, dietary supplements, and personal care products. The decision to offer these services to hemp-based products followed the enactment of the 2018 Farm Bill, which amended the Controlled Substances Act to differentiate between hemp and marijuana.
NSF’s testing services for hemp and hemp-derived CBD products will test for contaminants such as pesticides and heavy metals; microbes such as E. coli and Salmonella; undeclared ingredients; and quantities of ingredients that conflict with labeled amounts. In addition, Quality Assurance International Inc. (QAI), an NSF subsidiary and a USDA-accredited organic certifier, began offering organic certification to hemp and hemp-derived CBD products last month.
With its new hemp and CBD services, NSF has the added responsibility of tetrahydrocannabinol (THC) testing. According to the 2018 Farm Bill, hemp products may not contain more than 0.3% THC by dry weight.
“For CBD products, verification of THC content is extremely important. Unfortunately, most manufacturers and suppliers currently do not have access to validated test methods to verify the THC content of hemp extracts—so consumers have no way to know what’s really inside most hemp and CBD products,” said Katie Fillinger, business unit manager, dietary supplements, NSF International, to Nutritional Outlook.
Currently, there are few other options for hemp-derived CBD testing and verification. “Testing and verification of hemp-derived CBD is complex, and few labs are able to conduct these tests correctly. The NSF International laboratory that performs this testing is ISO/IEC 17025-accredited and has a U.S. Drug Enforcement Administration registration that permits possession of THC reference standards on site,” explained Fillinger.
“[Hemp and hemp-derived CBD products] can be manufactured and marketed by small start-ups with little expertise in quality management, Good Manufacturing Practices (GMPs), and labeling requirements, creating potential risk and confusion for consumers,” stated Lori Bestervelt, PhD, executive vice president and chief technical officer at NSF International, in a press release. “Even established brands may have limited experience sourcing, authenticating, producing, and packaging products containing hemp or hemp-derived CBD.”
To test hemp and hemp-derived CBD products, NSF International uses a modified version of AOAC Official Method 2018.11 (Quantitation of Cannabinoids in Cannabis Dried Plant Materials, Concentrates, and Oils Liquid Chromatography–Diode Array Detection Technique with Optional Mass Spectrometric Detection, First Action 2018.11).
For dietary supplements, NSF certification demonstrates that a product meets the requirements of NSF/ANSI 173 (the American National Standard for Dietary Supplements), or NSF 229. This means that products are produced in a facility according to GMPs, have been independently tested for harmful levels of contaminants such as lead and arsenic, and have been tested to ensure the ingredients listed on the package are actually in the product.
Overall, NSF and QAI’s services for the hemp industry will include:
• Raw ingredient verification
• Raw material and single-ingredient finished-goods testing of hemp products to quantify CBD and confirm permissible levels of THC
• GMP audits
• USDA organic certification
• Gap and consulting audits
• Label compliance consulting
• Training and education
• NSF’s non-GMO certification
• NSF’s gluten-free certification
One of the current challenges for NSF is determining a safe upper limit for CBD. Until the limit is determined, products bearing CBD-content claims are not eligible for NSF certification. “Our toxicology team is currently working to identify an upper safety limit for CBD in dietary supplements,” said David Trosin, general manager of NSF’s dietary supplements program, in a press release. “Once that permissible level is identified, we will begin certifying supplements that contain hemp and hemp-derived CBD.”
Fillinger added: “For dietary supplements, NSF International plans to use a robust, scientific-evidence-based approach to determine an acceptable upper safety limit for hemp-derived CBD in products that may potentially meet the Federal Food, Drug, and Cosmetic Act’s definition of ‘dietary supplement.’”
NSF says that as early as October 2019, once NSF has published certain program policy revisions, products containing hemp and hemp-derived CBD may be eligible for NSF/ANSI 173 or NSF 229 certification, depending on the circumstances. Specifically:
• Products which make no CBD content claims will be eligible for evaluation under the requirements NSF/ANSI 173 or NSF 229.
• Products which make CBD content claims and contain full- and broad-spectrum hemp will be eligible for evaluation under the requirements of NSF/ANSI 173 or NSF 229. (This is only after NSF International has established an acceptable upper safety limit for hemp-derived CBD in dietary supplements.)
• Products which contain CBD isolate or refined hemp extract, whether or not CBD content claims are made, will not be eligible for evaluation under the requirements of NSF/ANSI 173 or NSF 229.