Labelling a CBD product: the mandatory wording in France

A cream, a raw flower, an e-liquid and an infusion do not fall under the same texts. That is the first thing to establish when looking at a label, because it determines what the manufacturer must write on it and what they have no right to write on it.

This logic explains a good part of the confusion on the market: wording that is perfectly regular on a cosmetic may be unlawful on a foodstuff, and vice versa.

This is the best-defined regime. Article 19 of regulation (EC) no. 1223/2009 requires seven items on the container and the packaging.

The name or company name and the address of the responsible person, with the country of origin for imported products. The nominal content at the time of packaging, by weight or by volume. The date of minimum durability, replaced by the period-after-opening symbol where durability exceeds thirty months. The particular precautions for use. The manufacturing batch number. The function of the product, unless it is clear from its presentation. Finally, the list of ingredients, preceded by the word « ingredients », that is to say the INCI list.

Two of these items deserve particular attention when buying: the batch number, without which no traceability is possible, and the INCI list, which makes it possible to check the real place of cannabidiol in the formula. We develop these checks in our buying guide for CBD cosmetics.

Regulation (EU) no. 655/2013 lays down six common criteria applicable to cosmetic claims. Three are particularly operative: truthfulness, which prohibits attributing to the finished product the property of an ingredient without evidence; evidential support, which requires verifiable justification relating to the actual product; and fairness, under which the alleged effects may not go beyond the effects demonstrated.

A methodological point: this regulation contains no sentence specifically prohibiting therapeutic claims. That prohibition follows from the boundary between cosmetic and medicine, a product claiming a therapeutic effect falling into medicinal product law. The Assurance Maladie makes the same point on its side: products containing CBD may not, on pain of criminal sanctions, make therapeutic claims, unless they are authorised as a medicine.

This is the major development of the year. On 20 May 2026 the Ministry of Agriculture published a statement entitled « Foodstuffs containing cannabidiol (CBD): illegal products that must be withdrawn from the market ».

The basis is regulation (EU) 2015/2283 on novel foods: a foodstuff containing CBD among its ingredients is not authorised under it, the safety of cannabidiol not having been demonstrated. The Ministry states that it is extending controls to all foodstuffs containing or highlighting CBD, including food supplements and online sales, and invites consumers not to buy these products.

Only two categories remain authorised: hemp seeds and their derivatives, and leaves intended for the preparation of an aqueous infusion, subject to the THC limits and provided that no cannabinoid extract has been added.

On the scientific substance, on 9 February 2026 EFSA established a provisional safe intake level of 0.0275 mg per kilogram of body weight per day, that is around 2 mg per day for a 70 kg adult, while indicating that safety cannot be established for those under 25, pregnant or breastfeeding women and people undergoing treatment. We follow this file in our article on Novel Food regulation.

For raw flower, the reference text remains the decree of 30 December 2021, which authorises only the varieties listed in the official catalogues and below 0.30 % of delta-9-THC. Its provision prohibiting the sale of flowers and leaves to consumers was annulled by the Conseil d'État on 29 December 2022: the consolidated version carries the note « Annulled » on that point.

For e-liquids, the detailed regime governing the presentation of the product appears in the provisions of the Public Health Code specific to vaping products containing nicotine. Most CBD e-liquids do not contain any, and we prefer not to publish a list of mandatory items that would be extrapolated. What is certain falls under the general regime: a ban on advertising and a ban on sales to minors under eighteen.

Alongside the label, the document that really commits a seller remains the certificate of analysis, whose reading we set out in our dedicated article on the certificate of analysis, and whose other buying criteria appear in our quality guide.

Which items are mandatory on a CBD cosmetic?

Seven, set by article 19 of regulation (EC) no. 1223/2009: the responsible person and their address, the nominal content, the date of minimum durability or the period-after-opening symbol, the precautions for use, the batch number, the function of the product and the list of ingredients in INCI nomenclature. Their absence is a signal of non-compliance.

Can a label state that the product relieves pain?

No. Such wording constitutes a therapeutic claim, which would tip the product into medicinal product law and exposes the seller to criminal sanctions according to the Assurance Maladie. Regulation (EU) no. 655/2013 further requires that the alleged effects do not exceed the effects demonstrated, on the actual product and with verifiable evidence.

Can CBD oils to be swallowed still be sold in France?

No. The Ministry of Agriculture confirmed in a statement of 20 May 2026 that foodstuffs containing CBD are illegal under regulation (EU) 2015/2283 and must be withdrawn from the market. Only hemp seeds and their derivatives, along with leaves intended for an aqueous infusion, remain authorised, with no cannabinoid extract added.