cbd reg nov. 20

Manufacturers of CBD pet products report that they are focused on strict standards in an effort to produce reputable and reliable products.

The cannabidiol (CBD) pet product category is not just surging in popularity, it’s forging a whole new territory. In 2019, the U.S. pet CBD market grew to more than 10 times its 2018 size, according to a report by Brightfield Group, a consumer insights and market intelligence firm based in Chicago. By 2025, Brightfield officials estimate that the market will grow to $1.7 billion. This uptick will be primarily driven by wide consumer appeal and the high probability of more mass pet retail chains, supercenters and product manufacturers entering the industry in 2020, according to the report. While good for business, the rapid growth has created a murky terrain teeming with inconsistent standards, misunderstood terminology and what seems to be a lack of consumer education.

“It can certainly be a tricky landscape to navigate,” said Lee W. Mayberry, chief quality and regulatory affairs officer at Minneapolis-based Kradle.

While the brand is new—it was launched in July—Mayberry is quite familiar with the supplement sector.

“I’ve been on multiple industry committees focused on critical issues from cannabis to government relations to quality,” said Mayberry, who has 30-plus years of experience in the food/beverage/dietary supplement sector. “Prior to joining the Kradle team, I developed the hemp benchmark standards for the nation’s premier natural grocer, so I’ve been tracking the cannabis regulatory landscape for several years. This combination of contacts and firsthand experience puts Kradle in a unique position to monitor the state-level developments and continually update a state-by-state regulatory/risk matrix.”

Mayberry said he also relies on insights from industry associations, giving the examples of the National Animal Supplement Council (NASC), the American Herbal Products Association (AHPA), the Council for Responsible Nutrition (CRN), the National Products Association (NPA) and the United Natural Products Alliance (UNPA).

In an interview with PPN earlier this year, Steve Smith, co-founder and president of Pet Releaf, a CBD manufacturer in Littleton, Colo., said, “As a pioneer in the CBD pet market, we knew that regulation would be close to nonexistent for quite some time, so it was important to us that we came to market with a high-quality product that would meet the high standards we expected to see as the regulatory environment evolved.”

Pet Releaf officials are not only continuing to meet these high standards, they are also helping with the regulatory efforts to take the category to the next level.

“At Pet Releaf, we strongly support reasonable regulations on hemp products,” Smith recently told PPN. “That is why Pet Releaf dedicates significant funds and time to support the U.S. Hemp Roundtable and the Hemp Industries Association.”

The U.S. Hemp Roundtable is a coalition of companies and organizations committed to safe hemp and CBD products through education and action. Smith is not only a member; he’s an active participant representing the pet sector.

“Being the only pet CBD company on the board of directors and executive committee of the U.S. Hemp Roundtable brings great responsibility,” Smith said. “As ‘the pet guy’ at the [U.S. Hemp Roundtable], I also volunteered to help out on the [U.S. Food & Drug Administration] FDA committee to make sure our part of the CBD world had a voice. Our board and our committee have invested significant sums on lobbyists to petition the FDA and Congress to codify reasonable rules for CBD products. We have also traveled to Washington several times in person to visit dozens of senators and representatives and lay out our wishes.”

Currently, U.S. Congress has a pending bill that would specifically categorize hemp derivatives, including CBD products, as supplements and be subject to the Dietary Supplement Health and Education Act (DSHEA) regulations and other supplement laws, Smith said.

“On a state level, we are still working on CBD’s clarification out of the gray area in many states,” Smith added. “California, for example, still has not formalized CBD’s legality. The U.S. Hemp Roundtable bill, which [California’s] governor supported, did not make it out of the legislature due to the COVID-19 outbreak in the spring.”

In the meantime, Pet Releaf is navigating the category by upholding itself to the highest of standards. For example, Pet Releaf creates all its packaging, marketing and editorial content to comply with federal law, including the DSHEA guidelines for human supplements, according to Smith.

“We then make sure we are incorporating and/or respecting hemp-specific rules based on the 2018 Farm Bill, which addressed hemp derivatives,” Smith said.

Pet Releaf also adds or tweaks its packaging to comply with state-specific laws, such as mandatory QR codes in many states that take a consumer directly to the Pet Releaf testing page, Smith added.

When manufacturing CBD products, Min Lee, president of brand development and co-founder of Honest Paws in League City, Texas, said that the company focuses on meeting the strictest standards.

“Our approach has always been to analyze the laws by state and try to align our products to the laws of the strictest state,” Lee said. “Although not the most efficient way to develop products, it ensures that we remain as compliant as possible. Because of the nature of our products and where we sell them, we must remain vigilant to laws and regulations set forth by the FDA, [Drug Enforcement Administration] DEA, [Federal Trade Commission] FTC, states and, by choice, the NASC. Needless to say, we remain anxiously waiting for guidelines to be presented by the federal government.”

Despite the tricky—and changing—landscape, it does present an upside.

“One significant upside is that regulations tend to eliminate those who are selling inferior or misrepresenting their products,” said Dean Robbins, co-owner of Bark Appeal, a manufacturer in San Clemente, Calif. “It ensures consumers have a quality product.”

Mayberry agreed.

“I believe that clear and reasonable regulations will ultimately favor those companies that have put in the hard work to create safe and effective products,” Mayberry said. “Consumers will ultimately benefit, too, since the overall quality of products and the claims being made will improve.”

Defining Terms

Mention “CBD” and a slew of related words may come to mind, such as hemp, cannabis and marijuana. Consumers may be well aware of such terminology, but industry insiders are finding that many people don’t have a grasp on the important distinctions of each term.

Lee broke it down:

  • CBD is the nonpsychoactive compound that is extracted from the hemp plant, providing the many benefits we see today.
  • Hemp is the term used to identify cannabis plants that contain 0.3 percent tetrahydrocannabinol (THC) or less. THC is the psychoactive ingredient that provides the “high.”
  • If the plant has more than 0.3 percent THC, then it is commonly referred to as marijuana.
  • Cannabis is the scientific term (genus) that all these plants are identified as, regardless of THC levels.

“Now that you know what the correct definition is, you can clearly see how loosely and inaccurately the terms have been used by both brands and the general public,” Lee said. “There are many unfortunate results from this confusion.”

For example, hempseed oil is often advertised as providing the same benefits as CBD, but it doesn’t, Lee said.

“I always tell people to read the ingredients,” Lee added. “Almost every product you see on Amazon uses hempseed oil. It does not provide any of the benefits that CBD does. It’s really unfortunate that Amazon allows consumers to get swindled like this.”

There’s another level of terminology that consumers should be aware of, too, such as full spectrum, broad spectrum and isolates, according to insiders.

“Most companies refer to a hemp extract or product that contains some THC, along with CBD and other cannabinoids, as full spectrum,” Mayberry said. “Extracts or products that contain no detectable THC, along with CBD and other cannabinoids, are typically called broad spectrum.”

Smith added, “Full spectrum means what it says—the entire spectrum of the plant is in the final product. If a company tries to remove any cannabinoids, such as THC, it is illegal to call it a full-spectrum product. A supposed ‘THC free’ product cannot be full spectrum. A rainbow is not a rainbow if blue has been removed.”

Isolates contain only pure CBD. No other cannabinoids, terpenes or flavonoids are present. Insiders tend to agree that CBD isolates are less effective than full- or broad-spectrum CBD.

While the definitions may be set, there are differing opinions as to whether full- or broad-spectrum products are best for pets.

“Based on the research and the concerns in the veterinary community regarding canine ingestion of THC at any level, Kradle products have been formulated with broad-spectrum hemp extract to deliver the benefits of CBD without any detectable THC,” Mayberry said.

Pet Releaf products are full spectrum.

“A very important point here to note is that THC free or isolates do not carry anywhere near the efficacy of a full-spectrum product,” Smith said. “That is the science and, no, THC is not dangerous for animals unless it is at high levels in the product. Having small amounts of THC, which a true hemp-based CBD plant provides, will not get your pets ‘high.’”

Equally important to know is how CBD products can be labeled.

“Retailers should always refer to CBD as being a supplement,” Smith said. “Pet Releaf’s position, which is also the strong position of the FDA, is that CBD has no place in food or beverages. It is far too difficult to regulate the dosage. Having CBD in a chew form can still be a supplement as many pharmaceuticals for dogs are in a chew form. However, putting CBD in kibble is illegal—and we feel should remain so without many years of research.”

Lee agreed about defining CBD as supplements.

“To me, food products are defined as something provided to the animal strictly for nutritional and caloric benefit. As a supplement, the CBD should only be delivered through methods and portions that are just large enough to successfully dose the animal without the goal of providing nutrition or calories,” he said. “Honest Paws products are defined as supplements, which is why you won’t find nutrient tables on our labels. This is also why we adhere to guidelines set forth by the NASC.”

The concern with adding CBD to foods and treats, according to Mayberry, is that it becomes more difficult to determine the amount a pet may consume from multiple sources, the total dietary intake.

“If hemp-based CBD is only found in supplements, it is much simpler to calculate and control the daily dose,” Mayberry said.

On the Shelf

While it’s up to manufacturers to produce quality products, pet retailers are tasked with selecting which ones to put on their shelves. Due diligence is key, according to insiders.

“I believe it is absolutely critical for retailers to understand what CBD is and the difference between what is being offered out there,” Lee said. “Once they have a basic understanding of the different types of CBD, it becomes fairly easy to vet the different brands out there. We actually developed Honest Paws Academy solely for the purpose of educating retailers, teaching them everything they need to know about CBD and when to offer it to their customers.”

It’s also important that pet retailers have a relationship with the CBD manufacturer, according to Robbins.

“You will want to be educated and confident in the products you are offering your clients,” Robbins said.

Pet Releaf created “5 Questions to Ask Any Pet CBD Brand,” which is available on its website.

  1. Where is the hemp grown?
  2. If they claim organic, can they prove it with USDA [U.S. Department of Agriculture] certification?
  3. What extraction method is being used, and do they have third-party testing to prove there are no residual chemicals?
  4. Are they using CBD isolate?
  5. How much CBD is in the product, and do they have consistent third-party test results to prove this amount?

Smith strongly recommended that pet retailers do not carry a lot of brands.

“Several high-level hemp industry analysts have data proving that stores with a multitude of brands far undersell the stores that carry three brands at most,” Smith said. “Ask any of the big human CBD companies and they will tell you that the FDM [food, drug and mass] stores have been a spectacular failure for them because they are carrying five to 10 brands and the consumers just shrug and give up.”

Michele Hanson Pahan, owner of Riley’s Natural Pet Supply in Littleton, Colo., always asks the manufacturer if the plant is human-grade organic, and if the product is third-party tested and certified. Hanson Pahan also shops local.

“I choose Colorado [companies] that allow me to walk their hemp fields, and proudly present their manufacturing practices,” she said. “Our store showcases fewer companies that comprehensively cover different customer needs and methods of giving to a pet.”

This includes various oil carriers, strengths, product sizes and price points, Hanson Pahan said.

“I find it better to be educated in the benefits of a few incredible companies than [to] overwhelm the customers with too many options,” she added.

About 50 percent of Hanson Pahan’s customers are familiar with CBD manufacturers and associated products, so when they come in, they are ready to purchase.

“All others are given a tutorial of selection, written educational material and a business card to contact us as they try the products,” Hanson Pahan said.

Retailers should also look beyond the product itself and take time to understand the pet’s need, Mayberry noted.

“I think it is important to understand and acknowledge that just like humans, each animal is unique and possesses a unique body and metabolism that impacts things like response time and dosage,” Mayberry said. “What works for one animal may work even better or not as well for another.”

For more of PPN’s coverage on CBD, read: