Cannabis in Cosmetics and Supplements – Regulatory Compliance in China

While the legalization of therapeutic use of Cannabis products across the world continues, there has been a rapid increase in the interest in cannabis sativa in cosmetics as well as in dietary supplements. The purported medical benefits and healing properties of cannabis is driving the trend across the industries. This craze is expected to last for years to come while the evidence of cannabis’ functional benefits as well as safety is being documented.

China has been using cannabis in traditional Chinese medicine for thousands of years. Cannabis seed oil is one of the 50 “fundamental” herbs in traditional Chinese medicine. In cosmetics products, hemp seed oil is widely used and legally approved in Chinese registered cosmetics products.

The problem is that there is a lot of confusion in regard to whether “cannabis” is approved for cosmetics and general food in China. The reason being that marijuana and hemp are two varieties of the same plant family, cannabis sativa, and are therefore often lumped together as “cannabis”.

Below we have illustrated the differences between marijuana, hemp and hemp seed oil.

Marijuana

Hemp Hemp seed oil (cannabis sativa seed oil)
Can be used to produce THC; the compound that makes a person feel “high.” Can be used to produce THC. 0% THC, trace amounts of CBD
Produces CBD at 10%+ levels Produces CBD at 20%+ Used in general food food such as hempseed milk, granola, and more
Medicinal and therapeutic applications;  chronic pain, mental health, and illnesses Stalks of the hemp plant can produce clothing, rope, paper, fuel, home insulation… (the list goes on and on) Cold-pressed for oil production that can be used in general food and cosmetics products.

Cannabis in Cosmetics

Cosmetics products with cannabis sativa (hemp seed oil) are already selling well on the Chinese market. The use of cannabis in cosmetics is however limited to 3 approved ingredients;

1. CANNABIS SATIVA FRUIT 大麻(CANNABIS SATIVA)仁果,

2. CANNABIS SATIVA SEED OIL 大麻(CANNABIS SATIVA)籽油

3. CANNABIS SATIVA LEAF EXTRACT 大麻(CANNABIS SATIVA)叶提取物

Function claims for cosmetics products using hemp seed oil are mostly ”anti-inflammatory”, ”anti-acne” and ”moisturization”. Hemp seed oil can be used both as an ingredient in a products and by its own. We advise to be cautious in regard to functional claims especially as the Chinese authorities are very strict in regard to misleading or exaggerated claims.

Some domestic cosmetics products have completed the NMPA filing process with the product name of ‘cannabis oil’ on their packaging.

The cosmetic product has been approved by Fengxian NMPA with the English name “Cannabis Oil Hydra-Calming Mask”

Cannabis in Supplements and General Food

CBD cannot be used as an ingredient in traditional Chinese medicine and all products containing CBD must apply for drug approval before selling in China.

Hemp seed oil – Cannabis sativa seed oil – is approved for use in both health food and general food – both as an ingredient and as an oil for cooking (see picture below).

Hemp Seed Oil

Cannabis in Drugs

THC (tetrahydrocannabinol) is approved for use by the NMPA. It’s main uses are typically as a painkiller and for anesthesia. THC can be used as a ‘1st class prescribed psychotropic narcotic’ that is strictly limited in China. In order to get access to a drug containing THC, you must receive a ‘pink-coloured’ handwritten prescription paper from a specialist doctor.

The characters to represent THC are: 四氢大麻酚.

CBD is not an approved drug by the NMPA.

For more information on the cannabis regulatory framework in China, please contact us on info@knudsenchina.com

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