Consumable Hemp

What is the FD-99 Consumable Hemp Plans Review Questionnaire?

The plans packet is provided by the sanitarian in the region in which your business will be operating. The questionnaire provides the department with basic information about your business. Note that if you are not engaged in wholesale manufacture or distribution of Consumable Hemp, you do not need a plans questionnaire or a permit from the Louisiana Department of Health.

What are the plumbing requirements for a consumable hemp facility (toilet count, grease interceptor, et cetera)?

Per the state sanitary code, the Certified Building Official (CBO) in your area is tasked with making most of the determinations regarding sizing and location of plumbing fixtures in your business. However, LDH does have the regulatory discretion to mandate that certain types of fixtures that are deemed critical to public health be present. For instance, even with a waiver from a local CBO, a person would not be permitted to open a food-service establishment with no hand lavatories.

What is the FD-10(N) New Application for a Consumable Hemp Product Registration Form?

The product registration application form, FD-10(N), is available for download at ldh.la.gov/hemp. However, you should not simply download the form and send it to this office. The process starts with submitting label artwork for review. See the link at the top of the page to submit your artwork and supporting documents. LDH staff will review your submission along with online marketing language and materials and notify you of required changes. Once all necessary changes are made to render compliant artwork, you may submit a registration packet as directed by staff.

What are the testing requirements for consumable hemp products?

One of the requirements for registering products is that the firm provide access by means of a QR code, barcode, or website URL printed on the product label, to original, per-batch certificates of analysis from a third-party laboratory for a cannabinoid profile, pesticide residues, solvent residues, heavy-metal contaminants, and microbiological contaminants. These CoAs must be from one or more laboratories that is/are accredited to the ISO/IEC 17025 standard.

Who can submit products for registration or documents to support an application for a permit to LDH?

For legal reasons, we cannot engage in discussions with individuals who are not authorized to make the necessary commitments and modifications to existing artwork or marketing materials or physical facilities in regards to registration and permitting processes for particular firms.

What are examples of prohibited medical claims on hemp label artwork?

The statutory language in Louisiana's law specifically prohibits any kind of medical claims on products derived from industrial hemp, and this includes claims that may ostensibly not be directly linked to the hemp-derived ingredient. Nowhere on the physical packaging, the company's website or social media may the firm make any implicit or explicit claims that the products treat, cure or prevent any disease condition or otherwise have a structural or functional impact on the human body. Terms that suggest or imply that a product can cure a condition, relieve an ailment, or reduce pain or inflammation are all examples of impermissible claims.

What is a responsible party name?

For any type of business organization other than a proprietorship, the full firm name must be used as the responsible party name. If the products are being manufactured by a firm other than the registrant, this must be preceded by a qualifying statement such as "Manufactured for" or "Distributed by."

What is a statement of identity?

The statement of identity tells a consumer what your product is; in the case of consumable hemp, the term "cannabidiol" or "delta-8" or "hemp" is an insufficiently-specific descriptor. If the product is an extract, isolate, or tincture, the statement of identity should reflect that. This statement is one of two that needs to appear on the part of the label most likely to be observed by the consumer when it is sitting on a shelf (this is also known as the principal display panel).

How do I list the net quantity of contents of a hemp package in a compliant manner?

The net quantity of contents must appear on the part of the label most likely to be seen by a consumer when the product is displayed on a shelf (known as the principal display panel). Statements expressed in terms of fluid measure do not require a prefatory statement, but if one is present, it must be expressed in terms of fluid measure (e.g., "Net" or "Net contents") and never in terms of weight measure (e.g., "Net wt."). For items expressed in terms of weight measure, a prefatory statement is always required. Examples of valid statements include the following: Net wt. 8 oz (227 g), Net contents 1 fl. oz. (30 mL).

What types of products are not allowed to be registered (or sold) in Louisiana under the current regulatory regimen?

Statutory language prohibits consumable hemp products in forms intended for inhalation. In addition, due to the potential for confusion, LDH is not registering products such as suppositories, injections, infusions, implants or similar forms that are traditionally associated with pharmaceuticals.

What forms of payment does LDH accept for hemp registrations or permits?

The department is currently piloting a new online payment system specifically for Consumable Hemp registration payments. If you would prefer this option to including a cashier's check or money order with your registration packet, notify your label reviewer once your artwork has been accepted for registration. He or she will generate an invoice for your firm and direct you where to send the necessary documents once your payment is received. There is a small convenience fee charged by the third-party processor for online payments.

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