The 2018 Farm Bill removed hemp (≤0.3% Δ-9 THC by dry weight) from the Controlled Substances Act but preserved the U.S. Food and Drug Administration’s authority over cannabis-derived products that fall within regulated categories such as foods, dietary supplements, drugs, cosmetics, and devices. In practice, hemp-derived vape oils must meet applicable FDA labeling and safety frameworks, and manufacturers are prohibited from making unsubstantiated health claims.

At the federal level, the FDA has highlighted safety uncertainties surrounding cannabinoids, including CBD, and has requested that Congress create a risk-based regulatory pathway with clearer labeling requirements and contamination controls. This indicates that robust labeling will remain central to consumer protection going forward.

States have stepped in to fill gaps with their own rules for hemp-derived products. These typically require product identity, net quantity, ingredient listings, cannabinoid content per serving and per container, batch numbers, and manufacturing dates. Regulations often mandate tamper-evident packaging, clear usage directions, age restrictions, and Certificates of Analysis (COAs) accessible via QR code, issued by accredited labs. New York, for example, requires tamper-evident packaging and serving details, while Colorado and Florida have enforced specific testing and COA requirements, supported by active regulatory oversight.

Why Labeling Matters

Labeling standards have become a priority due to safety incidents and misleading marketing practices, particularly with intoxicating hemp derivatives such as delta-8 THC. Reports of adverse events and the use of child-appealing “copycat” packaging have led to heightened scrutiny. Accurate, transparent labeling reduces risks of accidental ingestion, supports informed decision-making, and improves traceability in case of safety issues.

What Labels Must Include—and Avoid

• Accurate composition and potency. Labels must declare cannabinoids present, with per-serving and total amounts, and link to a batch-specific COA.
• Product identity and ingredients. Labels must state the product name, list ingredients (including carrier oils and flavorings), display net contents, and identify the manufacturer or distributor with contact information and lot/batch numbers.
• Directions and warnings. Clear usage instructions, age restrictions where required, impairment cautions, and tamper-evident packaging are mandatory in many states.
• No unsubstantiated health claims. Labels cannot claim to prevent, treat, or cure diseases without FDA approval. Such claims risk FDA and FTC enforcement, including fines and warning letters.

Impact Across the Supply Chain

Manufacturers must approach labels as controlled quality records. Each SKU must be tied to a COA and reviewed against federal and state requirements. Pre-launch reviews, version control, and change management systems help prevent costly missteps. White-label producers also need standardized workflows for QR code/COA integration and records management to prepare for inspections or recalls.

Retailers share liability when products are mislabeled. They are expected to vet suppliers, conduct shelf audits, and verify QR codes and COAs. Staff training is essential to avoid making health claims at the point of sale or in online listings. Enforcement activity in states like Florida demonstrates that regulators will remove non-compliant inventory.

Consumers ultimately benefit from reliable labeling. Accurate cannabinoid disclosures, ingredient lists, and accessible testing results help consumers make informed decisions and build trust in legitimate brands. Conversely, misleading labels can erode consumer confidence in the market.

Compliance Best Practices for White-Label Hemp Vape Oil

Manufacturers and retailers can adopt several practical measures:

1. Maintain a regularly updated 50-state labeling requirements matrix.
2. Implement a claims review checklist aligned with FDA and FTC standards.
3. Tie each product label to a live COA URL or QR code.
4. Provide bilingual warnings where applicable.
5. Approve and retain “golden sample” label proofs for each batch.
6. Establish recall procedures and distribution logs to ensure traceability.

Labeling compliance is more than a regulatory obligation—it is a critical tool for consumer safety, brand integrity, and long-term industry growth. White-label hemp vape oil manufacturers and their retail partners that prioritize accurate, transparent labeling will be best positioned to build lasting trust with consumers in a rapidly evolving market.