All topical hemp CBD products fall under the FDA Cosmetic Guidance and Regulation. According to the Coalition of Handcrafted Entrepreneurs there has been some significant activity in Congress related to cosmetics legislation, which also means any hemp CBD company producing topical products and aromatherapy products.
First, Senators Feinstein and Collins re-introduced a new version of their Personal Care Products Safety Act. This version includes exceptions for very small businesses (less than $500,000 in annual sales), businesses out of private residences (with sales of $1,000,000 in annual sales), and simplified facility registrations (with sales $500,000 to $2 million). Other key points include a simplified version of Good Manufacturing Practices, required serious adverse reaction reporting, mandatory recall, and new fees for businesses earning 10 million in annual sales. Read more detail about the Personal Care Safety Act on the Coalition of Handcrafted Entrepreneurs.
Second, a discussion draft was introduced by Representative Pallone of New Jersey, the Chair of the House Energy and Commerce Committee, and Representative Shimkus of Illinois to reform cosmetics. This discussion draft has a low exception level and a disproportionate burden of fees.
We highly recommend following and becoming part of the Coalition of Handcrafted Entrepreneurs to keep up to date as these possible bills progress.