The Latest Look at CBD Distribution and Fulfillment Requirements

July 21, 2020 by Amware Fulfillment

Great news:  CBD oil stays fresh for a year or longer. 

Not-so-great news:  CBD information doesn’t. 

As federal and state authorities continue to refine their regulatory stance on a wide variety of industrial hemp issues, the latest advice can lose its accuracy and efficacy in a matter of months – or less. All of which can make it tough for companies like yours to remain compliant.

CBD distribution companiesThankfully, Amware Fulfillment has got your back, because we’ve taken the time to collect some of the latest CBD news and data and used it to refresh the detailed findings that we presented in last summer’s highly informative CBD article.    

You’ll find the final result, which contains our updated side-by-side findings, in the handy table below. 

The Burning Question

What We Said Then

What’s Changed

Is it currently legal for CBD distribution companies to ship CBD oil or industrial hemp products to every state?

Yes. However any CBD product you ship must be derived from hemp rather than marijuana, and as such it must contain less than 0.3% THC. Anything more than that makes it marijuana.

This is all still true – with one very positive twist. It’s now easier for CBD distribution companies to ship CBD and industrial hemp nationally thanks to a new USDA interim rule that was issued in late 2019. 

Do all of the national U.S. parcel carriers (DHL, Fed Ex, UPS and the USPS) ship CBD and other hemp products?

 

All do, but only UPS, DHL and the U.S. Postal Service actually do. Fed Ex will not.

 

You’re in luck. All four of the national U.S. parcel carriers – including Fed Ex – will now ship CBD products. This is great news for shippers who want to choose from the widest possible range of reliable and economical parcel shipping options.

Are there any special requirements for shipping CBD oil and other hemp products?

 

The parcel carriers who accept  CBD shipments have three primary requirements: 

  • All products shipped must contain less than 0.3% THC level .
  • Shippers must ensure they’re compliant with all federal, state, and local laws that pertain to the manufacturing, distribution, sales, and transportation of hemp.
  • Shippers must maintain documentation that shows they’re compliant with the above laws for two years.

All of those requirements still apply, and there have been no significant new requirements added. That said, some states like Florida, have introduced more stringent labeling requirements, which means that orders shipped there may need a bit of additional attention in the warehouse before they can be shipped. 

It’s also important to note that UPS will not ship any CDB or other hemp products that come from a location that sells marijuana or marijuana products, so bear that in mind as you’re choosing a CBD distribution company. 

There have been stories about the seizure of packages or truckloads containing hemp in some state. Is that still an issue?

 

Although the 2018 Farm Bill permits the use of industrial hemp nationwide, it doesn’t supersede any state or local laws that pertain to the same subject.   Much like some local municipalities have laws prohibiting the sale of alcohol, some states still can (and do) choose to exercise strong restrictions against the sale or transportation of hemp within their borders.  

 

States and cities can still restrict the sale or production of hemp-based products within their borders. But per a late 2019 USDA ruling they can’t do the same with transportation. To quote that ruling: “States and Indian tribes may not prevent the movement of hemp through their states or territories . . . .” 

Even so, it is still within states’ legal rights to make life tougher on hemp shippers by requiring costly transportation licenses or permits.

It’s something to keep in mind as you choose the most optimal and economical locations for your CBD fulfillment centers – and the best shipping routes for your incoming hemp-based products.

Do CBD oils and other hemp products require special material handling, parcel handling, or fulfillment protocols and are these subject to change?

It depends on whether or not the CBD or hemp product you’re selling is edible. If so, it’s a food-grade product that needs to be stored at a food-grade warehousing facility. 

It also depends on whether your product has a sell-by or best-by date, because that will make efficient inventory control and picking procedures like first in/first out considerably more important.

Traceability is also key, especially if your CBD product is certified organic and your company strives to stay compliant with farm-to-shipping documentation requirements.

Per the latest word from the FDA, selling and shipping edible CBD products isn’t permitted. So our first piece of advice is moot, at least for now. 

Meanwhile, sound inventory rotation and lot control processes are as important as ever, both in terms of preserving CBD products’ efficacy and ensuring product traceability (which is also important in the event of a recall.)

And yes, all of these protocols are subject to change – because this is, after all, the CBD industry.

Are there any other CBD distribution, fulfillment and shipping best practices you’d recommend?

As a general rule, we recommend that companies consider adopting some of the smart practices that are often used for the shipping of high-value products – including use of generic packaging that doesn’t advertise what’s actually inside packages, using tamper-proof packaging materials, and working with providers whose employees have been carefully screened and background checked.

It also might be smart to consider housing your product with a third-party logistics provider (3PL) or CBD distribution company that can provide value-added services like kitting and packaging. That way if federal, state or local authorities require you to make a modification to your product packaging or labeling, these 3PL employees can switch your packaging out in the warehouse rather than having to ship it back to you so you can do the same.  

All of this still advice still applies – and some of it has already come in handy for some of our CBD clients, who are now being tasked with affixing different labels for packages that are being shipped to Florida. Amware is now handling the application of those labels in its facility. 

Some hemp-based products, like CDB oil, also come in breakable containers, so using best dunnage and packaging practices – like tightly packing boxes with paper pods that are made out of craft paper (which can absorb the oil on the off chance that a bottle breaks in transit) – is also highly recommended.    

Any other advice?

This landscape is constantly changing, so we encourage you to monitor the latest reports from leading hemp industry news outlets, key lobbying and industry groups such as the National Hemp Association, and  the CBD industry’s compliance experts.

 

In addition to these resources, you also might wish to bookmark the following helpful sites:

For that matter, keep Amware on your radar screen. We’re a proud CBD distribution company for a number of clients and are closely monitoring the landscape, and we’ll continue to share CBD logistics updates with you as circumstances merit.

Filed Under: Fulfillment Operations