Research reveals gaps in Brazil’s CBD labeling laws

Brazil's latest study on CBD product labeling is a pivotal moment. The research brings much-needed attention to the overlooked area of labeling practices in cannabidiol-based products, especially given the rapid expansion of this market in Brazil.

A fragmented regulatory environment fuels inconsistency

The study, conducted by a team of researchers led by Eduardo Yoshio Nakano and published in the Journal of Cannabis Research, examined the quality of labeling on CBD products available in Brazil.

The evaluation focused on two distinct regulatory categories: the N660/2022 regulation, which governs imported products, and N327/2019, which covers domestically notified products with temporary trade permits.

According to the findings, out of 105 products evaluated, only 19 received a rating of very satisfactory in terms of labeling. Nearly 40 were rated as not very satisfactory, signaling inconsistencies that may pose risks to consumers and create challenges for healthcare professionals recommending these products.

Key domains reveal alarming gaps in information

The research framework categorized labeling quality into four critical domains:

• Prescription: Information essential for selecting and recommending a product.
• Good Manufacturing Practices (GMP): Standards to ensure product quality before it reaches consumers.
• Safety of use: Clear directions and warnings for appropriate use.
• Laboratory tests (CoA): Independent analysis verifying the product’s contents and purity.

Products falling under the N327 framework generally scored higher in the prescription and safety of use categories. These products were more likely to include accessible, detailed information such as usage instructions, potential risks, and standard packaging elements required by Brazil’s health authority ANVISA.

Low response from manufacturers raises red flags

One critical observation made by the researchers was the lack of engagement from manufacturers when asked to provide missing information. Out of 105 products, only 12 companies responded to email inquiries for additional labeling details.

This minimal responsiveness suggests a systemic issue in industry transparency and regulatory accountability.

Imported products show weaker labeling standards

Statistical analysis showed that products regulated under N660 performed significantly worse than their N327 counterparts in key labeling domains. In the area of safety of use, for example, N660 products had notably lower median scores, lacking critical usage information and cautionary guidance typically found in a product insert or label.

Why this matters for Brazil’s growing CBD market

Brazil is witnessing a surge in demand for CBD-based products, with hundreds of thousands of citizens importing or purchasing them locally each year. Yet, this rapid growth is occurring amid regulatory gaps and weak enforcement mechanisms.

The lack of uniform, transparent labeling can lead to misuse, misunderstanding, and reduced confidence in the market overall.

Global parallels exist. Research from the U.S. and South Africa has uncovered widespread discrepancies between actual cannabinoid content and what's listed on product labels. Such discrepancies, if left unregulated, may expose users to unintended compounds or contaminants.

Current limitations hinder consumer confidence

Despite the existence of ANVISA’s regulations, the study concluded that current Brazilian laws lack strict requirements for public disclosure of quality assurance data, including Certificates of Analysis (CoA). Without enforceable labeling transparency, users and providers are left navigating a marketplace with minimal verified information.

Personal perspective

Having followed global developments in cannabis regulation, I believe Brazil’s situation reflects a broader challenge — rapid market growth outpacing regulatory capacity.

It’s commendable that ANVISA has attempted to bring structure through N660 and N327, but labeling should never be treated as a formality. It is the consumer’s primary guide and the prescriber’s foundation for trust.

In my view, the lack of transparency from many manufacturers shows a concerning disregard for public health. Clear, accessible, and consistent labeling is not just a regulatory box to tick — it’s a moral and commercial imperative.

As demand for CBD continues to rise in Brazil, stronger enforcement and mandatory lab testing disclosure will be crucial steps in protecting consumers and legitimizing the market.