Project Summary
Cannabidiol (CBD) products have rapidly gained popularity, with more than 46 million US adults reporting use,
primarily to treat medical ailments. The growing CBD market spans the range of products that the US Food
and Drug Administration (FDA) regulates including drugs, dietary supplements, food/beverages and cosmetics.
CBD cannot be marketed as having therapeutic benefits, be false or misleading to consumers, or convey the
products are approved or endorsed by the FDA. In addition, CBD cannot be marketed as a food additive or
dietary supplement since it is an active ingredient in an approved drug, Epidiolex. Despite this, CBD products
have been unlawfully advertised online to consumers with these claims including unsubstantiated health claims
that promote benefits including curing cancer, preventing Alzheimer’s disease and providing chronic pain relief.
This a public health concern as these claims may reduce perceptions of harm, increase perceived benefits and
influence consumers to delay medical treatment. Coupled with lacking scientific evidence on CBD’s safety and
efficacy and uncertainty about product quality, consumers are at risk for unintended consequences including
liver toxicity and adverse drug interactions with existing medications if they are misled about CBD’s risks and
benefits by illicit health claims. This project, focused on informing regulatory actions for CBD, aims to
document the types of health claims being made by brick and mortar CBD retailers, evaluate consumer
perceptions of them, and assess their impact on consumer purchase of CBD. First, we will document health
claims displayed in a large sample of CBD retailers from three states with contrasting cannabis policies. Our
team and experts in cannabis, public health regulation and health communication will content analyze the
health claims to identify potential FDA-prohibited claims. Next, we will assess consumer perceptions of the
real-world CBD health claims by conducting a web-based survey with a nationally representative sample of
3,000 adult CBD users and non-users. Participants will assess if the claims indicate a FDA-prohibited category,
share their interpreted meaning of each claim, and interest in trying CBD. Finally, in Aim 3, we will examine the
impact of CBD health claims on consumer purchase behavior using a simulated retail environment. We will
conduct a two-arm (CBD claims, no claim control) randomized controlled trial (RCT) in a simulated CBD
retailer with 400 adult CBD users and susceptible non-users to evaluate the impact of CBD health claims on
the purchase of CBD products (primary), willingness to try, perceived benefits, product safety, and outcome
expectancies. The proposed study, informed by multiple disciplines including tobacco regulatory science and
food and nutritional claims, will be the first to document health claims made by CBD retailers, assess consumer
perceptions of those claims, and test the impact of claims on consumer behavior in a real-world RCT. This
study will directly inform regulatory actions, assisting FDA in determining which claims consumers interpret in
ways prohibited by law and ensuring consumers are not misled about CBD.