Have you considered self-certifying your CBD products as Generally Recognized As Safe (GRAS) so you are “legal” at the federal and state level? It would get around the ban on CBD in California and other states, for example.
“The Center for Science in the Public Interest (CSPI) and other consumer groups have proposed to members of Congress sweeping reforms to how dietary supplements are regulated in the United States.
The comprehensive proposals were incorporated in a March 10 letter to members of Congress, which urged them to reject a bill that would legalize CBD in dietary supplements.
CSPI, Consumer Federation of America, Consumer Reports and National Consumers League proposed manufacturers list their supplements with FDA, report all adverse events linked to their products and submit a new dietary ingredient notification (NDIN) to FDA for every novel ingredient.
The latter recommendation is intended to eliminate reliance on an exemption to the notification requirement for NDIs in the food supply in a non-chemically altered form—or what the letter described as the “GRAS [generally recognized as safe] loophole to secretly self-affirm that new ingredients and uses are safe without FDA review.””