Who’s Buying Pet CBD and Why?
Brightfield data for all CBD consumers reveals that 28% of those who have pets report giving their pets CBD. Brightfield Senior Insights Manager (and former Cannabis Business Times managing editor) Brian MacIver shares that pet CBD buyers skew toward urban and suburban women who use CBD themselves. Pet CBD purchasers also tend to be mid- to high-income earners, with 60% of respondents to a Brightfield survey earning more than $50,000 per year. While pet CBD buyers span all generations, millennials make up more than half of pet CBD buyers.
When it comes to pets enjoying CBD benefits, dog lovers dominate the pet CBD market. Based on Brightfield data, more than three out of every four pet CBD purchases are for dogs. While purchases for cats cruise into second place, at roughly 20% of purchases, consumers with less conventional pets are turning to pet CBD, too: Rabbits, fish, horses, rodents and reptiles were all represented.
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MacIver shares that pet owners who use CBD for their companions most often report using it to relieve general or situational stress or anxiety. Respondents to the 2021 Pet CBD Brightfield survey also noted that they use pet CBD, similar to a supplement, to improve their pet’s wellbeing. “In terms of specific ailments, nearly one in four pet CBD users treat their pet’s arthritis with these products,” MacIver adds. And while veterinarian opinions typically matter to pet CBD buyers, many can’t freely discuss cannabinoid treatments with their family vet.
Where Does Veterinary Medicine and Cannabinoid Research Stand?
Brightfield’s 2021 Pet CBD Survey found that 70% of surveyed pet owners reported talking with their pets’ veterinarians about pet CBD. The vast majority said they were met with positive responses; however, many veterinarians typically hesitate to initiate conversations about CBD.
Cornell University College of Veterinary Medicine Professor Joseph J. Wakshlag, DVM, Ph.D., explains that many veterinarians don’t feel they know enough or have enough clinical data about cannabinoids to recommend them. For many others, the American Veterinary Medical Association (AVMA) warns against prescribing cannabis- or hemp-derived products for animals.
Veterinarians in most states currently risk violating federal, state, or veterinary medical board regulations regarding cannabinoids in general and pet use specifically. Michigan was an early leader in expressly allowing veterinarians to consult with patients on cannabis and CBD use. Recent legislative actions in California and Utah are poised to give veterinarians greater clarity and leeway in discussing and recommending hemp- and cannabis-based products with pet owners. But these examples are exceptions to the rule.
Wakshlag, who pioneered early research in CBD treatments for dogs and co-authored the first peer-reviewed published paper on CBD for canine osteoarthritis in 2018, says the looming questions for most veterinarians and pet owners are whether pet CBD is safe and effective.
Now in his fifth year of research with cannabinoids and animals, Wakshlag also serves as chief medical officer for Portland, Maine-based pet CBD and CBDA (cannabidiolic acid) company ElleVet Sciences. In that role, he helps organize and coordinate peer-reviewed clinical trials with veterinary and academic institutions for the company’s hemp-derived products.
As clinical research expands, Wakshlag believes more vets will travel a path similar to his own—from skeptic to advocate of clinically proven, diagnosis-specific pet cannabinoid products.
Wakshlag shares that there’s still a tremendous amount to learn about the endocannabinoid systems and receptor concentration in different animal species and how to optimize cannabinoid absorption and benefits. For example, Wakshlag says horses have CBD absorption issues, yet they absorb CBDA quite well.
When it comes to cannabinoids for your beloved pooch, Wakshlag says, “I think the research is bearing out that it’s definitely good for three different conditions now: One is arthritis. The second is atopic dermatitis. The third is seizures.” And while canine cannabinoid coverage often mentions anti-inflammatory effects in dogs, his research hasn’t indicated that for CBD or CBDA.
Another compelling concern for pet owners and veterinarians is the lack of regulation and quality control and assurance in pet CBD products. In a 2020 analysis of 29 over-the-counter veterinary hemp supplements, Wakshlag and a team found nearly 40% of the products were labeled inappropriately, with “highly variable concentrations of CBD or total cannabinoids.” Nearly one in four products couldn’t provide third-party certificates of analysis (COAs), and four tested positive for heavy metal contamination.
Even with reputable product lines, variations between brands complicate dosing. CBD:THC ratios also matter, Wakshlag says. For example, a hemp-derived pet CBD product might test below 0.3% THC, but the product’s CBD:THC ratio might be 6:1. “What you’re looking for is a product that is 20:1 ratio or 30:1 ratio,” he explains. In addition, research may discover that appropriate dosing for conditions like anxiety could be highly dependent on the pet.
Wakshlag notes that there’s a lot left to learn, and that there are many other cannabinoids beyond CBD that may prove significant for pets and other animals for a wide range of conditions. “One day there will be the perfect mix,” he says. “We’re just not there yet.”
But Is Pet CBD Legal?
The answer to that question is yes and no—with several qualifiers attached to either answer. Just because pet CBD isn’t intended for human consumption, it isn’t free from the complications surrounding the legality of some hemp-derived products.
“Whether you’re dealing with a product for human consumption or animal consumption, it’s essentially the same. Even though requirements may vary, the principle behind it is the same.” - Attorney Nathalie Bougenies of Miller Nash LLP.
Attorney Nathalie Bougenies of Miller Nash LLP focuses her practice on hemp, cannabinoids, and health and wellness. In helping clients maneuver hemp’s complex regulatory landscape, Bougenies encourages companies considering pet CBD to understand current risks and position themselves for the future.
“When hemp was legalized, there was also this movement that thought because hemp is legal, it means that all of these hemp products are now automatically lawful. That’s not exactly the case,” she says.
Bougenies notes that the 2018 Farm Bill’s preservation of FDA regulatory authority over hemp-derived products applies to products intended for animals—not just humans. “It will take more scientific research, backed by solid data, to get these products tested, approved, and deemed safe for pet consumption in the eyes of the FDA,” she adds.
But legality and enforcement are two different matters, Bougenies says. As with CBD products marketed for human consumption, FDA enforcement actions regarding pet CBD have targeted companies making medical claims. FDA warning letters regarding pet-intended CBD claims date back to 2015.
RELATED: FDA Issues Warning Letters to Companies Claiming Their CBD Products Can Treat COVID-19
Of course, as with other cannabis- and hemp-derived products, states often choose a different approach. Bougenies calls out three categories in the state-driven patchwork of regulations around hemp-infused products for animal consumption: Some states allow or expressly authorize and regulate pet CBD products. Some states expressly prohibit the manufacture, sale, and distribution of pet CBD products within their borders. A third group falls somewhere in between, with either no clear opinion or regulation of pet CBD products, but no enforcement actions either.
The balancing act between federal and state pet CBD laws gets more complicated when businesses sell products online without limiting sales to their state. “The moment you start doing that online, it involves interstate commerce—and interstate commerce means federal law,” Bougenies says. “So that’s where you have this combination of state law with the FDA that inevitably collides and comes into play.”
Ultimately, Bougenies says, “There’s no elegant or perfect solution here.” She advises producers, manufacturers, and marketers of pet CBD to ensure they comply with all state laws where they’re selling and marketing pet CBD, and avoid making any medical claims about product efficacy. But don’t stop there.
Bougenies emphasizes that businesses get ready for the day when FDA approval finally comes. When it does, as with products for human consumption, pet CBD products will need to meet all the new obligations—on top of the basic requirements that already exist for products intended for pet use.
“You have to ensure that you’re in compliance with federal law, good manufacturing practices, and the like, because that’s just the floor for the FDA. That’s where it’s going to start when it adopts regulations for CBD products,” she says. Companies that position themselves now by meeting federal requirements imposed on pet products will be ahead of the pack when FDA regulations for CBD products come out.
“Whether you’re dealing with a product for human consumption or animal consumption, it’s essentially the same. Even though requirements may vary, the principle behind it is the same,” Bougenies says. Pet CBD manufacturers and marketers that get in compliance now can hit the ground running when FDA acts—and run strong.
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