HHC and CBD Product Labelling Rules in the Czech Republic

Do you want to sell HHC or CBD products? You must know exactly what may and may not appear on the packaging. Incorrect packaging can cost you millions of Czech crowns in fines, seizure of stock, or even criminal prosecution in the Czech Republic. In this article, you will learn what the legal requirements for product labelling are in the Czech Republic and the EU, what happens if you breach them, and how to avoid the most common mistakes.

Quick summary

• Packaging of HHC products and the sale of HHC are now prohibited in the Czech Republic : HHC (and other derivatives such as HHC-O, THCP) has been added to the list of prohibited addictive substances. Manufacturers and sellers of HHC products therefore cannot operate legally in the Czech Republic – possession and sale constitute a criminal offence unless for licensed research purposes.
• CBD products are subject to strict labelling rules : Packaging must not imitate food, especially sweets attractive to children (so-called food imitation), must include Czech-language labelling, statutory warnings and ingredient information in line with the Consumer Protection Act and EU regulations. Edible products (edibles) are particularly problematic due to the Novel Food regulation.
• Incorrect packaging and labelling lead to sanctions : If you breach labelling requirements or place an unauthorised type of product on the market, you risk fines of up to CZK 50,000,000, seizure of stock and a ban on activity. In the case of HHC, this involves criminal liability.
• ARROWS attorneys handle this agenda on a daily basis : They work with manufacturers and distributors of cannabis products, understand all risks, and can help you avoid mistakes that would cost you significant money and time.

Legal status of HHC products: Sales ban in the Czech Republic

If you are considering selling HHC products in the Czech Republic, you need to know one fundamental thing: HHC is currently completely prohibited. The Czech Government added HHC, HHC-O and THCP to the list of addictive substances with effect from March 2024.

Although new legislation on psychomodulatory substances is being prepared, at this moment the status of HHC is clear and it is a prohibited addictive substance under Czech law.

This means that any commercial handling of HHC – including production, import, storage, distribution and sale – is illegal and criminally punishable in the same way as other drugs. The only exception is professional activity under a special permit to handle addictive substances, typically for research and scientific purposes.

This decision followed the massive spread of HHC products in the Czech Republic, especially in edibles, which were sold in vending machines and ended up in the hands of children.

If you have HHC products in your warehouses, you are engaging in unlawful conduct. The sale of HHC products constitutes the criminal offence of unauthorised production and other handling of narcotic and psychotropic substances and poisons, which may result in imprisonment, forfeiture of items and financial penalties.

The attorneys at ARROWS, a Prague-based law firm, have experience with criminal defence and can help you assess your situation from a legal perspective under Czech legislation and minimise the impact at office@arws.cz.

Related questions on HHC and the legal ban

1. Can I still sell HHC products that I purchased before the ban?
No. The ban applies absolutely. Possession of more than a small amount and any sale is a criminal offence.

2. Can I sell off HHC at a discount?
No. Placing it on the market is a criminal offence.

3. Are there any exceptions to the HHC ban?
There are none for ordinary commercial sales. Exceptions apply only to holders of a permit to handle addictive substances (laboratories, research).

CBD products: Strict labelling and packaging requirements

While HHC is prohibited, CBD (cannabidiol) obtained from industrial hemp is not considered an addictive substance. Its sale is possible in the Czech Republic; however, it is subject to strict regulations that differ depending on the product category under which it is placed on the market.

Basic requirements for CBD product packaging

Regardless of category, CBD product packaging must meet the general requirements of the Consumer Protection Act and the Packaging Act under Czech law:

Language and legibility : All mandatory information on the packaging must be in the Czech language. The font must be sufficiently large and legible. Selling goods with foreign-language packaging without a Czech overlabel is a breach of the Consumer Protection Act and may be fined.

Information on ingredients and the manufacturer: The packaging must clearly identify the product, its characteristics and ingredients, and must state the identification details of the manufacturer or importer.

Safety warnings : Depending on the type of product, the packaging must include the relevant warnings (e.g., for cosmetics “not for internal use”, “keep out of reach of children”).

Correct categorisation: It is crucial that the packaging does not mislead consumers as to the nature of the product; therefore, if the product is sold as a cosmetic, the packaging must not encourage consumption.

Manufacturers often have packaging designed by graphic designers without knowledge of the legal requirements, which leads to packaging that promises medicinal effects or fails to meet formal requirements. The attorneys at ARROWS, a Prague-based law firm, deal with such failures daily and will help you create packaging that is legally compliant under Czech and EU rules (office@arws.cz).

What must definitely not appear on CBD product packaging

Below are items that must absolutely not appear on the packaging, and including them exposes you to the risk of enforcement action by the Czech Agriculture and Food Inspection Authority (SZPI) or regional public health authorities:

Prohibition of medicinal claims : For foods, food supplements or cosmetics, you must not claim that CBD treats, prevents or alleviates a disease. Phrases such as “CBD cures insomnia”, “against pain” or “eliminates inflammation” are prohibited by the Czech Advertising Regulation Act and EU rules.

Imitation of food (Food Imitation): If you sell a product that is not a food but looks like food (gummy bears, chocolate) and could be mistaken by children for something to eat, you are breaching the Product Safety Directive. Such products may be classified as dangerous by supervisory authorities (risk of choking, poisoning) and withdrawn from the market.

Colourful and attractive packaging targeting children: Packaging must not be designed primarily to target children and minors; therefore, using characters and sweet-themed motifs is highly risky.

Misleading information about content : The stated CBD content (e.g., 10%) must not differ from the actual content. Any discrepancy is grounds for sanctions for misleading consumers under Section 5 of the Consumer Protection Act.

Practical example from practice: A manufacturer sold CBD oils with the claim “Medicine for anxiety and cancer”, for which SZPI imposed a high fine and ordered the products to be withdrawn.

Related questions on CBD packaging and labelling

1. Can I have CBD product packaging only in English if I sell online?
No. If you are targeting Czech consumers, all mandatory statutory information must be provided in Czech.

2. Is it necessary to state a best-before/use-by date?
Yes, for both cosmetics and foods, the minimum durability date or use-by date is a mandatory item of information under Czech legislation.

3. Can I say on CBD product packaging that it helps with relaxation?
If the product is a food or a food supplement, such a claim for CBD is not authorised (the so-called on-hold list) and is risky. For cosmetics, you may describe effects on the skin, but not psychological effects.

CBD and the issue of foods (edibles)

This is where the biggest legislative pitfalls arise. In the European Union, CBD (cannabidiol) is considered a so-called Novel Food. This means that without approval by the European Commission, CBD may not be legally placed on the market as a food or food supplement in the Czech Republic.

Manufacturers often circumvent this situation by selling CBD gummies or oils as collectors’ items or oils for technical purposes.

However, if a product looks like a food (a gummy bear), the Czech Agriculture and Food Inspection Authority (SZPI) may assess the product based on its appearance and nature as a food that does not meet legal requirements and ban its sale.

If you nevertheless operate in this area, from a general safety perspective the packaging should meet the following:

• Safety closure : The packaging should be child-resistant (Child Resistant Packaging).
• Warning : A clear warning that the product is not intended for consumption (if sold as a collectors’ item) or is not intended for children, pregnant women, and breastfeeding women.
• Opaque packaging : Increases protection of the product from light and reduces the attractiveness of the contents to children before opening.

The attorneys at ARROWS advokátní kancelář can prepare a risk analysis for the sale of specific product types and propose a strategy that minimises the risk of conflict with SZPI in the Czech Republic.

Contact our experts

Laboratory analysis: Essential for your defence

Even if Czech law does not explicitly require a QR code with the analysis directly on the packaging, as a manufacturer or distributor you must be able to demonstrate that your product complies with statutory limits in the Czech Republic.

Key parameters that must be supported by a laboratory test (CoA - Certificate of Analysis):

• THC content : Must be below the statutory limit (in the Czech Republic, for technical hemp up to 1% by weight).
• CBD content : Must correspond to the declaration on the packaging.
• Absence of contaminants : Heavy metals, pesticides, mould (important from the perspective of ).

Placing a QR code on the packaging linking to the current analysis is a strong signal of transparency and builds trust with customers and supervisory authorities.

The analysis must come from an accredited laboratory, because home tests or certificates from a supplier in third countries without EU verification may not be recognised by the authorities.

Related questions on laboratory analyses

1. Is a QR code on the packaging mandatory?
It is not a legal obligation, but it is a recommended transparency standard.

2. What if the CBD content in the lab differs from the packaging?
If the deviation is significant, this constitutes misleading consumers and penalties may apply.

What you risk if you breach the rules

Risks and penalties	How ARROWS can help (office@arws.cz)
Fine for misleading consumers / breach of the Food Act: Up to CZK 50,000,000 under the Act on Food and Tobacco Products (e.g., when selling unauthorised food supplements or using misleading labelling).	Audit and compliance: ARROWS will review your packaging and terms and conditions and ensure compliance with regulations under Czech law to prevent fines.
Seizure of goods and a ban on placing products on the market: SZPI may order the immediate withdrawal of products from the market if it assesses them as unsafe or non-compliant (e.g., Novel Food).	Administrative proceedings: In the event of an inspection, ARROWS will represent you before the authority, help formulate objections, and minimise the scope of measures.
Criminal prosecution: In the case of selling HHC or products with THC above the legal limit, there is a risk of imprisonment for illegal production and handling of narcotic substances under Czech criminal law.	Criminal defence: ARROWS provides top-tier defence in criminal matters related to cannabis regulation in the Czech Republic.
Closure of your e-shop by platforms: Payment gateways and hosting providers may terminate services if they suspect illegal activity.	Legal opinions: We will prepare a legal opinion for your partners (banks, gateways) confirming the legality of your business under Czech law.

EU standards for CBD packaging: What differs by country

If you want to export, Czech rules are not enough. In the EU, harmonisation is not applied uniformly.

• Germany : Very strict Novel Food controls. The THC limit is usually lower (often requiring non-detectable amounts in foods).
• France : Long-term restrictive, although court decisions have eased the situation. A ban on selling flowers intended for smoking still applies, and the sale of CBD extracts is regulated.
• Poland : THC limit 0.3% (now 0.3% under EU cultivation rules, but caution is required for finished products).
• Austria : CBD as a food or food supplement is prohibited (Novel Food). It is often sold as “Aroma” products that are not intended for consumption.

If you are planning expansion, you must verify the local regulation for each country. The attorneys at ARROWS advokátní kancelář provide legal support for entering foreign markets through a network of partner firms (office@arws.cz).

How to avoid the most common mistakes

Here is a list of things we see often that can get you into trouble in the Czech Republic:

• Mistake 1: Making medicinal claims . Phrases such as “heals inflammation”, “helps with pain”, “against depression” are prohibited for over-the-counter products (outside registered medicinal products).
• Mistake 2: Selling “edible” CBD without addressing Novel Food . Selling CBD gummy bears as a “food supplement” is a direct route to a sales ban by SZPI, because CBD is not an approved food.
• Mistake 3: Missing Czech-language labelling . Reselling foreign products without Czech labels is one of the most common reasons for fines from the Czech Trade Inspection Authority (ČOI).
• Mistake 4: Exceeding the THC limit . Relying on a supplier’s certificate without your own checks. If a spot check finds THC above 1% (or above the limit for the relevant category), criminal prosecution may follow in the Czech Republic.
• Mistake 5: Child-oriented motifs on packaging . Packaging resembling well-known candy brands or featuring cartoon characters breaches legal rules and ethical codes.

Our Prague-based attorneys at ARROWS can help you set up processes to prevent these mistakes (office@arws.cz).

Remediation and corrective processes: What to do if you have packaging errors

If you discover an error (or an authority points it out), you need to act quickly.

• Option 1: Relabeling. If the error is only in the text (e.g., missing information in Czech) and the product is otherwise safe, it is often sufficient to add a corrective sticker with the correct information.
• Option 2: Withdrawal from the market . If the product is unsafe (e.g., confusion with food, high THC), you must immediately withdraw it from distributors as well as end customers in the Czech Republic.
• Option 3: Dealing with the regulator . Never ignore an authority’s notice. Active cooperation and legal representation can significantly reduce the final penalty under Czech administrative practice.

Legal consultation for CBD manufacturers

Doing business in the cannabis industry means walking on thin legislative ice. ARROWS, a Prague-based law firm, can help you with:

• Compliance review : Assessing whether your business model (e.g., sale of CBD flowers, oils) aligns with the current interpretation of Czech law.
• Novel Food assessment : Advice on the status of your products and options for placing them on the market (e.g., as cosmetics vs. food) in the Czech Republic and the EU.
• Contract agenda : Contracts with suppliers and customers that protect you if substandard material is delivered (e.g., with THC above the legal limit).
• Representation during inspections : Communication with the Czech Agriculture and Food Inspection Authority (SZPI), the Czech Trade Inspection Authority (ČOI), the Czech Customs Administration, and the Police of the Czech Republic.

We are one of the largest law firms in the Czech Republic and have a dedicated team for regulation and Life Sciences. Don’t wait for a fine—contact us in time at office@arws.cz.

Related questions on CBD product labelling

1. Do I need a permit to manufacture CBD products in the Czech Republic?
If you extract CBD from cannabis, you may need a permit to handle addictive substances (if you exceed THC limits during the process) and a trade licence notification. For merely selling finished products, a special “cannabis” permit is usually not required, but you must comply with applicable notification and regulatory obligations under Czech law.

2. Can I state “BIO” on the packaging of a CBD product?
You may use the BIO or EKO designation only if you have an organic farming certificate. Misuse of these labels is strictly sanctioned under Czech legislation.

3. What about CBD flowers?
The sale of dried flowers of industrial hemp is legal in the Czech Republic, but their intended use is disputed. They are often sold for “technical, horticultural, or collectors’ purposes” because they are not officially approved as food or for smoking.

Conclusion

Correct CBD product packaging and understanding the HHC ban is not just bureaucracy—it is a necessary condition for your business to survive in the Czech Republic.

• HHC is banned : Sale and possession are criminal offences.
• CBD requires precision : Packaging must be in Czech, without medicinal claims, and consistent with the chosen category (cosmetics, collectors’ item).
• Watch out for foods (edibles): They run into Novel Food rules and are on inspectors’ radar.
• High sanctions : Multi-million fines and criminal liability are a real risk under Czech law.

Our Prague-based attorneys at ARROWS have experience with packaging and labelling of cannabis products, know what the authorities check, and will help you create packaging that passes inspections and protects you from legal risks (office@arws.cz).

FAQ – Most common legal questions on HHC and CBD product labelling

1. Can I sell my HHC stock abroad where it is legal?
The export of addictive substances (which now includes HHC) is subject to a strict permit regime of the Ministry of Health (export permit) under Czech law. Without it, export constitutes the criminal offence of smuggling. A simple “sale abroad” is not possible.

2. Can I sell CBD products of a foreign company in the Czech Republic without adjusting the packaging?
Only if the packaging is already in Czech and includes all mandatory information required by Czech regulations. In most cases, the product must be “Czech-localised” (via a sticker or new packaging).

3. What happens if an authority finds a CBD product with incorrect labelling?
Administrative proceedings will be initiated in the Czech Republic. In the best case, you will be given a deadline to remedy the issue and a smaller fine; in the worst case (for serious errors or unsafe products), a sales ban, withdrawal from the market, and a high fine.

4. Can I create my own packaging without legal review?
You can, but you bear full responsibility. Given the complexity of the rules (Novel Food, health claims, the Packaging Act), the risk of error is high.

5. What are the requirements for a CBD product intended for export to the EU?
They vary from country to country. Only some rules are harmonised (e.g., cosmetics), but approaches to CBD (especially in foods) and THC limits differ. A jurisdiction-specific review for the target market is necessary.

6. How long does it take to prepare legally compliant packaging?
Legal review typically takes several days to weeks depending on the complexity of the portfolio. Contact ARROWS, a Prague-based law firm, at office@arws.cz.

Notice: The information contained in this article is of a general informational nature only and is intended for basic guidance. Although we take maximum care to ensure accuracy, legal regulations and their interpretation evolve over time under Czech law. To verify the current wording of the regulations and their application to your specific situation, it is therefore necessary to contact ARROWS directly (office@arws.cz). We accept no liability for any damages or complications arising from the independent use of the information in this article without our prior individual legal consultation and expert assessment.

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