The Ultimate Guide to Cannabis Labeling Regulations

Regulations For The American Cannabis Industry By State

If you want your cannabis business to run smoothly, the most important thing you’ll need to do first, is to get into compliance with state legislative guidelines. This is no easy feat since many state governments are constantly changing their cannabis legislative guidelines for conducting business and the labeling and packaging of cannabis products with a never-ending stream of “updates”. If your business is registered and licensed to sell cannabis, cannabis products or produce cannabis, you can expect a letter from your government authority letting you know what the new updates are when they are written into law.

The wheels of bureaucracy however, turn very slowly. If you want to stay on top of these legislative updates, without waiting for a letter or an email from your local government when they are finally written into law, check back to this blog post regularly. You’ll be able to find the latest cannabis legislative updates here as soon as they are written into law.

Better yet, opt in to our free monthly newsletter where you can always stay abreast of what’s happening in the cannabis industry with new cannabis labeling and packaging compliance for your state and everything else that’s new in the cannabis industry. As soon as you do, you’ll receive a free copy of this report and compliance updates every month from there after.

If you’d like us to send you a free 4X3 foot colorful laminated CANNABIS COMPLIANCE poster for your state, just fill out your business name and address in our email response form before clicking the “CONFIRM” button.

(OPT IN FORM HERE)

As long as your business is diligent in following these guideline updates, you should never have compliance problems with your state’s new cannabis legislation.

But many cannabis businesses aren’t even clear what the laws are now in June, 2019 to begin with!

To help your new cannabis business get off on the right foot, we’ve put together the latest labeling and packaging regulations you’ll need to know for the particular state your cannabis business is in.

To make this guide work for you, simply scroll down until you find the state you’re operating in and read, learn and memorize your applicable guidelines until you know them inside out. And if you chose not to opt-in to our free monthly newsletter, we recommend that you find a poster-sized printing machine and copy your state’s regulations to make a poster you can mount behind your service counter for all to see.

It’s also more convenient and cost-effective for your new cannabis business to acquire your own in-house label printing system for all your cannabis product packaging. At Arrow Systems we carry only the leading state-of-the-art printing systems with the lowest prices on the market!

 ALASKA CANNABIS LABELING REQUIREMENTS

Because of the newness of America’s individual state legalization of medical and, or recreational adult use marijuana, you’ll be able to spot some of the “hangover” requirements from the heavy-handed Harry J. Anslinger days of post-1930’s cannabis prohibition. Mr. Anslinger is now notorious for being the, “racist hate-monger who masterminded America’s war on drugs”! Back then, for example, even though marijuana was never scientifically studied (because it was against the law to do so, thanks to Mr. Anslinger!) there was the assumption because Anslinger claimed cannabis could cause “reefer madness”, that cannabis was also harmful to human health. Today, you can spot this hangover from the past in Alaska’s new cannabis labeling regulations in the clause, (C) “There are health risks associated with consumption of marijuana”. In the last 10 years this has still never been scientifically proven.

Ironically, there is no clause in Alaska’s new cannabis regulations that require sellers to provide government samples for purity verification.

Alaska’s cannabis labeling and packaging guidelines include the following:

3 AAC 306.345. Packaging and labeling.

(a) A retail marijuana store shall assure that:

  • (3) any marijuana or marijuana product sold at a retail marijuana store must be packaged in opaque, re-seal-able, child-resistant packaging when the purchaser leaves the retail premises; the packaging must be designed or constructed to be significantly difficult for children under five years of age to open; but not normally difficult for adults to use properly.
  • (b) In addition to labeling requirements provided in (a) of this section, a retail marijuana store shall affix a label to each package of marijuana or marijuana product that,
  • (1) identifies the marijuana retail store selling the marijuana product by name or distinctive logo and marijuana establishment license number; and
  • (2) states the total estimated amount of THC in the labelled product, and (3) contains the following statements:
    • (A) “Marijuana has intoxicating effects and may be habit forming and addictive;”
    • (B) “Marijuana impairs concentration, coordination, and judgment. Do not operate a vehicle or machinery under its influence;”
    • (C) “There are health risks associated with consumption of marijuana”
    • (D) “For use only by adults twenty-one and older. Keep out of the reach of children;” and
    • (E) “Marijuana should not be used by women who are pregnant or breast feeding;”

ARIZONA CANNABIS LABELING REQUIREMENTS

Arizona’s cannabis labeling and packaging guidelines are a little stricter than Alaska’s in that Arizona now requires dispensaries in clause 13, to provide to the Department upon request, a sample of the dispensary’s medical marijuana inventory of sufficient quantity to enable the Department to conduct an analysis of the medical marijuana sample at any time they request it to verify for purity.

“Arizona’s cannabis labeling and packaging guidelines include the following:

  • R9-17-317. Product Labeling and Analysis
    1. A dispensary shall ensure that medical marijuana provided by the dispensary to a qualifying patient or a designated caregiver is labeled with:
    2. The dispensary’s registry identification number;
    3. The amount, strain, and batch number of medical marijuana;
    4. The following statement: “ARIZONA DEPARTMENT OF HEALTH SERVICES’ WARNING: Marijuana use can be addictive and can impair an individual’s ability to drive a motor vehicle or operate heavy machinery. Marijuana smoke contains carcinogens and can lead to an increased risk for cancer, tachycardia, hypertension, heart attack, and lung infection. KEEP OUT OF REACH OF CHILDREN”;
    5. If not cultivated by the dispensary, whether the medical marijuana was obtained from a qualifying patient, a designated caregiver, or another dispensary;
    6. The date of manufacture, harvest, or sale;
    7. A list of all chemical additives, including non-organic pesticides, herbicides, and fertilizers, used in the cultivation and production of the medical marijuana; and…
    8. The registry identification number of the qualifying patient.
    9. If a dispensary provides medical marijuana cultivated by the dispensary to another dispensary, the dispensary shall ensure that the medical marijuana is labeled with:
    10. The dispensary’s registry identification number;
    11. The amount, strain, and batch number of the medical marijuana;
    12. The date of harvest or sale; and 4. A list of all chemical additives, including non organic pesticides, herbicides, and fertilizers, used in the cultivation of the medical marijuana.
    13. If medical marijuana is provided as part of an edible food product, a dispensary shall, in addition to the information in subsection (A), include on the label the total weight of the edible food product.
    14. A dispensary shall provide to the Department upon request a sample of the dispensary’s medical marijuana inventory of sufficient quantity to enable the Department to conduct an analysis of the medical marijuana.

For more information, please refer to Title 9, Chapter 17. Department of Health Services Medical Marijuana Program.”

 

CALIFORNIA CANNABIS LABELING REQUIREMENTS

California, America’s first state to go medical marijuana legal in 2009 and then adult-use-recreational legal in 2016 has now become infamous for constantly “updating” its already contradictory, voluminous regulations where countless news stories in the media have blamed California’s government for actually hurting it’s pioneering new legal cannabis industry!

Interestingly enough, California has the unique distinction of drawing the line between “finished” and “unfinished” cannabis products in its regulations. Finished cannabis products are those which are legally ready for public consumption.

And even though California consists of a population of 39% Latinos, one of the new leading label regulations require that all cannabis labels be written in English only!

As you read through comparing state by state, you’ll also see that California has more new legal cannabis label regulations than any other state in the Union except for Colorado which really takes the cake! The sheer volume of regulations makes them confusing enough as they are, not to mention its nearly impossible to fit them all into one cannabis product label!

This is another great reason for Californian dispensaries to find or purchase their own poster printing machine so they can create a poster of the multitude of muddled new regulations to hang it their shops for all to see!

 

“The Office of Manufactured Cannabis Safety (OMCS) has proposed the following regulations:

SUBCHAPTER 5. LABELING AND PACKAGING REQUIREMENTS Article 1. General Provisions

  • Applicability.

The requirements in this section shall apply to finished cannabis products and shall not apply to cannabis or cannabis products that are transferred between licensees for purpose of further processing or packaging.

  • Release to Distributor as Finished Product.

Prior to release of a product to a distributor, a licensee shall ensure that the product is in finished form and is labeled and packaged in its final form for sale at a dispensary.

Article 2. Labeling Requirements §40403. General Provisions.

(a) Any information required to be listed on a label shall be written in English.

(b) A label shall be unobstructed and conspicuous.

(c) All required label information shall be unobstructed and conspicuous.

  • Primary Panel Labeling Requirements.

(a) The label for a cannabis product shall include a primary panel that includes the following information:

(1) The identity of the product in a text size reasonably related to the most prominent printed matter on the panel;

(2) The words “cannabis-infused” immediately above the identity of the product in bold type and a text size larger than the text size used for the identity of the product;

(3) The cannabis product symbol as prescribed in Section 40412 ;

(4) The net weight or volume of the contents of the package;

(5) The THC content and CBD content for the package in its entirety, expressed in milligrams per package;

(6) The THC content and CBD content per serving, expressed in milligrams per serving; and

(7) The content of other cannabinoids or terpenes per serving if such information is verified by the certificate of analysis issued by a licensed testing laboratory pursuant to Business and Professions Code section 19344.

(b) The primary panel text must be in type size no less than 6 point font and be in relation to the size of the primary panel and container.

  • Informational Panel Labeling Requirements.

(a) The label for a medical cannabis product shall include an informational panel that includes the following:

(1) The licensed manufacturer and its contact number or website address;

(2) The date of manufacture;

(3) Each of the following statements:

(A) “SCHEDULE I CONTROLLED SUBSTANCE.”
(B) “KEEP OUT OF REACH OF CHILDREN AND ANIMALS” in bold print.
(C) “FOR MEDICAL USE ONLY.”
(D) “IF PREGNANT OR BREASTFEEDING, CONSULT A PHYSICIAN PRIOR TO USE.”
(E) “THE INTOXICATING EFFECTS OF THIS PRODUCT MAY BE DELAYED BY UP TO TWO HOURS.”
(F) “THIS PRODUCT MAY IMPAIR THE ABILITY TO DRIVE OR OPERATE MACHINERY, PLEASE USE EXTREME CAUTION.”

(4) A list of all product ingredients in descending order of predominance by weight or volume;

(5) If an edible product that contains an ingredient, flavoring, coloring, or an incidental additive that bears or contains a major food allergen, the word “contains,” followed by a list of the applicable major food allergens;

(6) If an edible product, the names of any artificial food colorings contained in the product;

(7) If an edible product, the amount, in grams, of sodium, sugar, carbohydrates, and total fat per serving;

(8) The lot number;

(9) Instructions for use, such as the method of consumption or application, and any preparation necessary prior to use;

(10) The product expiration date, “use by” date, or “best by” date; and

(11) The unique identifier.

(b) The informational panel text shall be in a type size of no less than 6 point font and in relation to the size of the primary panel and container, unless there is insufficient area on the container available to print all the required information in a type size of no less than 6 point font. In such a case, the label shall include the warning statements required by paragraph (3) in a type size of no less than 6 point font, and the product shall be accompanied by a supplemental labeling that includes all of the information required by this section. The text of the supplemental labeling shall be no less than 8 point font.

  • Labeling Restrictions.

The label shall not contain any of the following:

(a) Claims that the manufactured cannabis or cannabis product was grown in a California county when the cannabis was not grown there.

(b) The name of a California county unless the cannabis was grown there.

(c) Content that is or designed to be attractive to individuals under the age of 21, including but not limited to:

(1) Cartoons;
(2) Any likeness to images, characters, or phrases that are popularly used to advertise to children; or
(3) Any imitation of candy packaging or labeling.

(d) False labeling information. Labeling is false if it is false or misleading in any particular.

(e) Claims of health benefits or other physical benefits.

  • Cannabis Product Symbol.

The primary panel of a medical cannabis product shall be marked, stamped, or otherwise imprinted with the cannabis product symbol directly on the package.

(a) The symbol shall replicate the following in form and color:

(b) The symbol shall be no smaller in size than half (.5) inch by half (.5) inch and shall be printed legibly and conspicuously.

Article 3. Packaging §40415. Packaging.

A package used to contain a cannabis product shall adhere to the following requirements:

(a) The package shall protect the product from contamination and shall not expose the product to any toxic or harmful substance.

(b) The package shall be tamper-evident, which means that the product shall be packaged in a container within which a product is sealed so that the contents cannot be opened without obvious destruction of the seal.

(c) The package shall be child-resistant, which means the package shall be designed or constructed to be significantly difficult for children under five years of age to open or otherwise obtain access to the product contained therein within a reasonable time, and shall not be difficult for normal adults to open or obtain access to the product contained therein. A package shall be deemed child-resistant if it satisfies the standard for “special packaging” as set forth in the Poison Prevention Packaging Act of 1970 Regulations (16 C.F.R. §1700.1(b)(4)).

(d) The package shall not imitate any package used for products typically marketed to children.

(e)If the product is an edible product, the package shall be opaque.

(f) If the package contains more than one serving of cannabis product, the package shall be re-sealable so that child-resistance is maintained throughout the life of the package.

For more information on California cannabis regulations, please see the California Office of Manufactured Cannabis Safety’s proposed regulations.

COLORADO CANNABIS LABELING REQUIREMENTS

The award for the most copious amounts of marijuana label regulations goes to Colorado—almost 14 pages of regulations!

Luckily for all the folks in Colorado, these label regulations have been written in plain English without all the legal jargon. So even though its set up to look like it was written in “legalese” at first glance, its actually quite easy to understand if you’ve graduated from a decent high school. For example, if you know what the words, “unobstructed and conspicuous” mean you’ll be OK!

There are however, various terms that only a very experienced person in the cannabis industry could easily identify. We’ve made up a little glossary of 8 of the most conspicuous ones to help you out. Please note however that this glossary is by no means all inclusive. So if you’ve found a term we’ve missed putting into plain English for you, then just copy and paste it into Google and let them work their magic!

  1. RFID TAGS: are a type of tracking system that uses smart barcodes in order to identify items. RFID is short for “radio frequency identification,” and as such, RFID tags utilize radio frequency technology.
  2. Optional Premises Cultivation Operation: is any form of licensed indoor growing area NOT in the same address as the product seller’s address of business.
  1. Medical Marijuana-Infused Products Manufacturer is any licensed manufacturer of marijuana-infused products such as edible solid “food” products, beer, wine, flavoured drinks where concentrated THC and or CBD oils are added.
  1. Universal Symbol: “Contains Marijuana. For Medical Use Only. Keep out of the reach of children.” Universal symbols are not meant to be understood by aliens anywhere else in the universe—even though that’s what the term implies. A universal symbol is any symbol, cannabis related or not, that can be understood in any part of our world here on the planet Earth. The universal symbol for marijuana looks like this:

or this:

  1. Child-Resistant Exit Package is a package dispensaries must provide for their sold products that will be taken off their premises that are not already packaged in a child-proof container.
  2. Child-Resistant means anything that children under the age of 5 will not be able to understand how to open. This means that children over the age of 5, like the age of 6 are not considered children any more. So what are they called, “Senior Children”? A lot of 10 year olds, in fact, most 10 year olds don’t even know how to get into child-resistant containers!
  1. Solvent-Based Medical Marijuana Concentrate: Hash Oil.
  2. Food-Water Based Medical Marijuana Concentrate: Hash Brownies.

“Colorado’s most recent updates to labeling requirements include the following stipulations:

  • M 1002 – Labeling Requirements: General Requirements
    1. Labeling Required. All Medical Marijuana and Medical Marijuana-Infused Product sold, transferred, or otherwise provided to a consumer must be in a Container that is labeled with all required information, see Rules M 1001 – Packaging Requirements: General Requirements, M 1003 – Labeling Requirements: Specific Requirements, Medical Marijuana and Medical Marijuana-Infused Product and M 1004 – Labeling Requirements: Specific Requirements, Edible Medical Marijuana-Infused Product, and that specifically excludes certain text.
    2. Health and Benefit Claims. Labeling text on a Container may not make any false or misleading statements regarding health or physical benefits to the consumer.
    3. Font Size. Labeling text on a Container must be no smaller than 1/16 of an inch.
    4. Use of English Language. Labeling text on a Container must be clearly written or printed and in the English language.
    5. Unobstructed and Conspicuous. Labeling text on a Container must be unobstructed and conspicuous. A Licensee may affix multiple labels to a Container, provided that none of the information required by these rules is completely obstructed.

M 1002.5 – Packaging and Labeling of Medical Marijuana by an Optional Premises Cultivation Operation or a Medical Marijuana-Infused Products Manufacturer

  1. Packaging of Medical Marijuana by an Optional Premises Cultivation Operation or a Medical Marijuana-Infused Products Manufacturer. Every Optional Premises Cultivation Operation and Medical Marijuana-Infused Products Manufacturer must ensure that all Medical Marijuana is placed within a sealed package that has no more than ten pounds of Medical Marijuana within it prior to transport or transfer of any Medical Marijuana to another Medical Marijuana Business. The package shall be affixed with an RFID tag in accordance with rule M 1001.5(A).
  2. Labeling of Medical Marijuana Packages by an Optional Premises Cultivation Operation or a Medical Marijuana-Infused Products Manufacturer. Every Optional Premises Cultivation Operation and Medical Marijuana-Infused Products Manufacturer must ensure that a label(s) is affixed to every package holding Medical Marijuana that includes all of the information required by this rule prior to transport or transfer to another Medical Marijuana Business.
  3. Required Information. Every Optional Premises Cultivation Operation and Medical Marijuana-Infused Products Manufacturer must ensure the following information is affixed to every package holding Medical Marijuana:
  4. The license number of the Optional Premises Cultivation Operation where the Medical Marijuana was grown;
  5. The Harvest Batch Number(s) assigned to the Medical Marijuana;
  6. The net weight, using a standard of measure compatible with the Inventory Tracking System, of the Medical Marijuana prior to its placement in the package; and
  7. A complete list of all nonorganic pesticides, fungicides, and herbicides used during the cultivation of the Medical Marijuana.
  8. Required Potency Statement. For each package of Medical Marijuana, the potency of at least the Medical Marijuana’s THC and CBD shall be included on a label that is affixed to the package. The potency shall be expressed as a range of percentages that extends from the lowest percentage to the highest percentage of concentration for each cannabinoid listed, from every test conducted on that strain of Medical Marijuana cultivated by the same Optional Premises Cultivation Operation within the last six months.
  9. Required Contaminant Testing Statement. CODE OF COLORADO REGULATIONS 1 CCR 212-1 Marijuana Enforcement Division 142
  10. When All Required Contaminant Tests Are Not Performed. If a Medical Marijuana Testing Facility did not test a Harvest Batch for microbials, mold, mildew, and filth, then the package shall be labeled with the following statement: “The marijuana contained within this package has not been tested for contaminants.” Except that when an Optional Premises Cultivation Operation has successfully validated its process regarding contaminants pursuant to rule M 1501, then the package instead shall be labeled with the following statement: “The marijuana contained within this package complies with the mandatory contaminant testing required by rule M 1501.”
  11. When All Required Contaminant Tests Are Performed and Passed. If a Medical Marijuana Testing Facility tested a Harvest Batch for microbials, mold, mildew, and filth, and the required test(s) passed, then the package shall be labeled with the following statement: “The marijuana contained within this package complies with the mandatory contaminant testing required by rule M 1501.”
  12. Nothing in this rule permits a Medical Marijuana Business to transfer, wholesale, or sell Medical Marijuana that has failed contaminant testing and has not subsequently passed the additional contaminant testing required by rule M 1507(B).
  13. Labeling of Medical Marijuana Containers by an Optional Premises Cultivation Operation or a Medical Marijuana-Infused Products Manufacturer. If an Optional Premises Cultivation Operation or a Medical Marijuana-Infused Products Manufacturer packages Medical Marijuana within a Container that is then placed within a larger package, each Container must be affixed with a label(s) containing all of the information required by Rule M 1002.5(B), except that the net weight statement required by Rule M 1002.5(B)(1)(c) shall be based upon the weight in the Container and not the larger package or Shipping Container.

M 1003 – Labeling Requirements: Specific Requirements, Medical Marijuana and Medical Marijuana-Infused Product

  1. Labels Required. No Licensee shall sell, transfer, or give away any Medical Marijuana that does not contain a Label with a list of all ingredients, including all chemical additives, including but not limited to nonorganic pesticides, herbicides, and fertilizers that were used in its cultivation and production. The label must also list:
  2. The Batch Number or numbers assigned by the Optional Premises Cultivation Operation to the marijuana plant or plants from which the Medical Marijuana contained within the Container was harvested; and
  3. A complete list of solvents and chemicals used in the creation of any Medical Marijuana concentrate.

CODE OF COLORADO REGULATIONS 1 CCR 212-1 Marijuana Enforcement Division 143 B. Medical Marijuana Container Labeling Must Include the Following Information:

  1. The license number of the Optional Premises Cultivation Facility, if different than the Medical Marijuana Center’s license number, identifying where the Medical Marijuana within the Container was grown;
  2. The license number of the Medical Marijuana Center that sold the Medical Marijuana to the patient;
  3. The date of sale; and
  4. The patient registry number of the purchaser.
  5. Medical Marijuana-Infused Product Container Labeling Must Include the Following Information:
  6. The license number of the Medical Marijuana Business(es) where the Medical Marijuana used to manufacture the Medical Marijuana-Infused Product within the Container was grown;
  7. The license number of the Medical Marijuana Center that sold the Medical MarijuanaInfused Product to the patient;
  8. The following statement: “This product contains medical marijuana and was produced without regulatory oversight for health, safety or efficacy and there may be health risks associated with the consumption of the product.”
  9. For Medical Marijuana-Infused Product, the product identity and net weight statements must appear on the portion of the label displayed to the patient.
  10. When a Medical Marijuana-Infused Product is made specifically for a designated patient, the label of that product shall state the patient’s Medical Marijuana Registry number.
  11. The list of ingredients and company name statements must be conspicuously listed on the Medical Marijuana-Infused Product package.
  12. A nutrition facts panel may be required if nutritional claims are made on the label of any Medical Marijuana-Infused Product.
  13. Minimum print size. The minimum print size for each of the required statements for non-infused products and for each of the required statements for Medical Marijuana-Infused Product is 1/16 inch. The size of the characters in the net weight statement is determined by the area of the principal display panel and may be greater than 1/16 inch.

M 1003.5 – Packaging and Labeling of Medical Marijuana Concentrate by an Optional Premises Cultivation Operation or a Medical Marijuana-Infused Products Manufacturer

  1. Packaging of Medical Marijuana Concentrate by an Optional Premises Cultivation Operation or a Medical Marijuana-Infused Products Manufacturer. Every Optional Premises Cultivation Operation and Medical Marijuana-Infused Products Manufacturer must ensure that all Medical Marijuana Concentrate is placed within a sealed package that has no more than one pound of Medical Marijuana Concentrate within it prior to transport or transfer to another Medical Marijuana Business. The package shall be affixed with an RFID tag in accordance with rule M 1001.5(A).
  2. Labeling Medical Marijuana Concentrate Package by an Optional Premises Cultivation Operation or a Medical Marijuana-Infused Products Manufacturer. Every Optional Premises Cultivation Operation and Medical Marijuana-Infused Products Manufacturer must ensure that a label(s) is affixed to every package holding Medical Marijuana Concentrate that includes all of the information required by this rule prior to transport or transfer to another Medical Marijuana Business.
  3. Required Information. Every Optional Premises Cultivation Operation and Medical Marijuana-Infused Products Manufacturer must ensure the following information is affixed to every package holding Medical Marijuana Concentrate:
  4. The license number(s) of the Optional Premises Cultivation Operation(s) where the Medical Marijuana used to produce the Medical Marijuana Concentrate was grown;
  5. The license number of the Optional Premises Cultivation Operation or Medical Marijuana-Infused Products Manufacturer that produced the Medical Marijuana Concentrate;
  6. The Production Batch Number assigned to the Medical Marijuana Concentrate contained within the package;
  7. The net weight, using a standard of measure compatible with the Inventory Tracking System, of the Medical Marijuana Concentrate prior to its placement in the package;
  8. A complete list of all nonorganic pesticides, fungicides, and herbicides used during the cultivation of the Medical Marijuana used to produce the Medical Marijuana Concentrate contained within; and
  9. A complete list of solvents and chemicals used to create the Medical Marijuana Concentrate.
  10. Required Potency Statement. For each package of Medical Marijuana Concentrate, the potency of at least the Medical Marijuana Concentrate’s THC and CBD shall be included on a label that is affixed to the package. The potency shall be expressed in milligrams for each cannabinoid.
  11. Required Contaminant Testing Statement.
  12. When All Required Contaminant Tests Are Not Performed. CODE OF COLORADO REGULATIONS 1 CCR 212-1 Marijuana Enforcement Division 145
  13. Solvent-Based Medical Marijuana Concentrate. If a Medical Marijuana Testing Facility did not test a Production Batch of Solvent-Based Medical Marijuana Concentrate for residual solvents, mold, and mildew, then the package shall be labeled with the following statement: “The Medical Marijuana Concentrate contained within this package has not been tested for contaminants.” Except that when a Medical MarijuanaInfused Products Manufacturer has successfully validated its process regarding contaminants pursuant to rule M 1501, the package instead shall be labeled with the following statement: “The Medical Marijuana Concentrate contained within this package complies with the mandatory contaminant testing required by rule M 1501.”
  14. Food- and Water-Based Medical Marijuana Concentrate. If a Medical Marijuana Testing Facility did not test a Production Batch of Food- or Water-Based Medical Marijuana Concentrate for microbials, mold, and mildew, then the package shall be labeled with the following statement: “The Medical Marijuana Concentrate contained within this package has not been tested for contaminants.” Except that when an Optional Premises Cultivation Operation or a Medical Marijuana-Infused Products Manufacturer has successfully validated its process regarding contaminants pursuant to rule M 1501, then the package instead shall be labeled with the following statement: “The Medical Marijuana Concentrate contained within this package complies with the mandatory contaminant testing required by rule M 1501.”
  15. When All Required Contaminant Tests Are Performed and Passed.
  16. Solvent-Based Medical Marijuana Concentrate. If a Medical Marijuana Testing Facility tested a Production Batch of Solvent-Based Medical Marijuana Concentrate for residual solvents, mold, and mildew, and the required test(s) passed, then the package shall be labeled with the following statement: “The Medical Marijuana Concentrate contained within this package complies with the mandatory contaminant testing required by rule M 1501.”
  17. Food- and Water-Based Medical Marijuana Concentrate. If a Medical Marijuana Testing Facility tested a Production Batch for microbials, mold, and mildew, and the required test(s) passed, then the package shall be labeled with the following statement: “The Medical Marijuana Concentrate contained within this package complies with the mandatory contaminant testing required by rule M 1501.”
  18. Nothing in this rule permits a Medical Marijuana Business to transfer, wholesale, or sell Medical Marijuana Concentrate that has failed contaminant testing and has not subsequently passed the additional contaminant testing required by rule M 1507(B).
  19. Labeling of Medical Marijuana Concentrate Containers by an Optional Premises Cultivation Operation or a Medical Marijuana-Infused Products Manufacturer. If an Optional Premises Cultivation Operation or a Medical Marijuana-Infused Products Manufacturer packages a Medical Marijuana Concentrate within a Container that is then placed within a larger package, each Container must be affixed with a label(s) containing all of the information required by Rule M 1003.5(B), except that the net weight statement required by Rule M 1003.5(B)(1)(d) shall be based upon the weight in the Container and not the package or Shipping Container.

M 1004 – Labeling Requirements: Specific Requirements, Medical Marijuana-Infused Product

  1. Ingredient List. A list of all ingredients used to manufacture the Edible Medical Marijuana-Infused Product; which may include a list of any potential allergens contained within, or used in the manufacture of, the Medical Marijuana-Infused Product.
  2. Statement Regarding Refrigeration. A statement that the Medical Marijuana-Infused Product, if perishable, must be refrigerated.
  3. Statement of Expiration Date. A product expiration date, for perishable Medical Marijuana-Infused Product, upon which the product will no longer be fit for consumption, or a use-by-date, upon which the product will no longer be optimally fresh. Once a label with a use-by or expiration date has been affixed to a Container of a Medical Marijuana-Infused Product, a Licensee shall not alter that date or affix a new label with a later use-by or expiration date.

M 1004.5 – Packaging and Labeling Requirements of a Medical Marijuana Infused-Product by a Medical Marijuana-Infused Products Manufacturer

  1. Packaging of Medical Marijuana Infused-Product by a Medical Marijuana-Infused Products Manufacturer CODE OF COLORADO REGULATIONS 1 CCR 212-1 Marijuana Enforcement Division 147
  2. General Standard. Every Medical Marijuana-Infused Products Manufacturer must ensure that each Container holding a Medical Marijuana Infused-Product is placed in a package prior to transport or transfer to another Medical Marijuana Business. The package shall be affixed with an RFID tag in accordance with rule M 1001.5(A).
  3. Edible Medical Marijuana Infused-Product.
  4. Every Medical Marijuana-Infused Products Manufacturer must ensure that each Edible Medical Marijuana Infused-Product is packaged within a Child-Resistant Container prior to transport or transfer to another Medical Marijuana Business.
  5. If the Edible Medical Marijuana-Infused Product contains multiple portions then it must be packaged in a Child-Resistant Container that maintains its ChildResistant effectiveness for multiple openings
  6. Medical Marijuana Infused-Product that is not Edible Medical Marijuana Infused-Product. Every Medical Marijuana-Infused Products Manufacturer must ensure that each Medical Marijuana Infused-Product that is not an Edible Medical Marijuana Infused-Product is individually packaged within a Container prior to transport or transfer to another Medical Marijuana Business.
  7. Labeling of Medical Marijuana Infused-Product Containers by a Medical Marijuana-Infused Products Manufacturer. A Medical Marijuana-Infused Products Manufacturer must ensure that a label(s) is affixed to every Container holding a Medical Marijuana Infused-Product that includes all of the information required by this rule prior to transport or transfer to another Medical Marijuana Business.
  8. Required Information (General). Every Medical Marijuana-Infused Products Manufacturer must ensure the following information is affixed to every Container holding a Medical Marijuana Infused-Product:
  9. The license number(s) of the Optional Premises Cultivation Operation(s) where the Medical Marijuana used to produce the Medical Marijuana Infused-Product was grown;
  10. The Production Batch Number(s) of Medical Marijuana Concentrate(s) used in the production of the Medical Marijuana Infused-Product.
  11. The license number of the Medical Marijuana-Infused Products Manufacturer that produced the Medical Marijuana Infused-Product.
  12. A net weight statement.
  13. The Production Batch Number(s) assigned to the Medical Marijuana InfusedProduct.
  14. A statement about whether the Container is Child-Resistant.
  15. The Identity Statement and Standardized Graphic Symbol of the Medical Marijuana-Infused Products Manufacturer that manufactured the Medical Marijuana Infused-Product. A Licensee may elect to have its Identity Statement also serve as its Standardized Graphic Symbol for purposes of complying with this rule. The Licensee shall maintain a record of its Identity Statement and Standardized Graphic Symbol and make such information available to the State Licensing Authority upon request;
  16. The Universal Symbol, which must be located on the front of the Container and no smaller than ½ of an inch by ½ of an inch, and the following statement which must be labeled directly below the Universal Symbol: “Contains Marijuana. For Medical Use Only. Keep out of the reach of children.”
  17. The following warning statements:
  18. “There may be health risks associated with the consumption of this product.”
  19. “This product contains marijuana and its potency was tested with an allowable plus or minus 15% variance pursuant to 12-43.3- 202(2.5)(a)(I)(E), C.R.S.” iii. “This product was produced without regulatory oversight for health, safety, or efficacy.”
  20. “There may be additional health risks associated with the consumption of this product for women who are pregnant, breastfeeding, or planning on becoming pregnant.”
  21. A complete list of all nonorganic pesticides, fungicides, and herbicides used during the cultivation of the Medical Marijuana used to produce the Medical Marijuana Infused-Product.
  22. A complete list of solvents and chemicals used in the creation of any Medical Marijuana Concentrate that was used to produce the Medical Marijuana InfusedProduct.
  23. Required Potency Statement. This subsubparagraph (B)(1)(m) of rule M 1004.5 shall become effective October 1, 2017. Each Container holding a Medical Marijuana-Infused Product shall be labeled with the potency of at least the Medical Marijuana-Infused Product’s THC and CBD. The potency shall be expressed in milligrams for each cannabinoid. The potency shall be labeled either:
  24. In a font size that is at least two font sizes larger than the surrounding label text and also not less than 10 point font, bold, and enclosed within an outlined shape such as a circle or square; or
  25. Highlighted with a bright color such as yellow. 2. Required Information (Edible Medical Marijuana Infused-Product). Every Medical Marijuana-Infused Products Manufacturer must ensure that the following information or statement is affixed to every Container holding an Edible Medical Marijuana Infused Product:
  26. Ingredient List. A list of all ingredients used to manufacture the Edible Medical Marijuana Infused-Product; which shall include a list of any potential allergens contained within.
  27. Statement Regarding Refrigeration. If the Edible Medical Marijuana Infused Product is perishable, a statement that the Edible Medical Marijuana Infused Product must be refrigerated.
  28. Statement of Production Date. The date on which the Edible Medical Marijuana Infused-Product was produced.
  29. Statement of Expiration Date. A product expiration date, for perishable Edible Medical Marijuana Infused-Product, upon which the product will no longer be fit for consumption, or a use-by-date, upon which the product will no longer be optimally fresh. Once a label with a use-by or expiration date has been affixed to a Container holding an Edible Medical Marijuana Infused-Product, a Licensee shall not alter that date or affix a new label with a later use-by or expiration date.
  30. Permissive Information (Edible Medical Marijuana Infused-Product). Every Medical Marijuana-Infused Products Manufacturer may affix a label(s) with the following information to every Container holding an Edible Medical Marijuana Infused-Product:
  31. The Medical Marijuana Infused-Product’s compatibility with dietary restrictions.
  32. A nutritional fact panel.
  33. Required Potency Statement.
  34. Every Medical Marijuana-Infused Products Manufacturer must ensure that a label is affixed to the Container that includes at least the Medical Marijuana InfusedProduct’s THC and CBD content.
  35. Nothing in this rule permits a Medical Marijuana Business to transfer, wholesale, or sell Medical Marijuana Infused-Product that has failed potency testing and has not subsequently passed the additional potency testing required by rule R 1507(C).
  36. Required Contaminant Testing Statement.
  37. When All Required Contaminant Tests Are Not Performed. If a Medical Marijuana Testing Facility did not test a Production Batch of Medical Marijuana Infused Product for microbials, mold, and mildew, then the Container shall be labeled with the following statement: “The Medical Marijuana Infused-Product contained within this package has not been tested for contaminants.” Except that when a Medical Marijuana-Infused Products Manufacturer has successfully validated its process regarding contaminants for the particular Medical Marijuana Infused-Product pursuant to rule M 1501, then the Container instead shall be labeled with the following statement: “The Medical Marijuana Infused-Product contained within this package complies with the mandatory contaminant testing required by rule M 1501.”
  38. When All Contaminant Tests Are Performed and Passed. If a Medical Marijuana Testing Facility tested a Production Batch of Medical Marijuana Infused-Product for microbials, mold, and mildew, and the required test(s) passed, then the Container shall be labeled with the following statement: “The Medical Marijuana Infused-Product contained within this package complies with the mandatory contaminant testing required by rule M 1501.”
  39. Nothing in this rule permits a Medical Marijuana Business to transfer, wholesale, or sell Medical Marijuana Infused-Product that has failed contaminant testing and has not subsequently passed the additional contaminant testing required by rule M 1507(B). A Medical Marijuana-Infused Products Manufacturer must include the following information on every Shipping Container or package:
  40. The number of Containers holding a Medical Marijuana Infused-Product within the Shipping Container or package; and
  41. The license number of the Medical Marijuana-Infused Products Manufacturer(s) that produced the Medical Marijuana Infused-Product within the Shipping Container or package. The allowable plus or minus 15% potency variance has been included in the rule pursuant to the mandate of Senate Bill 15-260. Section 1 of the bill required the State Licensing Authority to establish an acceptable potency variance for correct labeling. The acceptable potency variance has been set at plus or minus 15% to comport with the potency variance mandated by the Retail Code.

M 1005 – Packaging and Labeling of Medical Marijuana by a Medical Marijuana Center

  1. Packaging of Medical Marijuana by a Medical Marijuana Center.
  2. A Medical Marijuana Center must ensure that all Medical Marijuana is placed within a Container prior to sale to a consumer. If the Container is not Child-Resistant, the Medical Marijuana Center must place the Container within an Exit Package that is ChildResistant.
  3. Except that when a patient provides written documentation signed by his or her physician attesting to the fact that it would be unreasonably difficult for the patient to open packaging that is Child-Resistant:
  4. A Medical Marijuana Center shall not be required to package the Medical Marijuana in a Child-Resistant Container for sale to the patient; and
  5. A Medical Marijuana Center shall not be required to utilize a 5 for the patient.
  6. If the Medical Marijuana is packaged in a Child-Resistant Container, a Medical Marijuana Center may defeat the Medical Marijuana’s Child-Resistant packaging on behalf of the patient, so long as the Medical Marijuana remains with the packaging after the Child-Resistant properties have been defeated. CODE OF COLORADO REGULATIONS 1 CCR 212-1 Marijuana Enforcement Division 151
  7. Labeling of Medical Marijuana by a Medical Marijuana Center. A Medical Marijuana Center must affix all of the information required by this rule to every Container in which Medical Marijuana is placed no later than at the time of sale to a patient:
  8. A Medical Marijuana Center must include the following information on every Container:
  9. The license number(s) of the Optional Premises Cultivation Operation(s) where the Medical Marijuana was grown;
  10. The license number of the Medical Marijuana Center that sold the Medical Marijuana to the patient;
  11. The Identity Statement and Standardized Graphic Symbol of the Medical Marijuana Center that sold the Medical Marijuana to the consumer. A Licensee may elect to have its Identity Statement also serve as its Standardized Graphic Symbol for purposes of complying with this rule. The Licensee shall maintain a record of its Identity Statement and Standardized Graphic Symbol and make such information available to the State Licensing Authority upon request;
  12. The Harvest Batch Number(s) assigned to the Medical Marijuana within the Container;
  13. The date of sale to the patient;
  14. The patient registry number of the purchaser;
  15. The net weight, in grams to at least the tenth of a gram, of the Medical Marijuana prior to its placement in the Container;
  16. The following warning statements:
  17. “There may be health risks associated with the consumption of this product.”
  18. “This marijuana’s potency was tested with an allowable plus or minus 15% variance pursuant to 12-43.3-202(2.5)(a)(I)(E), C.R.S.”

iii. “There may be additional health risks associated with the consumption of this product for women who are pregnant, breastfeeding, or planning on becoming pregnant.”

  1. A complete list of all nonorganic pesticides, fungicides, and herbicides used during the cultivation of the Medical Marijuana.
  2. The Universal Symbol, which must be located on the front of the Container and no smaller than ½ of an inch by ½ of an inch, and the following statement which must be labeled directly below the Universal Symbol: “Contains Marijuana. For Medical Use Only. Keep out of the reach of children.” For each Harvest Batch of Medical Marijuana packaged within a Container, the Medical Marijuana Center shall ensure the potency of at least the Medical Marijuana’s THC and CBD is included on a label that is affixed to the Container. The potency shall be expressed as a range of percentages that extends from the lowest percentage to the highest percentage of concentration for each cannabinoid listed, from every test conducted on that strain of Medical Marijuana cultivated by the same Optional Premises Cultivation Operation within the last six months.

2.1. Required Potency Statement.

For each Harvest Batch of Medical Marijuana packaged within a Container, the Medical Marijuana Center shall ensure the potency of at least the Medical Marijuana’s THC and CBD is included on a label that is affixed to the Container. The potency shall be expressed as a range of percentages that extends from the lowest percentage to the highest percentage of concentration for each cannabinoid listed, from every test conducted on that strain of Medical Marijuana cultivated by the same Optional Premises Cultivation Operation within the last six months. The potency shall be labeled either:

  1. In a font size that is at least two font sizes larger than the surrounding label text and also not less than 10-point font, bold, and enclosed within an outlined shape such as a circle or square; or
  2. Highlighted with a bright color such as yellow.
  3. Required Contaminant Testing Statement.
  4. When All Required Contaminant Tests Are Not Performed. If a Medical Marijuana Testing Facility did not test a Harvest Batch for microbials, mold, mildew, and filth, then a Medical Marijuana Center must ensure that a label is affixed to a Container holding any Medical Marijuana from that Harvest Batch with the following statement: “The marijuana contained within this package has not been tested for contaminants.” Except that when an Optional Premises Cultivation Operation has successfully validated its process regarding contaminants pursuant to rule M 1501, then the Container instead shall be labeled with the following statement: “The marijuana contained within this package complies with the mandatory contaminant testing required by rule M 1501.”
  5. When All Required Contaminant Tests Are Performed and Passed. If a Medical Marijuana Testing Facility tested a Harvest Batch for microbials, mold, mildew, and filth, and all the required test(s) passed, then the Container shall be labeled with the following statement: “The marijuana contained within this package complies with the mandatory contaminant testing required by rule M 1501.”
  6. Nothing in this rule permits a Medical Marijuana Business to transfer, wholesale, or sell Medical Marijuana that has failed contaminant testing and has not subsequently passed the additional contaminant testing required by rule M 1507

M 1006 – Packaging and Labeling of Medical Marijuana Infused-Product by a Medical Marijuana Center

  1. Packaging Requirements for a Medical Marijuana Center.
  2. Beginning December 1, 2016, a Medical Marijuana Center shall not purchase, take possession of, or sell Medical Marijuana-Infused Product that does not comply with rules M 604 and M 1004.5.
  3. A Medical Marijuana Center must ensure that each Medical Marijuana Infused-Product is placed within a Container prior to sale to a consumer. If the Container is not Child Resistant, the Medical Marijuana Center must place the Container within an Exit Package that is Child-Resistant.
  4. Except that when a patient provides written documentation signed by his or her physician attesting to the fact that it would be unreasonably difficult for the patient to open packaging that is Child-Resistant:
  5. If the Medical Marijuana-Infused Product is packaged in a Child-Resistant Container, a Medical Marijuana Center may defeat the Medical Marijuana Infused Product’s Child-Resistant packaging on behalf of the patient, so long as the Medical Marijuana-Infused Product remains with the packaging after the Child-Resistant properties have been defeated; or
  6. If the Medical Marijuana-Infused Product is not packaged in a Child-Resistant Container, a Medical Marijuana Center shall not be required to package the Medical Marijuana-Infused Product in a Child-Resistant Container for sale to the patient; and
  7. A Medical Marijuana Center shall not be required to utilize a Child-Resistant Exit Package for the patient.
  8. Labeling of Medical Marijuana Infused-Product by a Medical Marijuana Center. Every Medical Marijuana Center must ensure that a label(s) is affixed to every Exit Package at the time of sale to a consumer that includes all of the information required by this rule. If an Exit Package is not required pursuant to subparagraph (A)(2) of this rule M 1006, and the Medical Marijuana Center elects not to provide one, then the Medical Marijuana Center must ensure the labels required by this rule are affixed to each Container of Medical Marijuana Infused-Product no later than at the time of sale to a consumer.
  9. Required Information.
  10. The license number of the Medical Marijuana Center that sold the Medical Marijuana Infused-Product to the consumer;
  11. The Identity Statement and Standardized Graphic Symbol of the Medical Marijuana Center that sold the Medical Marijuana Infused-Product to the consumer. A Licensee may elect to have its Identity Statement also serve as its Standardized Graphic Symbol for purposes of complying with this rule. The Licensee shall maintain a record of its Identity Statement and Standardized Graphic Symbol and make such information available to the State Licensing Authority upon request;
  12. The date of sale to the consumer;
  13. The patient registry number of the purchaser;
  14. The following warning statements;
  15. “There may be health risks associated with the consumption of this product.”
  16. “This product contains marijuana and its potency was tested with an allowable plus or minus 15% variance pursuant to 12-43.3- 202(2.5)(a)(I)(E), C.R.S.”

iii. “This product was produced without regulatory oversight for health, safety, or efficacy.”

  1. “There may be additional health risks associated with the consumption of this product for women who are pregnant, breastfeeding, or planning on becoming pregnant.”
  2. The Universal Symbol, which must be located on the front of the Container or Exit Package as appropriate and no smaller than ½ of an inch by ½ of an inch, and the following statement which must be labeled directly below the Universal Symbol: “Contains Marijuana. For Medical Use Only. Keep out of the reach of children.”
  3. Required Potency Statement.

Each Container holding a Medical Marijuana-Infused Product shall be labeled with the potency of at least the Medical Marijuana-Infused Product’s THC and CBD. The potency shall be expressed in milligrams for each cannabinoid. The potency shall be labeled either:

  1. In a font size that is at least two font sizes larger than the surrounding label text and also not less than 10-point font, bold, and enclosed within an outlined shape such as a circle or square; or
  2. Highlighted with a bright color such as yellow.

M 1007 – Packaging and Labeling of Medical Marijuana Concentrate by a Medical Marijuana Center

  1. Packaging of Medical Marijuana Concentrate by an Optional Premises Cultivation Operation.
  2. A Medical Marijuana Center must ensure that all Medical Marijuana Concentrate is placed within a Container prior to sale to a consumer. If the Container is not ChildResistant, the Medical Marijuana Center must place the Container within an Exit Package that is Child-Resistant.
  3. Except that when a patient provides written documentation signed by his or her physician attesting to the fact that it would be unreasonably difficult for the patient to open packaging that is Child-Resistant:
  4. A Medical Marijuana Center shall not be required to package the Medical Marijuana Concentrate in a Child-Resistant Container for sale to the patient; and
  5. A Medical Marijuana Center shall not be required to utilize a Child-Resistant Exit Package for the patient.
  6. If the Medical Marijuana Concentrate is packaged in a Child-Resistant Container, a Medical Marijuana Center may defeat the Medical Marijuana Concentrate’s Child-Resistant packaging on behalf of the patient, so long as the Medical Marijuana Concentrate remains with the packaging after the Child-Resistant properties have been defeated.
  7. Labeling of Medical Marijuana Concentrate by Medical Marijuana Centers. Every Medical Marijuana Center must ensure that a label(s) is affixed to every Container holding Medical Marijuana Concentrate that includes all of the information required by this rule no later than at the time of sale to a consumer:
  8. Every Medical Marijuana Center must ensure the following information is affixed to every Container holding a Medical Marijuana Concentrate:
  9. The license number(s) of the Optional Premises Cultivation Operation(s) where the Medical Marijuana used to produce the Medical Marijuana Concentrate within the Container was grown;
  10. The license number of the Optional Premises Cultivation Operation or Medical Marijuana-Infused Products Manufacturer that produced the Medical Marijuana Concentrate;
  11. The Production Batch Number assigned to the Medical Marijuana Concentrate;
  12. The license number of the Medical Marijuana Center that sold the Medical Marijuana Infused-Product to the consumer;
  13. The net weight, in grams to at least the tenth of a gram, of the Medical Marijuana Concentrate prior to its placement in the Container;
  14. The date of sale to the consumer;
  15. The patient registry number of the purchaser;
  16. The following warning statements:
  17. “There may be health risks associated with the consumption of this product.”
  18. “This product contains marijuana and its potency was tested with an allowable plus or minus 15% variance pursuant to 12-43.3- 202(2.5)(a)(I)(E), C.R.S.”
  19. “This product was produced without regulatory oversight for health, safety, or efficacy.”
  20. “There may be additional health risks associated with the consumption of this product for women who are pregnant, breastfeeding, or planning on becoming pregnant.”
  21. The Universal Symbol, which must be located on the front of the Container and no smaller than ½ of an inch by ½ of an inch, and the following statement which must be labeled directly below the Universal Symbol: “Contains Marijuana. For Medical Use Only. Keep out of the reach of children.”
  22. A complete list of all nonorganic pesticides, fungicides, and herbicides used during the cultivation of the Medical Marijuana used to produce the Medical Marijuana Concentrate; and
  23. A complete list of solvents and chemicals used to produce the Medical Marijuana Concentrate.
  24. Required Potency Statement.

2.1. Required Potency Statement. Each Container holding a Medical Marijuana Concentrate shall be labeled with the potency of at least the Medical Marijuana Concentrate’s THC and CBD. The potency shall be expressed in milligrams for each cannabinoid. The potency shall be labeled either: CODE OF COLORADO REGULATIONS 1 CCR 212-1 Marijuana Enforcement Division 157

  1. In a font size that is at least two font sizes larger than the surrounding label text and also not less than 10-point font, bold, and enclosed within an outlined shape such as a circle or square; or
  2. Highlighted with a bright color such as yellow.
  3. Required Contaminant Testing Statement.
  4. When All Required Contaminant Tests Are Not Performed.
  5. Solvent-Based Medical Marijuana Concentrate. If a Medical Marijuana Testing Facility did not test a Production Batch of Solvent-Based Medical Marijuana Concentrate for residual solvents, mold, and mildew, then the Container shall be labeled with the following statement: “The Medical Marijuana Concentrate contained within this package has not been tested for contaminants.” Except that when a Medical MarijuanaInfused Products Manufacturer has successfully validated its process regarding contaminants pursuant to rule M 1501, then the Container instead shall be labeled with the following statement: “The Medical Marijuana Concentrate contained within this package complies with the mandatory contaminant testing required by rule M 1501.”
  6. Food- and Water-Based Medical Marijuana Concentrate. If a Medical Marijuana Testing Facility did not test a Production Batch of Food- or Water-Based Medical Marijuana Concentrate for microbials, mold, and mildew, then the Container shall be labeled with the following statement: “The Medical Marijuana Concentrate contained within this package has not been tested for contaminants.” Except that when an Optional Premises Cultivation Operation or a Medical Marijuana-Infused Products Manufacturer has successfully validated its process regarding contaminants pursuant to rule M 1501, then the Container instead shall be labeled with the following statement: “The Medical Marijuana Concentrate contained within this package complies with the mandatory contaminant testing required by rule M 1501.”
  7. When All Required Contaminant Tests Are Performed and Passed.
  8. Solvent-Based Medical Marijuana Concentrate. If a Medical Marijuana Testing Facility tested a Production Batch of Solvent-Based Medical Marijuana Concentrate for residual solvents, mold, and mildew, and the required test(s) passed, then the Container shall be labeled with the following statement: “The Medical Marijuana Concentrate contained within this package complies with the mandatory contaminant testing required by rule M 1501.”
  9. Food- and Water-Based Medical Marijuana Concentrate. If a Medical Marijuana Testing Facility tested a Production Batch for microbials, mold, and mildew, and the required test(s) passed, then the Container shall be labeled with the following statement: “The Medical Marijuana Concentrate contained within this package complies with the mandatory contaminant testing required by rule M 1501.”
  10. Nothing in this rule permits a Medical Marijuana Business to transfer, wholesale, or sell Medical Marijuana Concentrate that has failed contaminant testing and has not subsequently passed the additional contaminant testing required by rule M 1507(B).

For more information, please refer to both the Colorado Retail Marijuana Code, which includes additional guidelines for shipping containers, contaminant and potency testing, and more, as well as Colorado’s Packaging & Labeling Requirements For Retail Marijuana for Consumer Protection and Child Safety.”

Back to top

CONNECTICUT CANNABIS LABELING REQUIREMENTS

Notice the extreme difference in length between Colorado and Connecticut’s MJ label guidelines?

Even more peculiar is Connecticut’s absolutely bizarre FIRST guideline: “A producer shall individually package, label, and seal marijuana products in unit sizes such that no single unit contains more than a one-month supply of marijuana.”

The reason why this strikes us as very strange, is that Connecticut’s government has some nebulous idea of what a one-month supply of marijuana actually is but never defines it in terms of size, and especially weight, for all the different “marijuana products” out there! And what exactly is Connecticut’s idea of a “unit” anyway?

From these extremely large brush strokes, Connecticut’s guidelines share and include the basic specific guidelines with most other legalized medical marijuana states until near the bottom where it demonstrates quite a high level of sophistication:

“A producer shall label each marijuana product prior to sale to a dispensary and shall securely affix to the package a label that states in legible English…(7) A terpenes profile and a list of all active ingredients, including:

  • (A) tetrahydrocannabinol (THC);
  • (B) tetrahydrocannabinol acid (THCA);
  • (C) cannabidiol (CBD); (D) cannabidiolic acid (CBDA); and

(E) any other active ingredient that constitute at least 1% of the marijuana batch used in the product.”

We applaud Connecticut’s sophistication in writing this specific guide for several reasons:

*Just recently has it been scientifically demonstrated that terpenes go way beyond just determining the aroma and flavor of any specific plant, and through their synergistic relationship with the other medicinal and psycho-active ingredients of cannabis makes the specific strain more potent in flower form. When it comes to CBD and THC extract oils, more or less terpenes can be added for a desired medicinal effect.

*And second, Connecticut’s inclusion of the not only commonly known THC and CBD, but their closely related cannabinoids THCA and CBDA, which are recent discoveries to medical studies of cannabis effects now permitted in legalized states. THCA for example is a cannabinoid that has significant medicinal effects when taken raw, but is actually destroyed by heating.

“Connecticut’s cannabis labeling and packaging guidelines come from Sec. 21a-408-56 of its regulations:

  • A producer shall individually package, label, and seal marijuana products in unit sizes such that no single unit contains more than a one-month supply of marijuana.
  • A producer shall place any product containing marijuana in a child-resistant and light-resistant package.
  • A producer shall label each marijuana product prior to sale to a dispensary and shall securely affix to the package a label that states in legible English:
    • (1) The name and address of the producer;
    • (2) The brand name of the marijuana product that was registered with the department;
    • (3) A unique serial number that will match the product with a producer batch and lot number so as to facilitate any warnings or recalls the department or producer deem appropriate;
    • (4) The date of final testing and packaging;
    • (5) The expiration date;
    • (6) The quantity of marijuana contained therein;
    • (7) A terpenes profile and a list of all active ingredients, including:
      • (A) tetrahydrocannabinol (THC);
      • (B) tetrahydrocannabinol acid (THCA);
      • (C) cannabidiol (CBD); (D) cannabidiolic acid (CBDA); and
      • (E) any other active ingredient that constitute at least 1% of the marijuana batch used in the product.
    • (8) A pass or fail rating based on the laboratory’s microbiological, mycotoxins, heavy metals, and chemical residue analysis.

For more information, please refer to the State of Connecticut Regulation of the Department of Consumer Protection Concerning Palliative Use of Marijuana.”

DELAWARE CANNABIS LABELING REQUIREMENTS

Delaware may be the second smallest state in the mainland USA, but it also has the second smallest set of medical marijuana guidelines as well. Concise and to the point, Delaware’s guidelines might, in a perfect world, be a model to all the other states in the Union:

“Delaware’s cannabis labeling and packaging guidelines include a description of the packaging of the useable marijuana that the compassion center shall be utilizing which shall, a minimum, include:

  • The name of the strain, batch, and quantity;
  • The statement “this product is for medical use only, not for resale;”
  • Details indicating
    • (1) the medical marijuana is free of contaminants, and
    • (2) the levels of active ingredients in the product.

For more information, please refer to 4470 State of Delaware Medical Marijuana Code.”

DISTRICT OF COLUMBIA CANNABIS LABELING REQUIREMENTS

Similar to all other legalized medical marijuana states, District of Columbia medical marijuana labels specify that all MMJ product packages must be tamper-proof, child-proof, and within accordance of their local laws.

What makes Washington D.C. unique is the “personal” and business amount of information that must be added at the point of purchase to each packaging label. The personal information required includes:

*The name of the cultivation center where the medical marijuana was produced;

*The name of the dispensary where the medical marijuana was dispensed;

*The name of the recommending physician;

*The dispensing date that the medical marijuana was transferred to the qualified patient or caregiver;

*The qualifying patient’s name and registration card number:

“Washington D.C.’s cannabis labeling and packaging guidelines state that no medical marijuana shall be dispensed or distributed to a qualifying patient or caregiver unless the container in which it is distributed bears a legible label, firmly affixed, stating the following information:

  • (a) The name of the cultivation center where the medical marijuana was produced;
  • (b) The name of the dispensary where the medical marijuana was dispensed;
  • (c) The quantity of medical marijuana contained within;
  • (d) The cannabinoid profile of the medical marijuana contained within, including the THC level;
  • (e) Any other ingredient or ingredients besides medical marijuana contained within;
  • (f) The name of the recommending physician;
  • (g) The dispensing date that the medical marijuana was transferred to the qualified patient or caregiver;
  • (h) The qualifying patient’s name and registration card number; and
  • (i) A statement that the product is for medical use and not for resale or transfer to another person.

For more information, please refer to the D.C. Municipal Regulations and D.C. Register.”

HAWAII CANNABIS LABELING REQUIREMENTS

The unique aspect about Hawaii to most Americans, is that although they consider Hawaii as just another state in the Union, Americans also consider Hawaii as an exotic foreign destination “holiday country”. Hawaii is unique for the colorful nature of its traditional Polynesian inhabitants.

The medical marijuana labeling for this state by law however, makes it one of the least colorful as far as the packaging of MMJ product packaging and on some of its labeling, while being vividly colorful on newer versions of the MMJ labels themselves: “Uses only black lettering on a white background with no pictures or graphics”

Another distinction of Hawaii’s MMJ labeling is its “hyper” concern with dosages. Hawaii takes the term “medical” marijuana very seriously. But in doing so, it purposely confuses the fact that flower buds and extracts are still herbal natural remedies and not pharmaceutical chemically concocted drugs. Each specific package label must clearly state the dosage, even within smaller sized individualized dosage packaging models of dispensing. This must make it confusingly nightmarish for MMJ packaging companies as well as imposing a dampening emotional effect for consumers used to the exciting, colorful nature of “the herbbefore it was legalized.

Even more ironic, is that the whole concept of “buds” produced by the non-fertilized flowers of female cannabis plants actually originated in Hawaii with the term, “Sensimilla”. For people buying it on the mainland, it was extremely expensive and everyone first thought it was a “super strain” of cannabis. But it wasn’t actually the strain that made it special.

The way it was popularized in the “old school Cheech and Chong” days as a highly concentrated type of “SUPER-cannabis” which earned the nick-name, “Hawaiian” or “Sensi” made it a smash sensation. The Hawaiians couldn’t keep their secret for long and eventually people realized that it wasn’t the specific strain that mattered, but the way it was grown…

Back in the 60’s, 70’s and early 1980’s, unlike other sources of cannabis which was imported (smuggled) from the fields of Mexico and Columbia, sensimilla contained no seeds! Sensimilla refers to, “many strains of marijuana where the female plant is only allowed to produce flowers, but is left unfertilized (by the male cannabis plants) so it does not progress on to develop seeds. After the illegal growers in California discovered this concept, it became the norm for all the gro-opts both illegal and licensed, we know today:

Hawaii’s cannabis labeling and packaging guidelines come from Chapter 32D – Medical Marijuana Dispensary System:

  • Advertising and packaging. (a) The department shall establish standards regarding the advertising and packaging of marijuana and manufactured marijuana products; provided that the standards, at a minimum, shall require the use of packaging that:
    • Is child-resistant and opaque so that the product cannot be seen from outside the packaging;
    • Uses only black lettering on a white background with no pictures or graphics;
    • Is clearly labeled with the phrase “For medical use only”;
    • Is clearly labeled with the phrase “Not for resale or transfer to another person”;
    • Includes instructions for use and “use by date”;
    • Contains information about the contents and potency of the product;
    • Includes the name of the production center where marijuana in the product was produced, including the batch number and date of packaging:
    • Includes a barcode generated by tracking software; and
    • In the case of a manufactured marijuana product, a listing of the equivalent physical weight of the marijuana used to manufacture the amount of product that is within the packaging, pursuant to section 329D-9©
      1. Any capsule, lozenge, or pill containing marijuana or its principal psychoactive constituent tetrahydrocannabinol shall be packaged so that one dose, serving or single wrapped item contains no more than ten milligrams of tetrahydrocannabinol; provided that no manufactured marijuana product that is sold in a pack of multiple doses, servings, or single wrapped items, nor any containers of oils, shall contain more than a total of one hundred milligrams of tetrahydrocannabinol per pack or container.

For more information, please refer to Chapter 32D – Medical Marijuana Dispensary System.”

ILLINOIS CANNABIS LABELING REQUIREMENTS

Illinois decided to make its MMJ label guidelines long and detailed apparently modelling fore-running states that believed that licensing and taxing it would make MMJ more valuable than it really is—especially when you can grow it yourself. For example, this quote taken from the Illinois guidelines below says it all: “B) The acceptable tolerances for the minimum percentage printed on the label for any of subsections (d)(8)(A)(i) through (iv) shall not be below 85% or above 115% of the labeled amount”. What?

A small detail that makes Illinois unique is that Illinois specifies that the cannabis packaging be light-resistant:

“c) Packaging of any product containing cannabis shall be child-resistant and light-resistant consistent with current standards, including the Consumer Product Safety Commission standards referenced by the Poison Prevention Act.” The strange thing about this detail is that light by itself normally does not have any detrimental effect on MMJ.

“Illinois’ cannabis labeling and packaging guidelines include the following:

  • Each cannabis product produced for sale shall be registered with the Department on forms provided by the Department.
  • a) Each product registration shall include a label and the required registration fee (Section 1000.140). The registration fee is for the name of the product offered for sale, and one fee shall be sufficient for all package sizes.
  • b) All harvested cannabis intended for distribution to a dispensing organization must be packaged in a sealed and labeled medical cannabis container.
  • c) Packaging of any product containing cannabis shall be child-resistant and light-resistant consistent with current standards, including the Consumer Product Safety Commission standards referenced by the Poison Prevention Act.
  • d) Each cannabis product shall be labeled by the cultivation center prior to sale to a dispensary, and each label shall be securely affixed to the package and shall state in legible English:
    • 1) The name and P.O. Box of the registered cultivation center where the item was manufactured;
    • 2) The common or usual name of the item and the registered name of the cannabis product that was registered with the Department pursuant to subsection (a);
    • 3) A unique serial number that will match the product with a producer batch and lot number to facilitate any warnings or recalls the Department or producer deems appropriate;
    • 4) The date of final testing and packaging, if sampled, and the identification of the independent testing laboratory;
    • 5) The date of manufacture and “use by” date;
    • 6) The quantity (in ounces or grams) of cannabis contained in the product;
    • 7) A pass/fail rating based on the laboratory’s microbiological, mycotoxins, and pesticide and solvent residue analyses, if sampled;
    • 8) Content List
      • A) A list of the following, including the minimum and maximum percentage content by weight for subsections (d)(8)(A)(i) through (iv):
        • i) delta-9-tetrahydrocannabinol (THC);
        • ii) tetrahydrocannabinolic acid (THCA);
        • iii) cannabidiol (CBD);
        • iv) cannabidiolic acid (CBDA); and
        • v) any other ingredients besides cannabis.
      • B) The acceptable tolerances for the minimum percentage printed on the label for any of subsections (d)(8)(A)(i) through (iv) shall not be below 85% or above 115% of the labeled amount;
    • 9) A statement that the product is for medical use and not for resale or transfer to another person.

For more information, please refer to the General Provisions for the Compassionate Use of Medical Cannabis Pilot Act.”

MAINE CANNABIS LABELING REQUIREMENTS

Almost long gone are the days when you could just call up your favorite dealer and get your buds without all the red-tape. Its all the red tape in fact that is making many pot smokers stick with their favorite dealer. On the other hand, many Baby Boomers who’ve been too afraid to try cannabis before, find all the labeling regulations ensure they are getting their money’s worth even though they know that a large chunk of what they pay legally is now going to taxes.

The distinction of Illinois is that this state really tries to let consumers know where their taxes are going in extracts at least. If you’re legally buying cannabis extracts in Maine, you can at least be reassured the extracts you’re buying are “clean” because Maine has a label guideline that specifies what solvents are used in the making of cannabis extract oils and specifies the that the label must show exactly how many grams of concentrates you’re buying and what’s actually in them:

“Maine’s medical cannabis labels on prepared marijuana and goods containing marijuana that are sold by dispensaries and caregivers are used as evidence of compliance with the law that limits possession and dispensing to 2.5 ounces of prepared marijuana per qualifying patient. The packaging and labeling of prepared marijuana and marijuana products for sale by registered dispensaries and caregivers must comply with applicable State labeling laws. See 22 M.R.S.A. §2157.

  1. Labeling requirements.
  2. Required labeling: Adult use marijuana and adult use marijuana products must be labeled with the following information:
  3. The license number of the cultivation facility, the products manufacturing facility, and the marijuana store where the adult use marijuana or marijuana product was cultivated, manufactured if applicable, and offered for sale.
  4. An identity statement, a universal symbol and warning labels;
  5. The batch number;
  6. A net weight statement;
  7. Information on the THC potency of the adult use marijuana products and the potency of other such cannabinoids or other chemicals in the marijuana or marijuana products, including, but not limited to, cannabidiol;
  8. Information on the amount of THC and cannabidiol per serving of the adult use marijuana or marijuana products, and for edibles, the number of servings per package;
  9. Information on gases and solvents used in marijuana extraction;
  10. For adult use marijuana products, the amount of marijuana concentrate per serving, as measured in grams, and the amount of marijuana concentrate per package, as measured in grams, a list of ingredients and possible allergens, and a recommended use date or expiration date.
  11. For edible marijuana products, a nutritional fact panel;
  12. Instructions on usage; and
  13. Any other information requried by the department by rule.
  14. Packaging requirements 
  15. Required packaging. Adult use marijuana and adult use marijuana products must be packaged in the following manner:
  16. Adult use marijuana must be prepackaged in child-resistant and tamper-evident packaging, or must be placed in a child-resistant or tamper-evident exit packaging at the point of sale.
  17. Packaging for multi-serving liquid adult use marijuana products must include an integral measurement component and a child-resistant cap;
  18. Packaging must conform to all other applicable standards and requirements adopted by rule by the department.
  19. Labeling and packaging prohibitions
  20. Trademarks. Violates a federal trademark law or regulation or would cause a reasonable consumer confusion as to whether the marijuana or marijuana product was a trademarked product;
  21. Appeal to persons under 21. Is designed to appeal to a person under 21 years of age.
  22. False or deceptive labeling. Obscure identifying information on the label or uses a false or deceptive label.
  23. Rules. Violates any other labeling, packaging or health and safety requirement or prohibition imposed by the department.

For more information, please refer to Recreational Marijuana in Maine and  Rules Governing the Maine Medical Use of Marijuana Program

MARYLAND CANNABIS LABELING REQUIREMENTS

In many states dispensaries can legally fill orders in their own packaging according to what their customers have ordered. In Maryland its the complete opposite, and as you’ll see directly below, all cannabis items must be individually packaged and labeled at the point of processing.

Apparently, Maryland is still hedging on the fact that legally grown marijuana is a safe herbal medicine because all cannabis labels in Maryland must include the Maryland Poison Control Center emergency telephone number!

“Maryland’s cannabis labeling and packaging guidelines include the following:

Packaging of Medical Cannabis Finished Product

  1. All items shall be individually packaged at the original point of processing.
  2. Packaging Requirements. A package of medical cannabis finished product shall:

(1) Be plain;
(2) Be opaque;
(3) Be tamper-evident, and if applicable or appropriate, child-resistant;
(4) Bear a finished-product lot number and an expiration date;
(5) Bear a clear warning that:

(a) The contents may be lawfully consumed only by a qualifying patient named on an attached label;
(b) It is a illegal for any person to possess or consume the contents of the package other than the qualifying patient; and
(c) It is a illegal to transfer the package or contents to any person other than a transfer by a caregiver to a qualifying patient;

(6) Bear a clear warning to keep the package and its contents away from children other than a qualifying patient;
(7) Bear the Maryland Poison Control Center emergency telephone number;
(8) Bear the name of the licensee that packaged the medical cannabis finished product and the telephone number of the licensee for reporting an adverse patient event;
(9) Bear any allergen warning required by law;
(10) Bear a listing of the non-medical cannabis ingredients;
(11) Bear an itemization, including weight, of all cannabinoid and terpene ingredients specified for the product, and concentrates of any cannabinoid of less than one percent shall be printed with a leading zero before the decimal point; and
(12) Leave space for a licensed dispensary to attach a personalized label for the qualifying patient.

  1. Packaging Prohibitions. A package of medical cannabis finished product may not bear any:

(1) Resemblance to the trademarked, characteristic or product-specialized packaging of any commercially available candy, snack, baked good or beverage;
(2) Statement, artwork or design that could reasonably mislead any person to believe that the package contains anything other a medical cannabis finished product;
(3) Seal, flag, crest, coat of arms, or other insignia that could reasonably mislead any person to believe that the product has been endorsed, manufactured, or used by any State, county or municipality or any agency thereof; and
(4) Cartoon, color scheme, image, graphic or feature that might make the package attractive to children.

Label for Distribution to a Qualifying Patient

  1. A licensee shall print a label for a package of medical cannabis for a qualifying patient in English in letters no less than one-sixteenth of an inch high. If requested by a qualifying patient or caregiver, the licensee may also print a label in another language.
    B. A licensee may not distribute a package of medical cannabis without a label securely attached.
    C. A licensee shall state on a label of a package of medical cannabis:

(1) The name of the qualifying patient;
(2) The name of the certifying physician;
(3) The name of the licensee where the product was dispensed;
(4) The date that the medical cannabis was dispensed;
(5) The name of the product;
(6) The strength of applicable cannabinoid and terpene compounds:

(a) Displayed in units appropriate to the dosage form; and
(b) Concentrations of any cannabinoid of less than one percent shall be printed with a leading zero before the decimal point;

(7) The quantity of medical cannabis dispensed, displayed in units appropriate to the dosage form;
(8) Any directions for use of the product; and
(9) The instructions for proper storage or handling of the product.

  1. Any other information required by the dispensary at its discretion may be provided in a patient insert.
  2. The label may not:

(1) Contain any false or misleading statement or design; or
(2) Include any statement, image or design that may not be included on the package.

For more information, please refer to the Subtitle 62 of the Maryland Department of Health & Mental Hygiene.”

MASSACHUSETTS CANNABIS LABELING REQUIREMENTS

Laws, regulations and guidelines one would assume, should leave nothing up to the imagination. It appears however that the state of Massachusetts doesn’t agree when it came to writing its own state MMJ (Medical Marijuana) labeling guidelines. Massachusetts seems to believe that using “initialisms” is perfectly OK to confuse an already confusing set of guidelines.

Many people aren’t even aware what an “initialism” is—we sure didn’t!

An initialism is not an ACRONYM. An acronym is a set of letters printed in CAPITAL letters that make a word, but the individual letters in the word actually stand for other individual words. Here’s an example of an acronym used in a sentence:  “To grow marijuana illegally, you’ve got to be BAD.”

BAD is the acronym. When broken down here’s what the letters stand for:

B-Balls

A-Attitude

D-Direction

An initialism works differently. The letters in an initialism are pronounced by saying each letter of the word individually: MMJ is an initialism, and even though most people who are into cannabis know what it means, its actually a tough one because this initialism only stands for 2 words while it uses 3 initials like this: Medical Mari-J-uana!

Massachusetts uses 5 initialisms and here’s what they stand for:

  1. RMD- “Registered Marijuana Dispensary”
  2. MIPs- “Marijuana-Infused Products”
  3. CMR- Code of Massachusetts Regulations
  4. FDA- Food and Drug Administration
  5. THC-TetraHydroCannabinol

“Massachusetts’ cannabis labeling and packaging guidelines include the following:

  • (E) Packaging and Labeling
    • (1) Marijuana shall be packaged in plain, opaque, tamper-proof, and child-proof containers without depictions of the product, cartoons, or images other than the RMD’s logo. Edible MIPs shall not bear a reasonable resemblance to any product available for consumption as a commercially available candy.
    • (2) Labeling of Marijuana (Excluding MIPs). The RMD shall place a legible, firmly affixed label on which the wording is no less than 1/16 inch in size on each package of marijuana that it prepares for dispensing, containing at a minimum the following information:
      • (a) The registered qualifying patient’s name;
      • (b) The name and registration number of the RMD that produced the marijuana, together with the RMD’s telephone number and mailing address, and website information, if any;
      • (c) The quantity of usable marijuana contained within the package;
      • (d) The date that the RMD packaged the contents;
      • (e) A batch number, sequential serial number, and bar code when used, to identify the batch associated with manufacturing and processing;
      • (f) The cannabinoid profile of the marijuana contained within the package, including THC level;
      • (g) A statement that the product has been tested for contaminants, that there were no adverse findings, and the date of testing in accordance with 105 CMR 725.105(C)(2); and
      • (h) This statement, including capitalization: “This product has not been analyzed or approved by the FDA. There is limited information on the side effects of using this product, and there may be associated health risks. Do not drive or operate machinery when under the influence of this product. KEEP THIS PRODUCT AWAY FROM CHILDREN.”
    • (3) Labeling of MIPs. The RMD shall place a legible, firmly affixed label on which the wording is no less than 1/16 inch in size on each MIP that it prepares for dispensing, containing at a minimum the following information:
      • (a) The registered qualifying patient’s name;
      • (b) The name and registration number of the RMD that produced the MIP, together with the RMD’s telephone number and mailing address, and website information, if any;
      • (c) The name of the product;
      • (d) The quantity of usable marijuana contained within the product as measured in ounces;
      • (e) A list of ingredients, including the cannabinoid profile of the marijuana contained within the product, including the THC level;
      • (f) The date of product creation and the recommended “use by” or expiration date;
      • (g) A batch number, sequential serial number, and bar code when used, to identify the batch associated with manufacturing and processing;
      • (h) Directions for use of the product if relevant;
      • (i) A statement that the product has been tested for contaminants, that there were no adverse findings, and the date of testing in accordance with 105 CMR 725.105(C)(2);
      • (j) A warning if nuts or other known allergens are contained in the product; and
      • (k) This statement, including capitalization: “This product has not been analyzed or approved by the FDA. There is limited information on the side effects of using this product, and there may be associated health risks. Do not drive or operate machinery when under the influence of this product. KEEP THIS PRODUCT AWAY FROM CHILDREN.”

For more information, please refer to the Implementation of an Act for the Humanitarian Medical Use of Marijuana.”

MICHIGAN CANNABIS LABELING REQUIREMENTS

Are you ready for a laugh? As you can see, the state of Michigan uses 5 different types of MMJ labels, yet it has no guidelines for cannabis labeling and packaging requirements:

“Michigan currently has no cannabis labeling and packaging requirements.

For more information, please refer to the .Michigan Medical Marihuana Program

MINNESOTA CANNABIS LABELING REQUIREMENTS

Minnesota has 12 different facts that MUST be included on every medical marijuana label:

  • (1) the patient’s registry identification number, name, and date of birth;
  • (2) the name and date of birth of the designated registered caregiver, if applicable;
  • (3) the name of the patient’s parent or legal guardian, if listed on the registry verification, if applicable;
  • (4) the patient’s address;
  • (5) the name and address of the medical cannabis manufacturer where the medical cannabis was manufactured;
  • (6) the medical cannabis’s chemical composition;
  • (7) the recommended dosage;
  • (8) directions for use of the product;
  • (9) all ingredients of the product shown with common or usual names, including any colors, artificial flavors, and preservatives, listed in descending order by predominance of weight;
  • (10) the date of manufacture and batch number;
  • (11) a notice with the statement, including capitalization: “This product has not been analyzed or approved by the United States Food and Drug Administration. There is limited information on the side effects of using this product, and there may be associated health risks. Do not drive or operate heavy machinery when under the influence of this product. KEEP THIS PRODUCT OUT OF REACH OF CHILDREN.”; and
  • (12) a notice with the statement: “This medical cannabis is for therapeutic use only. Diversion of this product is unlawful and may result in the revocation of the patient’s registration.”

 

If you’re wondering how it is physically possible to put so much information on one tiny label where it can be read easily without squinting, there’s only a few high-quality printers that can do the job…especially if you’re looking for an in-house printing system. At Arrow Systems we sell state-of-the-art in-house printing systems that will meet any state’s labeling guidelines. For more information, give us a call at 1 716-285-2974.

 

“Minnesota’s cannabis labeling and packaging guidelines include the following:

  • 0850 PACKAGING AND LABELING. Subpart 1. Medical cannabis packaging. The medical cannabis manufacturer must package all medical cannabis intended for distribution according to the following standards:
  • In addition to the requirements in Minnesota Statutes, section 152.29, subdivision 3, paragraph (c), clause (5), medical cannabis containers must be:
    • (1) plain;
    • (2) designed to maximize the shelf life of contained medical cannabis;
    • (3) tamper-evident; and
    • (4) child-resistant.
  • Medical cannabis packaging must not bear a reasonable resemblance to any commercially available product.
  • Medical cannabis packaging must be packaged to minimize its appeal to children and must not depict images other than the medical cannabis manufacturer’s business name logo. Subp. 2. Medical cannabis trade names. The medical cannabis manufacturer’s medical cannabis trade names must comply with the following standards and are subject to approval by the commissioner:
    • names that are limited to those that clearly reflect the product’s medical cannabis nature;
    • any name that is identical to, or confusingly similar to, the name of an existing non-cannabis product is prohibited;
    • any name that is identical to, or confusingly similar to, the name of an unlawful product or substance is prohibited; and
    • any name that contains language that suggests using medical cannabis for recreational purposes or for a condition other than a qualifying medical condition is prohibited. Subp. 3. Labeling. A. A medical cannabis manufacturer must ensure that all medical cannabis that is distributed is labeled with the following information:
      • (1) the patient’s registry identification number, name, and date of birth;
      • (2) the name and date of birth of the designated registered caregiver, if applicable;
      • (3) the name of the patient’s parent or legal guardian, if listed on the registry verification, if applicable;
      • (4) the patient’s address;
      • (5) the name and address of the medical cannabis manufacturer where the medical cannabis was manufactured;
      • (6) the medical cannabis’s chemical composition;
      • (7) the recommended dosage;
      • (8) directions for use of the product;
      • (9) all ingredients of the product shown with common or usual names, including any colors, artificial flavors, and preservatives, listed in descending order by predominance of weight;
      • (10) the date of manufacture and batch number;
      • (11) a notice with the statement, including capitalization: “This product has not been analyzed or approved by the United States Food and Drug Administration. There is limited information on the side effects of using this product, and there may be associated health risks. Do not drive or operate heavy machinery when under the influence of this product. KEEP THIS PRODUCT OUT OF REACH OF CHILDREN.”; and
      • (12) a notice with the statement: “This medical cannabis is for therapeutic use only. Diversion of this product is unlawful and may result in the revocation of the patient’s registration.”
    • Labeling text must not include any false or misleading statements regarding health or physical benefits to the patient.
    • A package may contain multiple labels if the information required by this part is not obstructed.

For more information, please refer to the Minnesota Revisor of Statutes on Packaging and Labeling.

MONTANA CANNABIS LABELING REQUIREMENTS

Just like Michigan, Montana has no guidelines in place, but is working on it!

If you’re in any one of these two states, just use the medical marijuana labels they have in place, pick the one that is most “compliant”  and print out small label batches as you need them until the new compliance labeling guidelines are written into law.

The problem with this strategy however, is that most printing companies won’t take label orders for tiny, sporadic batches at a time. The perfect way around this hang-up is to buy your own in-house label printing system. Call the friendly folks at Arrow Systems for more information on how to set up your own convenient and very affordable in-house label printing operation: 1 716-285-2974.

“Montana’s packaging and labeling laws have been amended.

For more information, please refer to Montana’s Department of Public Health and Human Services Notice No. 37-820.”

NEVADA CANNABIS LABELING REQUIREMENTS

Nevada must be applauded for having the most concise set of medical marijuana labeling guidelines in The United States without being overly lengthy or being weighed down with meaningless details. Written in plain English so any layman with a grade 8 education can understand, Nevada has included 3 novel and very relevant points of interest in its guidelines.

The first one centers around the issue of “organically grown”. An overwhelming majority of MMJ patients are educated to the fact that the MMJ they are consuming as medicine SHOULD NOT be contaminated with chemical fertilizers or pesticides. What’s the point in calling a cannabis product “medical” when it could be toxic to human health by the way its grown?

Yet many unscrupulous growers do just that! Nevada is the only state we’ve found so far that has, “put its foot down” and tried to eliminate this nonsense by insisting in its guidelines that if a cannabis product claims to be organically grown, the company growing it must prove it right on its labeling:NAC 453A.504  Labeling as “organic.” (NRS 453A.370)  A cultivation facility or facility for the production of edible marijuana products or marijuana-infused products shall not label usable marijuana, edible marijuana products or marijuana-infused products as “organic” unless the marijuana plants used are produced, processed and certified in a manner that is consistent with the national organic standards established by the United States Department of Agriculture in accordance with the Organic Foods Production Act of 1990.

And speaking of labeling, the second thing Nevada has accomplished that no other state has dared to, is that Nevada has gone the extra mile to clearly define in every crucial area that labels must outline, how the labels should actually look like. You’ll be able to see below that each important area of the labeling is set up with a clear example.

The third thing Nevada has done to distinguish itself is to define, “Potentially hazardous marijuana products and ingredients”. So many edible products and concentrates on the MMJ market today are full of junk the way so much processed foods are these days. Nevada clearly lists all types of gunk that MUST NOT be in edibles and concentrates like, animal by-products for example.

“Nevada’s cannabis labeling and packaging guidelines include the following:

   NAC 453A.500  Packaging: Generally. (NRS 453A.370)

1.  Any product containing marijuana must be packaged in child-resistant packaging in accordance with 16 C.F.R. § 1700 or the standards specified in subsection 2 or 3.

2.  Except as otherwise provided in subsection 3, marijuana-infused products in solid or liquid form must be packaged in plastic which is 4 millimeters or more in thickness and must be heat-sealed without an easy-open tab, dimple, corner or flap so that it is difficult for a child to open and as a tamperproof measure.

3.  Marijuana-infused products in liquid form may be sealed using a metal crown cork-style bottle cap.

4.  Any container or packaging containing usable marijuana, edible marijuana products or marijuana-infused products must protect the contents from contamination and must not impart any toxic or deleterious substance to the usable marijuana or marijuana product.

(Added to NAC by Div. of Pub. & Behavioral Health by R004-14, 3-28-2014, eff. 4-1-2014)

      NAC 453A.502  Labeling: Generally. (NRS 453A.370)  Each cultivation facility, facility for the production of edible marijuana products or marijuana-infused products and medical marijuana dispensary shall:

1.  Use for labeling all marijuana, edible marijuana products and marijuana-infused products the standard label described in NAC 453A.506 to 453A.512, inclusive;

2.  Exercise strict control over labeling materials issued for use in labeling operations for marijuana, edible marijuana products and marijuana-infused products;

3.  Carefully examine labeling materials issued for a batch for identity and conformity to the labeling specified in the applicable production or control records; and

4.  Have and follow written procedures describing in sufficient detail the control procedures employed for the issuance of labeling.

(Added to NAC by Div. of Pub. & Behavioral Health by R004-14, 3-28-2014, eff. 4-1-2014)

      NAC 453A.504  Labeling as “organic.” (NRS 453A.370)  A cultivation facility or facility for the production of edible marijuana products or marijuana-infused products shall not label usable marijuana, edible marijuana products or marijuana-infused products as “organic” unless the marijuana plants used are produced, processed and certified in a manner that is consistent with the national organic standards established by the United States Department of Agriculture in accordance with the Organic Foods Production Act of 1990.

(Added to NAC by Div. of Pub. & Behavioral Health by R004-14, 3-28-2014, eff. 4-1-2014)

      NAC 453A.506  Maximum unit size; minimum requirements for font and size of label. (NRS 453A.370)

1.  Any medical marijuana establishment that packages marijuana, edible marijuana products or marijuana-infused products must individually package, label and seal the marijuana or marijuana products in unit sizes such that no single unit contains more than a 2 1/2 ounce supply of marijuana.

2.  For marijuana, edible marijuana products or marijuana-infused products that are intended to be dispensed or sold to a holder of a valid registry identification card or his or her designated primary caregiver:

(a) The text used on all labeling must be printed in at least 10-point font and may not be in italics; and

(b) Each label must be at least 2 3/4 inches high by 4 inches wide.

(Added to NAC by Div. of Pub. & Behavioral Health by R004-14, 3-28-2014, eff. 4-1-2014)

      NAC 453A.508  Labeling requirements for marijuana and related products for sale to medical marijuana dispensary. (NRS 453A.370)

1.  A cultivation facility or facility for the production of edible marijuana products or marijuana-infused products shall label all marijuana, edible marijuana products and marijuana-infused products before it sells the marijuana or marijuana products to a medical marijuana dispensary and shall securely affix to the package a label that includes, without limitation, in legible English:

(a) The name of the medical marijuana establishment and its medical marijuana establishment registration certificate number;

(b) The lot number;

(c) The date of harvest;

(d) The date of final testing;

(e) The date on which the product was packaged;

(f) The cannabinoid profile and potency levels and terpinoid profile as determined by the independent testing laboratory;

(g) If the product is perishable, the expiration date; and

(h) The quantity of marijuana being sold.

2.  The label required by subsection 1 for a container or package containing usable marijuana, edible marijuana products or marijuana-infused products sold by a cultivation facility or facility for the production of edible marijuana products or marijuana-infused products must be in substantially the following form:

JT’S NURSERY

Certificate Number: 123 456 789 001 0001

Lot Number:

1234

Harvested on:

01/01/2013

Final Testing Date: 01/15/2013

Packaged on: 01/17/2013

Best if used by: March 17, 2013

16.7% THC   1.5% CBD   0.3% CBN

Myrcene 5.6 mg/g   Limonene 5.1 mg/g   Valencene 3.5 mg/g

Net Weight: 2 lbs.

(Added to NAC by Div. of Pub. & Behavioral Health by R004-14, 3-28-2014, eff. 4-1-2014)

      NAC 453A.510  Labeling requirements for usable marijuana sold at retail; accompanying materials. (NRS 453A.370)

  1. A medical marijuana dispensary must affix to each container or package containing usable marijuana sold at retail a label which must include, without limitation:

Adopted Regulation R148-15

(a) The business or trade name and the medical marijuana establishment registration certificate number of the cultivation facility that cultivated and sold the usable marijuana.

(b) The lot number.

(c) The date and quantity dispensed, including the net weight measured in ounces and grams or by volume, as appropriate.

(d) The name and registry identification card number of the patient and, if applicable, the name of his or her designated primary caregiver, or, if the patient holds a letter of approval, the name of the patient and the name and number of the registry identification card of his or her designated primary caregiver.

(e) The name and address of the medical marijuana dispensary.

(f) The cannabinoid profile and potency levels and terpenoid profile as determined by the independent testing laboratory, which may include the potential total THC but shall not include any other calculated level of THC.

(g) A warning that states: “This product may have intoxicating effects and may be habit forming.”

(h) The statement: “This product may be unlawful outside of the State of Nevada.”

(i) The date on which the marijuana was harvested.

  1. The label required by subsection 1 for a container or package containing usable marijuana sold at retail must be in substantially the following form:
Joe’s Plant Emporium                         Cert.#: 123 456 789 001 0001

Lot#: 1234                                                       Harvested: 01/01/2013

Dispensed to: John J. Smith  #1234987 on 11/27/2013

by

We Care Dispensary

123 Main Street, Carson City, NV 89701

WARNING:

This product may have intoxicating effects

and may be habit forming.

16.7% THC   1.5% CBD   0.3% CBN

Myrcene 5.6 mg/g   Limonene 5.1 mg/g   Valencene 3.5 mg/g

Net Weight: .25 ounces (7 grams)

This product may be unlawful outside the State of Nevada.

3.  A medical marijuana dispensary must provide with all usable marijuana sold at retail accompanying material that discloses any pesticides applied to the marijuana plants and growing medium during production and processing and contains the following warnings:

(a) “Warning: This product may have intoxicating effects and may be habit forming. Smoking is hazardous to your health.”

(b) “There may be health risks associated with consumption of this product.”

(c) “Should not be used by women who are pregnant or breast feeding.”

(d) “For use only by the person named on the label of the dispensed product. Keep out of the reach of children.”

(e) “Marijuana can impair concentration, coordination and judgment. Do not operate a vehicle or machinery under the influence of this drug.”

4.  The text used on all accompanying material must be printed in at least 12-point font and may not be in italics.

(Added to NAC by Div. of Pub. & Behavioral Health by R004-14, 3-28-2014, eff. 4-1-2014)

      NAC 453A.512  Labeling requirements for edible marijuana products or marijuana-infused products sold at retail; accompanying materials. (NRS 453A.370)

1.  A medical marijuana dispensary must affix to each container or package containing edible marijuana products or marijuana-infused products sold at retail a label which must include, without limitation:

(a) The business or trade name and the medical marijuana establishment registration certificate number of the facility for the production of edible marijuana products or marijuana-infused products that manufactured and sold the product.

(b) The lot numbers of all marijuana used to create the product.

(c) The batch number of the product.

(d) The date and quantity dispensed, including the net weight in ounces and grams or by volume, as appropriate.

(e) The name and registry identification card number of the patient and, if applicable, the name of his or her designated caregiver.

(f) The name and address of the medical marijuana dispensary.

(g) The date on which the product was manufactured.

(h) If the product is perishable, a suggested use-by date.

(i) The total milligrams of active cannabinoids and terpinoids in the product, as provided by the independent testing laboratory that tested the product.

(j) A list of all ingredients and all major food allergens as identified in 21 U.S.C. §§ 343.

(k) A warning that states: “Caution: When eaten or swallowed, the intoxicating effects of this drug may be delayed by 2 or more hours.”

(l) If a marijuana extract was added to the product, a disclosure of the type of extraction process and any solvent, gas or other chemical used in the extraction process, or any other compound added to the extract.

(m) A warning that states: “This product may have intoxicating effects and may be habit forming.”

(n) A statement that: “This product may be unlawful outside of the State of Nevada.”

2.  The front and back of the label required by subsection 1 for a container or package containing edible marijuana products or marijuana-infused products sold at retail must be in substantially the following form:

We Care Dispensary, 123 Main Street, Carson City, NV 89701

Date Dispensed: 3/27/2014  To: John J. Smith #1234987

Cookie

Net Weight:  6oz (168 Grams)

Serving Size:  10mg of THC

Contains 10 servings and a total of 100 MG of THC

Use by:  6/3/2014

Myrcene 5.6 mg/g   Limonene 5.1 mg/g   Valencene 3.5 mg/g

CAUTION: When eaten or swallowed the intoxicating effects of this product can be delayed 2 or more hours.

This product may be unlawful outside the State of Nevada.

 

Manufactured at: Joe’s Kitchen        Cert.#: 321654987101 0401

123 Main Street, Las Vegas, NV on 2/1/14

Lot#: 1234 Batch #5463

INGREDIENTS: Flour, Butter, Canola Oil,

Sugar, Chocolate, Marijuana, Strawberries

CONTAINS ALLERGENS: Milk, Wheat

Contains marijuana extract processed with butane.

WARNING: This product may have intoxicating effects and may be habit forming.

3.  A medical marijuana dispensary must provide with all edible marijuana products and marijuana-infused products sold at retail accompanying material that discloses any pesticides applied to the marijuana plants and growing medium during production of the marijuana used to create the extract added to the edible marijuana products or marijuana-infused products and the type of extraction method used, including, without limitation, any solvents, gases or other chemicals or compounds used to produce or that are added to the extract, and contains the following warnings:

(a) “There may be health risks associated with consumption of this product.”

(b) “This product contains or is infused with marijuana or active compounds of marijuana.”

(c) “Should not be used by women who are pregnant or breast feeding.”

(d) “For use only by the person named on the label of the dispensed product. Keep out of the reach of children.”

(e) “Products containing marijuana can impair concentration, coordination and judgment. Do not operate a vehicle or machinery under the influence of this drug.”

(f) “Caution: When eaten or swallowed, the intoxicating effects of this drug may be delayed by 2 or more hours.”

4.  The text used on all accompanying material must be printed in at least 12-point font and may not be in italics.

(Added to NAC by Div. of Pub. & Behavioral Health by R004-14, 3-28-2014, eff. 4-1-2014)

      NAC 453A.514  Required examinations of packaged and labeled products. (NRS 453A.370)  Each cultivation facility, facility for the production of edible marijuana products or marijuana-infused products and medical marijuana dispensary shall:

1.  Examine packaged and labeled products during finishing operations to provide assurance that the containers and packages have the correct labels;

2.  Collect a representative sample of units at the completion of finishing operations and ensure that the samples are visually examined for correct labeling; and

3.  Record the results of the examinations performed pursuant to subsections 1 and 2 in the applicable production or control records.

(Added to NAC by Div. of Pub. & Behavioral Health by R004-14, 3-28-2014, eff. 4-1-2014)

Requirements for the Production of Edible Marijuana Products and Marijuana-Infused Products

      NAC 453A.550  “Potentially hazardous marijuana products and ingredients” defined. (NRS 453A.370)  As used in NAC 453A.550 to 453A.592, inclusive, unless the context otherwise requires:

1.  “Potentially hazardous marijuana products and ingredients” means an edible item that is natural or synthetic and that requires temperature control because it is in a form capable of supporting:

(a) The rapid and progressive growth of infectious or toxigenic microorganisms;

(b) The growth and toxin production of Clostridium botulinum; or

(c) In raw shell eggs, the growth of Salmonella Enteritidis.

2.  The term “potentially hazardous marijuana products and ingredients” includes, without limitation:

(a) An animal item that is raw or heat-treated;

(b) An item of plant origin that is heat-treated or consists of raw seed sprouts;

(c) Cut melons and tomatoes; and

(d) Garlic-in-oil mixtures that are not modified in a way that results in mixtures which prohibit growth.

3.  The term “potentially hazardous marijuana products and ingredients” does not include:

(a) An ingredient with a value of water activity of 0.85 or less;

(b) An ingredient with a pH level of 4.6 or below when measured at 75°F (24°C); or

(c) An ingredient, in a hermetically sealed and unopened container, that is commercially processed to achieve and maintain commercial sterility under conditions of nonrefrigerated storage and distribution.

(Added to NAC by Div. of Pub. & Behavioral Health by R004-14, 3-28-2014, eff. 4-1-2014)

RETAIL MARIJUANA

Sec. 1. Packaging and Labeling Requirements for marijuana and marijuana products that are not sold as medical marijuana: Generally.

  1. Relevant provisions in NRS 453A and NAC 453A are applicable herein.

Sec. 2. Packaging and Labeling Requirements for marijuana edible products.

  1. Each retail marijuana store and marijuana product manufacturing facility shall, in consultation with the Department, cooperate to ensure that all marijuana edible products offered for sale:
    1. Are labeled clearly and unambiguously:
      1. As marijuana with the words “THIS IS A MARIJUANA PRODUCT” bold type or similar alternate language that clearly identifies that the product contains marijuana; and
      2. as required by NRS 453A and NAC 453A.
    2. Are not presented in packaging that contains an image of a cartoon character, mascot, action figure, balloon or toy, except that such an item may appear in the logo of the marijuana product manufacturing facility which produced the product.
    3. Are not packaged and labeled in a manner which is modeled after products primarily consumed by or marketed to children.
    4. Are labeled in a manner which indicates the number of servings of THC in the product, measured in servings of a maximum of 10 milligrams per serving, and includes a statement that the product contains marijuana and its potency was tested with an allowable variance of plus or minus 15%.
    5. A marijuana product sold as a food product must be sold in a single package. A single package must not contain more than 100 milligrams of THC, and includes a statement that the product contains marijuana and its potency was tested with an allowable variance of plus or minus 15%.
  2. A marijuana product manufacturing facility shall not produce marijuana products in any form that:
    1. is or appears to be a lollipop or ice cream.
    2. Bears the likeness or contains characteristics of a real or fictional person, animal or fruit, without limitation, a caricature, cartoon or artistic rendering.
    3. Is modeled after a brand of products primarily consumed by or marketed to children.
    4. Is made by applying concentrated marijuana to a commercially available candy or snack food item other than dried fruit, nuts or granola.
  3. A marijuana product manufacturing facility shall:
    1. Seal any marijuana product that consists of cookies or brownies in a bag or other container which is not transparent.
    2. If not already included on the packaging, affix a label to each marijuana product intended for human consumption by oral ingestion which includes, without limitation, in a manner which must not mislead consumers, the following information:
      1. The words “Keep out of reach of children”;
      2. A list of all ingredients used in the marijuana product;
      3. A list of all allergens in the marijuana product; and
      4. The total weight of marijuana contain in the marijuana product or an equivalent measure of THC concentration.
    3. A retail marijuana store shall:
      1. Include a written notification with each sale of marijuana and marijuana products which advises the purchaser:
        1. To keep marijuana and marijuana products out of reach of children;
        2. That marijuana and marijuana products can cause severe illness in children;
        3. That allowing children to ingest marijuana or marijuana products, or storing marijuana or marijuana products in a location which is accessible to children may result in an investigation by an agency which provides child welfare services or criminal prosecution for children abuse or neglect;
        4. THAT THE INTOXICATING EFFECTS OF MARIJUANA PRODUCTS MAY BE DELAYED BY 2 HOURS OR MORE AND USERS OF MARIJUANA PRODUCTS SHOULD INITIALLY INGEST A SMALL AMOUNT OF THE PRODUCT CONTAINING NO MORE THAN 10 MG OF THC, THEN WAIT AT LEAST 2 HOURS BEFORE INGESTING ANY ADDITIONAL AMOUNT OF THE PRODUCT, capitalized in bold type;
        5. That pregnant women should consult with a physician before ingesting marijuana or marijuana products;
        6. That ingesting marijuana or marijuana products with alcohol or other drugs, including prescription medication, may result in unpredictable levels of impairment and that a person should consult with a physician before doing so;
        7. That marijuana and marijuana products can impair concentration, coordination, and judgement and a person should not operate a motor vehicle while under the influence of marijuana or marijuana products;
        8. That the ingestion of any amount of marijuana or marijuana products before driving may result in criminal prosecution for driving under the influence.

For more information, please refer to Chapter 453A – Medical Use of Marijuana.”

NEW HAMPSHIRE CANNABIS LABELING REQUIREMENTS

New Hampshire has this refreshing approach that’s so “short and sweet”, it might pleasantly surprise you:

“New Hampshire’s cannabis labeling and packaging guidelines require alternative treatment centers to provide a plan for safe and accurate packaging and labeling of cannabis, including the applicant’s plan for ensuring that all cannabis is free of contaminants.

For more information, please refer to New Hampshire House Bill 573.”

NEW JERSEY CANNABIS LABELING REQUIREMENTS

New Jersey has provided another short, but concise set of guidelines. Very clear and easy to understand, New Jersey’s set of labeling guidelines include only one thing that might throw off the regular consumer who is new to medical marijuana by using the initialized term, “ATC” without actually spelling it out—not even our computer spell checker knows what this is supposed to represent! All ATC means is, “Alternative Health Center”.

“New Jersey’s cannabis labeling and packaging guidelines include the following:

  • (b) The ATC–plant cultivation shall place a legible, firmly affixed label containing the information specified in (c) below on each package of medical marijuana it dispenses to an ATC–dispensary and shall not dispense medical marijuana if the package does not bear the label.
  • (c) The label required pursuant to (b) above shall contain the following:
    • The name and address of the alternative treatment center–plant cultivation that produced the medical marijuana;
    • The quantity of the medical marijuana contained within the package;
    • The date that the ATC–plant cultivation packaged the content;
    • A sequential serial number, lot number, and bar code to identify lot associated with manufacturing and processing;
    • The cannabinoid profile of the medical marijuana contained within the package, including THC level not to exceed 10 percent;
    • Whether the medical marijuana is of the low, medium, or high strength strain;
    • A statement that the product is for medical use by a qualifying patient and not for resale; and
    • A list of any other ingredients besides medical marijuana contained within the package.
  • (d) Labeling shall be clear and truthful in all respects and shall not be false or misleading in any particular.
  • A label containing any statements about the product other than those specified in this chapter shall contain the following statement prominently displayed, and in boldface type: “This statement has not been evaluated by the Food and Drug Administration. This product is not intended to diagnose, treat, cure, or prevent any disease.”

For more information, please refer to New Jersey Register Draft Regulations for the Medicinal Marijuana Program.”

NEW MEXICO CANNABIS LABELING REQUIREMENTS

New Mexico’s cannabis labeling and packaging guidelines include all the usual categories but their state government expects MMJ companies to figure out all the details that should be included in those guidelines in the first place! Then, New Mexico’s Medical Marijuana companies are required to submit what they come up with back to the New Mexico State government before being granted their licensing! To top it off, they don’t even instruct applicants where to send their applications to:

New Mexico’s cannabis labeling and packaging guidelines include the following:

  • Packaging and labeling: a manufacturer applicant shall submit a description and sample of the opaque, child-resistant packaging of the concentrate or cannabis-derived product that the manufacturer shall utilize, including a label that shall contain:
    • (1) the name of the entity that produced the cannabis and the name of the manufacturer;
    • (2) a batch number or code;
    • (3) a production date or expiration date, including a “use by” or “freeze by” date for products capable of supporting the growth of infectious, toxigenic, or spoilage microorganisms;
    • (4) a description of the number of units of usable cannabis contained within the product;
    • (5) instructions for use;
    • (6) warnings for use;
    • (7) instructions for appropriate storage;
    • (8) approved laboratory analysis, including the results of strength and composition within ten percent (10%) of numbers shown on the package;
    • (9) the name of the strain, product facts, or a nutrition fact panel, and a statement that the product is for medical use by qualified patients, to be kept away from children, and not for resale; and
    • (10) the name of the department-approved testing facility or facilities used for ingredient testing, and the type(s) of testing conducted.

For more information, please refer to Title 7, Chapter 34, Part 4 – Licensing Requirements for Producers, Couriers, Manufacturers and Laboratories.

NEW YORK CANNABIS LABELING REQUIREMENTS

First off, the writers of New York’s cannabis labeling and packaging guidelines don’t even know how to spell marijuana! They leave the word spelled incorrectly throughout the entire list. Another important term they misspell is “oromucosal” and we left it the way it was printed because we can only assume what the word was supposed to be, and assumptions are not good enough for our readers.

This strange word occurs in an even stranger subsection of the guidelines: “(1) liquid or oil preparations for metered oromucosal or sublingual administration or administration per tube;” and follows after this, even more disturbing sentence: “Approved medical marihuana products shall be limited to the following forms and routes of administration…”

What New York state is saying here is that approved MMJ products can ONLY be sold and taken (administered) in liquid or oil preparations and can not be smoked directly from medical marijuana flowers. This means that New York state is assuming that smoking medical marijuana is harmful to a patient’s health while this has never been clinically, scientifically proven beyond a doubt.

Therefore, this state is actually FORCING patients who want to remain compliant, to BUY expensive extract, concentrate products!

This is extremely frustrating because scientific clinical studies HAVE proven that smoking organically grown MMJ, grown correctly, does NOT leave any nasty health side-effects, let alone a harsh feeling in the throat the way cannabis and tobacco rushed to market full of toxins from chemical fertilizers and pesticides do.

Ironically, by legalizing recreational and medical marijuana, New York has also granted its citizens the right to grow up to 12 marijuana plants, medical, recreational or not, in their own homes!

With this being said, and along with the fact that our report is not intended to debate the above issues, the remainder of the label and packaging guidelines are in line with other legalized states guidelines.

“New York’s cannabis labeling and packaging guidelines include the following:

(g) Approved medical marihuana products shall be limited to the following forms and routes of administration:
(1) liquid or oil preparations for metered oromucosal or sublingual administration or administration per tube;
(2) metered liquid or oil preparations for vaporization;
(3) capsules for oral administration; or
(4) any additional form and route of administration approved by the commissioner. Smoking is not an approved route of administration.
(5) approved medical marihuana products may not be incorporated into edible food products by the registered organization, unless approved by the commissioner.

(h) The registered organization shall package the final form of the approved medical marihuana product at the manufacturing site. The original seal shall not be broken except for quality testing at an approved laboratory, for adverse event investigations, by the department, or by the certified patient or designated caregiver.

(i) The registered organization shall package the approved medical marihuana product such that it is child-resistant, tamper-proof/tamper-evident, light-resistant, and in a resealable package that minimizes oxygen exposure.

(j) The registered organization shall identify each lot of approved medical marihuana product with a lot unique identifier.

(k) Each approved medical marihuana product shall be affixed with a product label. Medical marihuana product labels shall be approved by the department prior to use. Each product label shall be applied at the manufacturing facility, be easily readable, firmly affixed and include:

(1) the name, address and registration number of the registered organization;
(2) the medical marihuana product form and brand designation;
(3) the single dose THC and CBD content for the product set forth in milligrams (mg);
(4) the medical marihuana product lot unique identifier (lot number or bar code);
(5) the quantity included in the package;
(6) the date packaged;
(7) the date of expiration of the product;
(8) the proper storage conditions;
(9) language stating:
(i) “Medical marihuana products must be kept in the original container in which they were dispensed and removed from the original container only when ready for use by the certified patient”;
(ii) “Keep secured at all times”;
(iii) “May not be resold or transferred to another person”;
(iv) “This product might impair the ability to drive”;
(v) “KEEP THIS PRODUCT AWAY FROM CHILDREN (unless medical marihuana product is being given to the child under a practitioner’s care”); and
(vi) “This product is for medicinal use only. Women should not consume during pregnancy or while breastfeeding except on the advice of the certifying practitioner, and in the case of breastfeeding mothers, including the infant’s pediatrician.”

(l) For each lot of medical marihuana product produced, the registered organization shall submit a predetermined number of final medical marihuana products (e.g., sealed vials or capsules; with the number of samples submitted, based on statistical analysis, determined to be representative of the lot) to an independent laboratory/laboratories approved by the department. The laboratory verifying the cannabinoid content shall be approved for the analysis of medical marihuana product by the department in accordance with section five hundred two of the public health law and subpart 55-2 of this title. Such laboratory, or approved laboratories cumulatively, shall certify the medical marihuana product lot as passing all contaminant testing and verify that the content is consistent with the brand prior to the medical marihuana product being released from the manufacturer to any dispensing facility.

(1) Any lot not meeting the minimum standards or specifications for safety shall be rejected and destroyed by the registered organization in accordance with the registered organization’s approved operating plan.

(2) Any lot not meeting the minimum standards or specifications for brand consistency shall be rejected and destroyed by the registered organization in accordance with the registered organization’s approved operating plan.

(3) The registered organization shall keep and maintain records documenting submission of medical marihuana products to approved laboratories as required herein, and the results of the laboratory testing. The registered organization shall provide the department with such records upon request.

(m) The registered organization shall demonstrate the stability of each approved medical marihuana product produced (each brand in each form) by testing at an approved laboratory in accordance with section 1004.14 of this title:

(1) the stability and expiration date of the final distributed medical marihuana product shall be validated and shall be stable for a minimum of 60 days under the specified storage conditions (light, temperature and humidity) when opened;

(2) shelf-life of unopened medical marihuana products (e.g., packages or vials) shall be validated by ongoing stability testing according to a schedule determined by the department and an expiration date for unopened products shall be determined through the stability testing;

(3) specifications regarding storage conditions must address storage at the manufacturing facility once the package is sealed, during transport, at the dispensing facility, in the patient’s home and for samples retained for future testing.

(n) No synthetic marihuana additives shall be used in the production of any medical marihuana product.

For more information, please refer to the New York Medical Marijuana Program Regulations.”

OREGON CANNABIS LABELING REQUIREMENTS

The state of Oregon has had medical and recreational marijuana legalized for a while now. Consequently, Oregon has had lots of time to get the lengthy details of labeling and packaging guidelines straight, clear and easy to understand by the average man or woman and this is reflected in the quoted guidelines below.

We would just like to point out for clarification, that the initialized term, “OMMP” that appears throughout the guidelines simply means: “Oregon Medical Marijuana Program”.

An interesting point of note to add is that Oregon is the only state we’ve noticed so far that has made specific guidelines for the labeling and packaging of marijuana seeds. Kudos to Oregon!

“Oregon’s cannabis labeling and packaging guidelines fall under 333-007-0010 Labeling and include the following:

  • 333-007-0030 Marijuana Plant Labeling Requirements Prior to a marijuana plant being sold or transferred to a consumer, patient or designated primary caregiver a tag or label must be affixed to the plant or plant container that has the following information:
    (1) Producer’s business or trade name and licensee or registrant number;
    (2) Business or trade name of licensee or registrant that packaged or distributed the product, if different from the producer;
  • (3) Name of the strain; and
    (4) Universal symbol.
  • Marijuana Seed Labeling Requirements Prior to marijuana seeds being sold or transferred to a consumer, patient or designated primary caregiver the container holding the seeds must have a label that has the following information:
    (1) Producer’s business or trade name and licensee or registrant number;
    (2) Business or trade name of licensee or registrant that packaged or distributed the product, if different from the producer;
    (3) Name of the strain of seed;
    (4) Date of harvest;
    (5) Number of seeds or net weight in U.S. customary and metric units as appropriate; and
    (6) Universal symbol.
  • Usable Marijuana Labeling Requirements Prior to usable marijuana being sold or transferred to a consumer, patient or designated primary caregiver the container holding the usable marijuana must have a label that has the following information:
    (1) Producer’s business or trade name and licensee or registrant number;
    (2) Business or trade name of licensee or registrant that packaged or distributed the product, if different from the producer;
    (3) For licensees, package unique identification number and for registrants, harvest lot number;
    (4) Date of harvest;
    (5) Name of strain;
    (6) Net weight in U.S. customary and metric units;
    (7) Concentration of THC and CBD, as calculated under OAR 333-064-0100;
    (8) Activation time expressed in words or through a pictogram;
    (9) Name of the lab that performed any test, any associated test batch number and any test analysis date;
    (10) Universal symbol;
    (11) For usable marijuana for sale to a consumer, warnings that state:
    (a) “For use by adults 21 and older. Keep out of reach of children.”
    (b) “It is illegal to drive a motor vehicle while under the influence of marijuana.”
    (12) For usable marijuana for use by a patient, warnings that state:
    (a) “For use by OMMP patients only. Keep out of reach of children.”
    (b) “It is illegal to drive a motor vehicle while under the influence of marijuana.”
  • Cannabinoid Topical Labeling Requirements Prior to a cannabinoid topical product being sold or transferred to a consumer, patient or designated primary caregiver the container holding the cannabinoid product must have a label that has the following information:
    (1) Processor’s business or trade name and licensee or registrant number;
    (2) Business or trade name of licensee or registrant that packaged or distributed the product, if different from the processor;
    (3) For licensees, package unique identification number and for registrants, process lot number;
    (4) Product identity (common or usual name);
    (5) Date the product was made;
    (6) Net weight or volume in U.S. customary and metric units;
    (7) Amount suggested for use by the consumer or patient at any one time;
    (8) Concentration or amount by weight or volume of THC and CBD in the container;
    (9) List of ingredients in descending order or predominance by weight or volume used to process the cannabinoid topical;
    (10) Activation time, expressed in words or through a pictogram;
    (11) Name of the lab that performed any test, any associated test batch number and any test analysis date;
    (12) Universal symbol;
    (13) For licensees, a medical grade symbol if applicable;
    (14) A statement that reads: “This product is not approved by the FDA to treat, cure, or prevent any disease”;
    (15) For cannabinoid topicals for sale to a consumer, warnings that state:(a) “For use only by adults 21 and older. Keep out of reach of children.”
    (b) “DO NOT EAT” in bold, capital letters.(16) For cannabinoid topicals for use by a patient, warnings that state:(a) “For use by OMMP patients only. Keep out of reach of children.”
    (b) “DO NOT EAT” in bold, capital letters.
  • Cannabinoid Edible Labeling Requirements Prior to a cannabinoid edible being sold or transferred to a consumer, patient or designated primary caregiver the container holding the edible must have a label that has the following information:(1) Processor’s business or trade name, place of address, and licensee or registrant number;
    (2) Business or trade name and place of address of licensee or registrant that packaged or distributed the product, if different from the processor;
    (3) Product identity (common or usual name);
    (4) For licensees, package unique identification number and for registrants, process lot number;
    (5) Date the edible was made;
    (6) Net weight or volume in U.S. customary and metric units;
    (7) Serving size and number of servings per container;
    (8) Concentration or amount by weight or volume of THC and CBD in each serving and in each container;
    (9) List of all ingredients in descending order of predominance by weight or volume used to process the cannabinoid edible;
    (10) List of potential major food allergens:(a) Using a “contains” statement to summarize the major food allergen information at the end of or immediately adjacent to the ingredient list; or
    (b) Placing the term for the appropriate major food allergen in parenthesis within the ingredient list after the common or usual name of the ingredient derived from that major food allergen;(11) The amount, in grams, of sodium, sugar, carbohydrates and total fat per serving;
    (12) If the edible is perishable, a statement that the edible must be refrigerated or kept frozen;
    (13) Name of the lab that performed any test, any associated test batch number and any test analysis date;
    (14) Activation time, expressed in words or through a pictogram;
    (15) Universal symbol;
    (16) For licensees, a medical grade symbol if applicable;
    (17) A statement that reads: “This product is not approved by the FDA to treat, cure, or prevent any disease”;
    (18) For cannabinoid edibles for sale to a consumer, warnings that state:(a) “For use only by adults 21 and older. Keep out of reach of children.”
    (b) “It is illegal to drive a motor vehicle while under the influence of marijuana.”
    (c) “BE CAUTIOUS” in bold, capital letters, followed by “Cannabinoid edibles can take up to 2 hours or more to take effect.”(19) For cannabinoid edibles for use by a patient warnings that state:
    (a) “For use by OMMP patients only. Keep out of reach of children.”
    (b) “It is illegal to drive a motor vehicle while under the influence of marijuana.”
    (c) “BE CAUTIOUS” in bold, capital letters, followed by “Cannabinoid edibles can take up to 2 hours or more to take effect.”
  • Labeling Requirements for Cannabinoid Concentrates and Extracts Prior to a cannabinoid concentrate or extract being sold or transferred to a consumer, patient or designated primary caregiver the container holding the concentrate or extract must have a label that has the following information:(1) Processor’s business or trade name and licensee or registrant number;
    (2) Business or trade name of licensee or registrant that packaged or distributed the product, if different from the processor;
    (3) For licensees, package unique identification number and for registrants, process lot number;
    (4) Product identity (concentrate or extract);
    (5) Date the concentrate or extract was made;
    (6) Net weight or volume in U.S. customary and metric units;
    (7) If applicable, serving size and number of servings per container or amount suggested for use by the consumer or patient at any one time;
    (8) Concentration or amount by weight or volume of THC and CBD in each amount suggested for use and in the container;
    (9) Activation time, expressed in words or through a pictogram;
    (10) Name of the lab that performed any test, any associated test batch number and any test analysis date;
    (11) Universal symbol;
    (12) For licensees, a medical grade symbol if applicable;
    (13) A statement that reads: “This product is not approved by the FDA to treat, cure, or prevent any disease”;
    (14) For cannabinoid concentrates and extracts for sale to a consumer, warnings that state:(a) “For use only by adults 21 and older. Keep out of reach of children.”
    (b) “It is illegal to drive a motor vehicle while under the influence of marijuana.”
    (c) “DO NOT EAT” in bold, capital letters.(15) For cannabinoid concentrates and extracts for use by a patient, warnings that state:(a) “For use by OMMP patients only. Keep out of reach of children.”
    (b) “It is illegal to drive a motor vehicle while under the influence of marijuana.”
    (c) “DO NOT EAT” in bold, capital letters.
  • Cannabinoid Tincture Labeling Requirements Prior to a cannabinoid tincture being sold or transferred to a consumer, patient or designated primary caregiver the container holding the tincture must have a label that has the following information:(1) Processor’s business or trade name, place of address and licensee or registrant number;
    (2) Business or trade name and place of address of licensee or registrant that packaged or distributed the product, if different from the processor;
    (3) Product identity (common or usual name);
    (4) For licensees, package unique identification number and for registrants, process lot number;
    (5) Date the tincture was made;
    (6) Net weight or volume in U.S. customary and metric units;
    (7) Serving size and number of servings per container;
    (8) Concentration or amount by weight or volume of THC and CBD in each serving and in each container;
    (9) List of all ingredients in descending order of predominance by weight or volume used to process the cannabinoid tincture;
    (10) Name of the lab that performed any test, any associated test batch number and any test analysis date;
    (11) Universal symbol;
    (12) For licensees, a medical grade symbol if applicable;
    (13) Activation time expressed in words or through a pictogram;
    (14) A statement that reads: “This product is not approved by the FDA to treat, cure, or prevent any disease”;
    (15) For cannabinoid tinctures for sale to a consumer, warnings that state:(a) “For use only by adults 21 and older. Keep out of reach of children.”
    (b) “It is illegal to drive a motor vehicle while under the influence of marijuana.”(16) For cannabinoid tinctures for use by a patient, warnings that state:(a) “For use by OMMP patients only. Keep out of reach of children.”
    (b) “It is illegal to drive a motor vehicle while under the influence of marijuana.”
  • Cannabinoid Products Other than Cannabinoid Edibles, Topicals or Tinctures Prior to a cannabinoid product other than a cannabinoid edible, topical or tincture being sold or transferred to a consumer, patient or designated primary caregiver the container holding the product must have a label that has the following information:(1) Processor’s business or trade name and licensee or registrant number;
    (2) Business or trade name of licensee or registrant that packaged or distributed the product, if different from the processor;
    (3) Place of address for the processor and packager, if applicable;
    (4) Product identity (common or usual name);
    (5) For licensees, package unique identification number and for registrants, process lot number;
    (6) Date the product was made;
    (7) Net weight or volume in U.S. customary and metric units;
    (8) Serving size and number of servings per container;
    (9) Concentration or amount by weight or volume of THC and CBD in each serving and in each container;
    (10) List of all ingredients in descending order of predominance by weight or volume used to process the cannabinoid product;
    (11) Name of the lab that performed any test, any associated test batch number and any test analysis date;
    (12) Universal symbol;
    (13) For licensees, a medical grade symbol if applicable;
    (14) Activation time expressed in words or through a pictogram;
    (15) A statement that reads: “This product is not approved by the FDA to treat, cure, or prevent any disease”;
    (16) For cannabinoid products for sale to a consumer, warnings that state:(a) “For use only by adults 21 and older. Keep out of reach of children.”
    (b) “It is illegal to drive a motor vehicle while under the influence of marijuana.”(17) For cannabinoid products for use by a patient, warnings that state:
    (a) “For use by OMMP patients only. Keep out of reach of children.”(b) “It is illegal to drive a motor vehicle while under the influence of marijuana.”
  • General Label Requirements; Prohibitions; Exceptions(1) Principal Display Panel.(a) Every container that contains a marijuana item for sale or transfer to a consumer, patient or designated primary caregiver must have a principal display panel, as that term is defined in OAR 333-007-0020.
    (b) If a container is placed within packaging for purposes of displaying the marijuana item for sale or transfer to a consumer, patient or designated primary caregiver, the packaging must have a principal display panel as that term is defined in OAR 333-007-0020.
    (c) The principal display panel must contain the product identity, net weight, and universal symbol, if applicable.
    (d) If the product is a medical grade cannabinoid product, concentrate or extract processed by a licensee the principal display panel must include the medical grade symbol.(2) A label required by these rules must:(a) Be placed on the container and on any packaging that is used to display the marijuana item for sale or transfer to a consumer, patient or designated primary caregiver.
    (b) Comply with the National Institute of Standards and Technology (NIST) Handbook 130 (2016), Uniform Packaging and Labeling Regulation, incorporated by reference.
    (c) Be in no smaller than 8 point Times New Roman, Helvetica or Arial font;
    (d) Be in English, though it can be in other languages; and
    (e) Be unobstructed and conspicuous.(3) A marijuana item may have one or more labels affixed to the container or packaging.
    (4) A marijuana item that is in a container that because of its size does not have sufficient space for a label that contains all the information required for compliance with these rules:
    (a) May have a label on the container that contains a marijuana item and on any packaging that is used to display the marijuana item for sale or transfer to a consumer, patient or designated primary caregiver that includes at least the following:(A) Information required on a principal display panel, if applicable for the type of marijuana item;
    (B) Licensee or registrant business or trade name and licensee or registrant number;
    (C) For licensees, package unique identification number and for registrants, batch or process lot number;
    (D) Concentration of THC and CBD; and
    (E) Required warnings; and(b) Must include all other required label information not listed in subsection (4)(a) of this rule on an outer container or package, or on a leaflet that accompanies the marijuana item.(5) A marijuana item in a container that is placed in packaging that is used to display the marijuana item for sale or transfer to a consumer, patient, or designated primary caregiver must comply with the labeling requirements in these rules, even if the container qualifies for the exception under section (4) of this rule.
    (6) The universal symbol:(a) Must be at least 0.48 inches wide by 0.35 inches high.
    (b) May only be used by licensees or registrants.
    (c) May be downloaded at healthoregon.org/marijuana.(7) Medical grade symbol. The medical grade symbol must be at least 0.35 inches in diameter.
    (8) A label may not:(a) Contain any untruthful or misleading statements including, but not limited to, a health claim that is not supported by the totality of publicly available scientific evidence (including evidence from well-designed studies conducted in a manner which is consistent with generally recognized scientific procedures and principles), and for which there is significant scientific agreement, among experts qualified by scientific training and experience to evaluate such claims; or
    (b) Be attractive to minors, as that is defined in OAR 845-025-7000.(9) A marijuana item that falls within more than one category, for example a product that is both a cannabinoid concentrate and cannabinoid edible, must comply with the labeling requirements that apply to both categories, with the exception of the “DO NOT EAT” warning if the product is intended for human consumption or the “BE CAUTIOUS” warning if the effects of the product are customarily felt immediately.
    (10) The THC and CBD amount required to be on a label must be the value calculated by the laboratory that did the testing in accordance with OAR 333-064-0100.
    (11) If a marijuana item has more than one test batch number, laboratory, or test analysis date associated with the marijuana item that is being sold or transferred, each test batch number, laboratory and test analysis date must be included on a label.
    (12) If a marijuana item is placed in a package that is being re-used, the old label or labels must be removed and it must have a new label or labels.
    (13) A licensee or registrant must have documentation that demonstrates the validity of the calculation of the amount of sodium, sugar, carbohydrates and total fat in a cannabinoid edible and must make that documentation available to the Commission or the Authority upon request.(14) Exit packaging must contain a label that reads: “Keep out of the reach of children.”
  • Pre-Approval of Labels (1) A registrant must submit labels for pre-approval in accordance with OAR 845-025-7060 and must keep all records related to the pre-approval process and provide those records at the request of the Authority.
    (2) On and after October 1, 2016, a registrant may not transfer a marijuana item unless the label has been pre-approved in accordance with OAR 845-025-7060.

For more information, please refer to the Marijuana Labeling and Concentration Limits.”

RHODE ISLAND CANNABIS LABELING REQUIREMENTS

The tiniest state in the mainland USA also has the smallest easiest to understand labeling and packaging guidelines…enjoy!

“Rhode Island’s cannabis labeling and packaging guidelines include the following:

  • (j) A description of the packaging of the useable marijuana that the compassion center shall be utilizing which shall, as a minimum, include:
    • (1) A label containing the name of the strain, batch, and quantity; and
    • (2) A statement that the product is for medical use and not for resale.

For more information, please refer to the Rules and Regulations Related to the Medical Marijuana Program.”

VERMONT CANNABIS LABELING REQUIREMENTS

Vermont has made it VERY easy to get compliant with your MMJ labels and packaging. We’re just wondering though…

If it’s so easy to get into the medical marijuana business in Vermont, then why does the state seem to distance itself as far away as possible from the industry with this simple statement: “… the label shall contain a statement to the effect that the State of Vermont does not attest to the medicinal value of cannabis…”?

Isn’t Vermont forcing its medical marijuana businesses to, “shoot themselves in the foot” when it comes to their marketing? Its like the Vermont government saying, OK, we’ll let you try and sell MMJ, even though we think its worthless?

Maybe with any other product, but to all the citizens of Vermont who DO know the power of medical marijuana, a mandatory cautionary warning like this might be worth a giggle, if not being overlooked completely.

And just as a side note, since people seem to be moving out of Vermont by the hundreds, and the state is trying to counteract this “loosing tax dollars” trend with a $10,000 bonus “settling incentive” to people wishing move IN, we say, GO FOR IT! Unless you’re into really warm weather, Vermont is one of America’s most beautiful states with big incentives to move right in and set up shop!

“Vermont’s cannabis labeling and packaging guidelines include the following:

  • A registered dispensary shall package all marijuana dispensed in an envelope or other container used and intended for sale.
  • A label shall be affixed on the packaging of all marijuana that is dispensed. The label shall identify the particular strain of marijuana and the weight of marijuana contained within the package in gram or ounce units. Marijuana strains shall reflect the properties of the plant.
  • Additionally, the label shall contain a statement to the effect that the State of Vermont does not attest to the medicinal value of cannabis, a statement that this product is not for resale, and clearly identify “marijuana” is contained within the packaging.
  • The dispensary shall verify the amount of all marijuana dispensed.
  • Documentation shall be maintained containing at a minimum the name and registry identification number of the registered dispensary cardholders verifying the amount of marijuana and any errors identified.

For more information, please refer to the Final Proposed Rules Regulating Cannabis for Symptom Relief.”

WASHINGTON CANNABIS LABELING REQUIREMENTS

Washington has successfully legalized the sale of MMJ right along with alcohol in the same retail outlets. Along with Colorado, Washington was the first state in the Union to legalize recreational marijuana for adults, and the legal age of adults in the USA is 21.

With its first labeling and packaging stipulation, “All usable marijuana and marijuana-infused products must be stored behind a counter or other barrier to ensure a customer does not have direct access to the product”, the state of Washington is trying to sell it like alcohol as well!

Many provinces in Canada, which legalized recreational marijuana 6 years after Washington did, are now selling marijuana in, “Liquor Marts” which were in the not too distant past, government controlled stores devoted to selling only spirits, beer and wine, and were called, “The Liquor Control Board”. The beer, wine and spirits in Canada have always been sold, “on the floor” in shelving just like a grocery store. Ironically, the Weed is now locked up behind the counters! Washington therefore seems to have set up a great precedent not only for other states in America, but for other countries new to legalizing MMJ as well. Medical marijuana always gets legalized before recreational marijuana.

Since it went completely legal in 2012, Washington made a successful and relatively smooth transition from turning a vilified illegal product into a legal one and even promotes 99% of medical marijuana products as “good” for your health.  We wholeheartedly believe Washington was so successful in its legalization primary because of the logical, clear legislation it wrote into law, specifically for its guidelines for the labeling and packaging of MMJ as well as recreational.

The 1% that Washington DOES warn its citizens about is smoking cannabis: “Smoking is hazardous to your health”. Again this one little warning is a “hang-over” from prohibition years when the government was doing everything in its power to demonize cannabis and turned it into a Schedule 1 drug in the Dirty Thirties. Isn’t it ironic how smoking “Reefer” was made out to be so bad for people, when at the same time, smoking tobacco was actually promoted as being good for your health! And because it was illegal, marijuana was band from being studied by American scientists. Now that it IS legal for scientists in our great medical universities in America to study the effects of smoking cannabis, not one study has yet proven smoking organically grown cannabis to be detrimental to your health…and definitely no one has ever died from cancer attributed to smoking ONLY cannabis!

“Washington’s cannabis labeling and packaging guidelines include the following:

·     Packaging and labeling requirements.

(1) All usable marijuana and marijuana-infused products must be stored behind a counter or other barrier to ensure a customer does not have direct access to the product.

(2) Any container or packaging containing usable marijuana, marijuana concentrates, or marijuana-infused products must protect the product from contamination and must not impart any toxic or deleterious substance to the usable marijuana, marijuana concentrates, or marijuana-infused product.

(3) Upon the request of a retail customer, a retailer must disclose the name of the certified third-party testing lab and results of the required quality assurance test for any usable marijuana, marijuana concentrate, or marijuana-infused product the customer is considering purchasing.

(4) Usable marijuana, marijuana concentrates, and marijuana-infused products must not be labeled as organic unless permitted by the United States Department of Agriculture in accordance with the Organic Foods Production Act.

(5) The certified third-party testing lab and required results of the quality assurance test must be included with each lot and disclosed to the customer buying the lot.

(6) A marijuana producer must make quality assurance test results available to any processor purchasing product. A marijuana producer must label each lot of marijuana with the following information:

(a) Lot number;

(b) UBI number of the producer; and

(c) Weight of the product.

(7) Marijuana-infused products and marijuana concentrates meant to be eaten, swallowed, or inhaled, must be packaged in child resistant packaging in accordance with Title 16 C.F.R. 1700 of the Poison Prevention Packaging Act or use standards specified in this subsection. Marijuana-infused product in solid or liquid form may be packaged in plastic four mil or greater in thickness and be heat sealed with no easy-open tab, dimple, corner, or flap as to make it difficult for a child to open and as a tamperproof measure. Marijuana-infused product in liquid form may also be sealed using a metal crown cork style bottle cap.

Marijuana-infused solid edible products. If there is more than one serving in the package, each serving must be packaged individually in childproof packaging (see WAC 314-55-105(7)) and placed in the outer package.

Marijuana-infused liquid edible products. If there is more than one serving in the package, a measuring device must be included in the package with the product. Hash marks on the bottle do not qualify as a measuring device. A measuring cap or dropper must be included in the package with the marijuana-infused liquid edible product.

(8)

(9) A producer or processor may not treat or otherwise adulterate usable marijuana with any organic or nonorganic chemical or other compound whatsoever to alter the color, appearance, weight, or smell of the usable marijuana.

(10) Labels must comply with the version of NIST Handbook 130, Uniform Packaging and Labeling Regulation adopted in chapter 16-662 WAC.

(11) All marijuana and marijuana products when sold at retail must include accompanying material that is attached to the package or is given separately to the consumer containing the following warnings:

(a) “Warning: This product has intoxicating effects and may be habit forming. Smoking is hazardous to your health”;

(b) “There may be health risks associated with consumption of this product”;

(c) “Should not be used by women that are pregnant or breast feeding”;

(d) “For use only by adults twenty-one and older. Keep out of reach of children”;

(e) “Marijuana can impair concentration, coordination, and judgment. Do not operate a vehicle or machinery under the influence of this drug”;

(f) Statement that discloses all pesticides applied to the marijuana plants and growing medium during production and processing.

(12) Labels affixed to the container or package containing marijuana or marijuana products sold at retail must include:

(a) The business or trade name and the sixteen digit Washington state unified business identifier number of the licensees that produced, processed and sold the marijuana or marijuana products. The marijuana retail licensee trade name and Washington state unified business identifier number may be in the form of a sticker placed on the label;

(b) Sixteen digit inventory ID number assigned by the WSLCB’s traceability system. This must be the same number that appears on the transport manifest;

(c) Net weight in ounces and grams or volume as appropriate;

(d) Statement that discloses all pesticides applied to the marijuana plants and growing medium during production of the base marijuana used to create the extract added to infused products; and

(e) If solvents were used, statement that discloses the type of extraction method, including any solvents, gases, or other chemicals or compounds used to produce or that are added to the extract.

(f) Warnings that state: “This product has intoxicating effects and may be habit forming”;

(g) Statement that “This product may be unlawful outside of Washington state”;

(h) The WSLCB may create a logo that must be placed on all usable marijuana and marijuana-infused products.

(13) In addition to requirements in subsection (10) of this section, labels affixed to the container or package containing usable marijuana, or packaged marijuana mix sold at retail must include:

(a) Concentration of THC (total THC and activated THC-A) and CBD (total CBD and activated CBD-A);

(b) Date of harvest.

(14) In addition to requirements in subsection (10) of this section, labels affixed to the container or package containing marijuana-infused products meant to be eaten or swallowed sold at retail must include:

(a) Date manufactured;

(b) Best by date;

(c) Serving size and the number of servings contained within the unit;

(d) Total milligrams of active THC, or Delta 9 and total milligrams of active CBD;

(e) List of all ingredients and major food allergens as defined in the Food Allergen Labeling and Consumer Protection Act of 2004;

(f) “Caution: When eaten or swallowed, the intoxicating effects of this drug may be delayed by two or more hours.”

(15) In addition to requirements in subsection (10) of this section, labels affixed to the container or package containing marijuana-infused extract for inhalation, or infused marijuana mix sold at retail must include:

(a) Date manufactured;

(b) Best by date;

(c) Concentration of THC (total Delta 9 and Delta 9 THC-A) and CBD (total CBD and activated CBD-A).

(16) In addition to requirements in subsection (10) of this section, labels affixed to the container or package containing marijuana topicals sold at retail must include:

(a) Date manufactured;

(b) Best by date;

(c) Total milligrams of active tetrahydrocannabinol (THC), or Delta 9 and total milligrams of active CBD.

(17) Other cannabinoids and terpenes may be included on the label if:

(a) The producer or processor has test results from a certified third-party lab to support the claim; and

(b) The lab results are made available to the consumer upon request.

For more information, please refer to the Washington Administrative Code 314-55-105 for Packaging and Labeling Requirements.”

 

Looking for more information? Contact our label experts today!

Leave a Reply

2019/10/23