California Government Introduces New Resources for Cannabis Labeling and Packaging

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The California Department of Public Health has adopted new regulations on the packaging and labeling of cannabis and cannabis products.

Here is a quick overview of the available cannabis packaging resources to help you better understand the changes and requirements now in place.

Packaging Checklist

As far as general packaging requirements for all types of products go, the checklist is as follows:

  • Tamper Evident – a plastic seal, a sticker across the lid that is ripped when opened, a jar with a lid that pops up after opening, etc.
  • Child Resistant – packages designed to be difficult for children under five to open.
  • Resealable (for products with multiple uses) – the package can be closed after each use (a lid, box top closure or adhesive closure, etc.)
  • Opaque (for edibles only) – non-transparent packaging. This includes amber-colored bottles.

Dos:

  • Cannabis flower may be packaged by a cultivator, manufacturer or distributor. Manufactured cannabis products must be packaged and labeled by the manufacturer prior to transfer to a distributor as finished products.
  • Protect products from contamination and exposure to any toxic or harmful substances
  • If a product has multiple layers of packaging, the packaging requirements can be fulfilled using any one of those layers.

Don’ts:

  • Cannot imitate packaging used for products typically marketed to children
  • Cannot imitate packaging used for non-cannabis food products

State law requires all cannabis and cannabis products to be in child-resistant packaging. The products that require initial CRP are flower and flower only pre-rolls, topicals, single-serving cannabis products and inhaled concentrates.

The products that require lifetime CRP are edibles, tinctures, capsules, orally consumed concentrates and suppositories.

Packaging Checklist for Cannabis

These requirements apply to flower and flower only pre-rolls.

Primary panel – the label part displayed to consumers at retail, usually the front or top of the package

  • Product Identity – a common name describing the item. For example, flower or pre-roll
  • Net weight – listing weight in both metric and U.S. customary units (for example, NET WT. 4.0 oz (113.4g))
  • Universal Symbol – the California symbol that identifies cannabis and cannabis products, in black color, at least 0.5 X 0.5

Informational panel – any part of the label which is not the primary panel

  • UID number – The unique number issued through the Track-and-Trace system (this requirement begins when you receive your Track-and-Trace login. Don’t create a placeholder UID number)
  • Licensee name and phone number or website – either the name of the licensed cultivator or licensee packaging the product, with a name listed on the license certificate, either the legal business name or registered DBA
  • Date of packaging for retail sale – including the month, day and year
  • Government warning statement – in capital and bold letters

Other labeling

  • Cannabinoid content, stated in percentage

Dos

  • Display information clearly and legibly
  • Use English and at least a 6 point font
  • Make sure all labeling information is displayed on the outer layer of packaging
  • Additional product information may be added as long as it is truthful and not misleading

Don’ts

  • California county names – Unless 100% of the cannabis in the product is grown in the county
  • Cannot be attractive to children – no usage of cartoons or images popularly used to advertise to children. No imitation of candy labeling, or usage of the word “candy,” “candies” or a play on those words.
  • Cannot include false or misleading information – anything untrue on unproven that gives an inaccurate impression. No use of the word organic anywhere on the label
  • Cannot make unproven health claims – Health-related statements may not be used unless there is significant scientific agreement and the claims are supported by a totality of publicly-available peer-reviewed evidence

Packaging Checklist for Cannabis Products – Edibles, Concentrates, and Topicals

If a product has multiple layers of packaging, basic labeling must be included on the innermost container that holds the cannabis product.

Inhaled cannabis products (such as vape cartridges, shatter and wax) must include the universal symbol

Non-inhaled products, such as edibles, tinctures, and topicals must include the product identity, universal symbol and net weight or volume. Edible products must also include the words “Cannabis-Infused.”

Edible cannabis product labels must also include the words Cannabis-Infused above the product identity, in a bold font and larger text size than the one used for the product identity, as well as Sodium, sugar, carbohydrates and total fat per serving, in milligrams or grams.

The Dos and DON’Ts are the same as listed before, with two added requirements

  • For edibles, you cannot include a picture of the product.
  • The product may not be marketed as an alcoholic beverage.

Primary panel

  • Product identity
  • Universal symbol
  • Net weight or volume
  • Cannabis infused, for edibles.

Informational panel

  • Manufacturer name and contact information
  • Date of manufacture/packaging
  • Government warning statement for cannabis products
  • UID number
  • Batch or lot number
  • Instructions for use and any preparation needed – For example, the method of consumption or application.
  • List of all ingredients (in descending order by weight or volume, also include sub-ingredients, if any are present
  • Allergens (if applicable) – the word “Contains” followed by a list of any major food allergen in the product – these are milk, eggs, tree nuts, wheat, peanuts, soybeans, fish or crustacean shellfish. Use the name of the specific food, and not the general category.
  • Artificial food coloring – if applicable
  • Expiration, use-by or best-by date – if applicable
  • KEEP REFRIGERATED” or “REFRIGERATE AFTER OPENING” – if perishable after opening
  • FOR MEDICAL USE ONLY – if applicable

Other labeling

  • Cannabinoid content in milligrams
  • THC or CBD per package
  • THC and CBD per serving
  • Any other cannabinoid that makes up 5% or more of the total cannabinoid content

Packaging and Labeling FAQs

  • Can CDPH provide feedback on my label?

No, but resources are available on the CDPH’s website to help you understand and meet the requirements

  • Can I make the Universal Symbol white or another light color if my packaging is dark?

No, the symbol must be black. The symbol must be visible on your label. If the packaging is dark, use a lighter background where the symbol will be placed, or outline the symbol with a contrasting color

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