The Ultimate Guide to Creating Custom Cannabis Labels

Custom Cannabis Labels:

Rules and Regs 101

With the Green Rush comes dynamic and professional packaging that can simultaneously elevate and highlight an already amazing product—cannabis. You, the small business owner, must know what the standards are in labeling your product, because they aren’t only meant to be simple aesthetic branding pieces that should make you look good—first and foremost they are “information sheets” that help customers identify your product and see if it is a good fit for them, versus other products, versus your competition.

You already know that legal marijuana or cannabis as a regulated business category is unlike tobacco and alcohol in that it is not legal at the federal level. What this means for you is that the absence of federal regulations means the creation of independent rules and regs for labeling based on where you are in the USA. It’s important that you follow these rules and establish your presence right away.

Explicitly noted in state guidelines, cannabis labeling regulations are geared toward two things—a clear communication of the contents of the package, and protecting public safety. Of course art and a visual premium figures largely as well. So, what should you include on your cannabis labels?

Keep in mind though that there are still exceptions and variations to the guidelines for specific product categories. When in doubt, find your state below and go to the link at the end of each summary to check the full text of guidelines for complete details. You can simply annex the information based on what section it is that you need to clarify.

[Tweet “Confused about cannabis packaging state laws? This guide will clear that up!”]

Let’s get started–we’ll guide you through clear-cut labeling rules for cannabis product presentation and content.

CUSTOM CANNABIS LABELS: PRESENTATION/AESTHETICS

Primo presentation rules—all packaging must be light-resistant (opaque containers for concealment of contents) and “child-resistant”. In terms of artwork and design concepts, medical and recreational cannabis, whether in bud form or as infused edibles and topicals, must appeal only to adults. This means no cartoon characters and no ultra bright color palettes that could catch kids’ interest.

A fine example is Leafs by Snoop which has elevated cannabis as connoisseur-type, high-end, very “adult-looking” product.

Packaging conventions using color also help customers identify brand extensions easier, as with Honey Pot 420’s color-coded caps.

CUSTOM CANNABIS LABELS:

CONTENT

Essential content rules—Apart from the standard brand name + ID (for what kind of cannabis product it is) + contact info, you should include specific information that will help your customer understand and use the product correctly, in legible English.

This wraparound label from Humboldt Relief is concise but comprehensive, and does the job well.

In most states, it is required that the recommended dosage, warnings, specific quantity (in ounces or grams), name of medicine, and expiration date be placed on all cannabis labels. Of particular note is to list the following in the minimum and maximum percentage content by weight: delta-9-tetrahydrocannabinol (THC); tetrahydrocannabinolic acid (THCA); cannabidiol (CBD); cannabidiolic acid (CBDA); and any other ingredients besides cannabis.

To make the product labels even more straightforward, certain statements such as “Product is for medical use and not for resale or transfer to another person.” for medical cannabis and “Keep Out of Reach of Children” for all cannabis products. Allergen warnings are mandatory.

For content, the general notes above aren’t blanket rules though. To be certain, follow the cannabis labeling rules and regulations specified by your state below.

ALASKA

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-sealable, 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 labeled 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;”

For more information, please refer to the full text of the Act to Tax and Regulate the Production, Sale and Use of Marijuana.

ARIZONA

Arizona’s cannabis labeling and packaging guidelines only specifies for child-resistant packaging.

For more information, please refer to the Arizona Department of Health Services for Medical Marijuana.

CALIFORNIA

The following regulations for packaging and labelling are lifted from the Assembly Bill 266:

(a) Prior to delivery or sale at a dispensary, medical cannabis products shall be labeled and in a tamper-evident package. Labels and packages of medical cannabis products shall meet the following requirements:

• (1) Medical cannabis packages and labels shall not be made to be attractive to children.
• (2) All medical cannabis product labels shall include the following information, prominently displayed and in a clear and legible font:
  • (A) Manufacture date and source.
  • (B) The statement “SCHEDULE I CONTROLLED SUBSTANCE.”
  • (C) The statement “KEEP OUT OF REACH OF CHILDREN AND ANIMALS” in bold print.
  • (D) The statement “FOR MEDICAL USE ONLY.”
  • (E) The statement “THE INTOXICATING EFFECTS OF THIS PRODUCT MAY BE DELAYED BY UP TO TWO HOURS.”
  • (F) The statement “THIS PRODUCT MAY IMPAIR THE ABILITY TO DRIVE OR OPERATE MACHINERY. PLEASE USE EXTREME CAUTION.”
  • (G) For packages containing only dried flower, the net weight of medical cannabis in the package.
  • (H) A warning if nuts or other known allergens are used.
  • (I) List of pharmacologically active ingredients, including, but not limited to, tetrahydrocannabinol (THC), cannabidiol (CBD), and other cannabinoid content, the THC and other cannabinoid amount in milligrams per serving, servings per package, and the THC and other cannabinoid amount in milligrams for the package total.
  • (J) Clear indication, in bold type, that the product contains medical cannabis.
  • (K) Identification of the source and date of cultivation and manufacture.
  • (L) Any other requirement set by the bureau.
  • (M) Information associated with the unique identifier issued by the Department of Food and Agriculture pursuant to Section 11362.777 of the Health and Safety Code.
• (b) Only generic food names may be used to describe edible medical cannabis products.

For more information, see the Guidelines for the Security and Non-Diversion of Marijuana Grown for Medical Use, and the SF Medical Cannabis Dispensary Regulations.

COLORADO

Colorado’s cannabis labeling and packaging guidelines state that a retail marijuana store must place any cannabis products in a container that adheres to the following restrictions (before this is sold to a customer):

• Is child-resistant or is placed into an “exit package” that is child-resistant;
• Is opaque;
• Is closable if not intended for single use;
• Is properly labeled pursuant to the Colorado Retail Marijuana Code
  • The packaging may not be designed to appeal to children
  • The labeling makes no false or misleading statements regarding health or physical benefits to the consumer
  • Labeling text is no smaller than 1/16 of an inch
  • Labeling text must be clearly written or printed and in the English language
  • Labeling text must be unobstructed and conspicuous
• Includes Colorado’s Universal THC Symbol

Additionally, containers for edible marijuana products must be labeled with all ingredients.

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.

CONNECTICUT

Connecticut’s cannabis labeling and packaging guidelines are lifted 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

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

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

Hawaii’s cannabis labeling and packaging guidelines are lifted from Hawaii House Bill 321:

• (a) The department shall establish standards regarding the advertising and packaging of medical marijuana products; provided that the standards, at a minimum, shall require the use of packaging that:
  • (1) Is child-resistant and opaque so that the product cannot be seen from outside the packaging;
  • (2) Is clearly labeled with the phrase “For medical use only”; and
  • (3) Contains information about the contents and potency of the product.
• (b) Any lozenge, capsule, or pill containing medical 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.

For more information, please refer to House Bill 321 Relating to Medical Marijuana.

ILLINOIS

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

Maine’s 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 labelling laws seen at 22 M.R.S.A. §2157.

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

MARYLAND

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

• .01 Packaging of Medical Cannabis Finished Product.
  A. All items shall be individually packaged at the original point of processing.
• (1) Be plain;
• (3) Be tamper-evident, and if applicable or appropriate, child-resistant;
• (5) Bear a clear warning that:(b) It is a illegal for any person to possess or consume the contents of the package other than the qualifying patient; and
• (6) Bear a clear warning to keep the package and its contents away from children other than a qualifying patient;
• (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;
• (10) Bear a listing of the non-medical cannabis ingredients;
• (12) Leave space for a licensed dispensary to attach a personalized label for the qualifying patient.
• (1) Resemblance to the trademarked, characteristic or product-specialized packaging of any commercially available candy, snack, baked good or beverage;
• (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.
• (2) Statement, artwork or design that could reasonably mislead any person to believe that the package contains anything other a medical cannabis finished product;
• C. Packaging Prohibitions. A package of medical cannabis finished product may not bear any:
• (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
• (9) Bear any allergen warning required by law;
• (7) Bear the Maryland Poison Control Center emergency telephone number;
• (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;
• (a) The contents may be lawfully consumed only by a qualifying patient named on an attached label;
• (4) Bear a finished-product lot number and an expiration date;
• (2) Be opaque;

B. Packaging Requirements. A package of medical cannabis finished product shall:

• .02 Label for Distribution to a Qualifying Patient.
  A. 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.C. A licensee shall state on a label of a package of medical cannabis:
• (2) The name of the certifying physician;
• (4) The date that the medical cannabis was dispensed;
• (6) The strength of applicable cannabinoid and terpene compounds:(b) Concentrations of any cannabinoid of less than one percent shall be printed with a leading zero before the decimal point;
• (8) Any directions for use of the product; and D. Any other information required by the dispensary at its discretion may be provided in a patient insert.
• (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.

E. The label may not:

• (9) The instructions for proper storage or handling of the product.
• (7) The quantity of medical cannabis dispensed, displayed in units appropriate to the dosage form;
• (a) Displayed in units appropriate to the dosage form; and
• (5) The name of the product;
• (3) The name of the licensee where the product was dispensed;
• (1) The name of the qualifying patient;
• B. A licensee may not distribute a package of medical cannabis without a label securely attached.

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

MASSACHUSETTS

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

Currently, Michigan has no cannabis labeling and packaging requirements.

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

MINNESOTA

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

• 4770.0850 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:
• A. 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.
• B. Medical cannabis packaging must not bear a reasonable resemblance to any commercially available product.
• C. 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:
  • A. names that are limited to those that clearly reflect the product’s medical cannabis nature;
  • B. any name that is identical to, or confusingly similar to, the name of an existing non-cannabis product is prohibited;
  • C. any name that is identical to, or confusingly similar to, the name of an unlawful product or substance is prohibited; and
  • D. 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.”
• B. Labeling text must not include any false or misleading statements regarding health or physical benefits to the patient.
• C. 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

Currently, Montana has no cannabis labeling and packaging requirements.

For more information, please refer to Initiative Referendum No. 124.

NEVADA

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

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

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

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

• 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 terpenoid 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.

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

NEW HAMPSHIRE

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

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:
  • 1. The name and address of the alternative treatment center–plant cultivation that produced the medical marijuana;
  • 2. The quantity of the medical marijuana contained within the package;
  • 3. The date that the ATC–plant cultivation packaged the content;
  • 4. A sequential serial number, lot number, and bar code to identify lot associated with manufacturing and processing;
  • 5. The cannabinoid profile of the medical marijuana contained within the package, including THC level not to exceed 10 percent;
  • 6. Whether the medical marijuana is of the low, medium, or high strength strain;
  • 7. A statement that the product is for medical use by a qualifying patient and not for resale; and
  • 8. 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.
• 1. 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

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

• C. 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

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:(2) metered liquid or oil preparations for vaporization;(4) any additional form and route of administration approved by the commissioner. Smoking is not an approved route of administration.(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.(j) The registered organization shall identify each lot of approved medical marihuana product with a lot unique identifier.(1) the name, address and registration number of the registered organization;(3) the single dose THC and CBD content for the product set forth in milligrams (mg);(5) the quantity included in the package;(7) the date of expiration of the product;(9) language stating:(ii) “Keep secured at all times”;(iv) “This product might impair the ability to drive”;(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.(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.(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:(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;(n) No synthetic marihuana additives shall be used in the production of any medical marihuana product.
• (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.
• (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;
• (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.
• (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.
• (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.”
• (iii) “May not be resold or transferred to another person”;
• (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”;
• (8) the proper storage conditions;
• (6) the date packaged;
• (4) the medical marihuana product lot unique identifier (lot number or bar code);
• (2) the medical marihuana product form and brand designation;
• (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:
• (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.
• (5) approved medical marihuana products may not be incorporated into edible food products by the registered organization, unless approved by the commissioner.
• (3) capsules for oral administration; or
• (1) liquid or oil preparations for metered oromucosal or sublingual administration or administration per tube;

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

OREGON

Oregon’s cannabis labeling and packaging guidelines fall under 333-008-1225 packaging and include the following:

• (1) For purposes of this rule:
  • (a) “Child-resistant safety packaging” means:
    • (A) Containers designed and constructed to be significantly difficult for children under five years of age to open and not difficult for adults to use properly;
    • (B) Opaque so that the product cannot be seen from outside the packaging;
    • (C) Closable for any product intended for more than a single use or containing multiple servings; and
    • (D) Labeled in accordance with OAR 333-008-1220.
  • (b) “Container” means a sealed, hard, or soft-bodied receptacle in which a tetrahydrocannabinol infused product is placed prior to being transferred to a patient or caregiver.
  • c) “Packaged in a manner not attractive to minors” means the tetrahydrocannabinol-infused product is not in a container that is brightly colored, depicts cartoons or images other than the logo of the facility, unless the logo of the facility depicts cartoons, in which case only the name of the facility is permitted.
• (2) A registered facility may not transfer any tetrahydrocannabinol-infused product that is meant to be swallowed or inhaled, unless the product is:
  • (a) In child-resistant safety packaging; and
  • (b) Packaged in a manner that is not attractive to minors.

For more information, please refer to the Final Rules for the Medical Marijuana Dispensary Program.

PENNSYLVANIA

Pennsylvania has just recently legalised the use of medical marijuana. Your medical marijuana products only may be dispensed in the following forms:  pill, oil, topical forms (including gel, creams or ointments), vaporization or nebulization, tincture or liquid. Smoking marijuana is not permitted under the law. Cannabis labeling and packaging guidelines include the following:

• (v) Packaging and labeling by licensed growers, licensed processors and licensed dispensers. Regulations under this subparagraph shall require labelling to specify:
• (A) date of packaging;
• (B) use-by date;
• (C) instructions to keep the product in the package;
• (D) warnings related to use, including pregnancy and medical conditions;
• (E) warnings to keep medical cannabis out of children’s reach;
• (F) other warnings deemed appropriate by the board;
• (G) recommended dosages;

For more information, please read updates on recent changes to the Senate Bill 3 – Information on the Medical Marijuana Act.

RHODE ISLAND

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

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

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

• (10) Labels must comply with the version of NIST Handbook 130, Uniform Packaging and Labeling Regulation adopted in chapter 16-662 WAC.
• (11) All usable marijuana when sold at retail must include accompanying material that contains the following warnings that state:
  • (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) All marijuana concentrates and marijuana-infused products sold at retail must include accompanying material that contains the following warnings that state:
  • (a) “There may be health risks associated with consumption of this product”;
  • (b) “This product is infused with marijuana or active compounds of marijuana”;
  • (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) “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 two or more hours”;
  • (g) 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 the infused product; and
  • (h) 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.
• (13) Labels affixed to the container or package containing usable marijuana sold at retail must include:
  • (a) The business or trade name and Washington state unified business identifier number of the licensees that produced, processed, and sold the usable marijuana. 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) Inventory ID number assigned by the liquor control board’s traceability system. This must be the same number that appears on the transport manifest;
  • (c) Concentration of THC (total THC and activated THC-A) and CBD;
  • (d) Net weight in ounces and grams or volume as appropriate;
  • (e) Warnings that state: “This product has intoxicating effects and may be habit forming”;
  • (f) Statement that “This product may be unlawful outside of Washington state”;
  • (g) Date of harvest; and
  • (h) The board may create a logo that must be placed on all usable marijuana and marijuana-infused products.
• (15) Labels affixed to the container or package containing marijuana-infused products sold at retail must include:
  • (a) The business or trade name and Washington state unified business identifier number of the licensees that produced, processed, and sold the marijuana. 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) Inventory ID number assigned by the liquor control board’s traceability system. This must be the same number that appears on the transport manifest;
  • (c) Date manufactured;
  • (d) Best by date;
  • (e) Products meant to be eaten or swallowed, recommended serving size and the number of servings contained within the unit, including total milligrams of active tetrahydrocannabinol (THC), or Delta 9;
  • (f) Net weight in ounces and grams, or volume as appropriate;
  • (g) List of all ingredients and major food allergens as defined in the Food Allergen Labeling and Consumer Protection Act of 2004;
  • (h) “Caution: When eaten or swallowed, the intoxicating effects of this drug may be delayed by two or more hours.”;
  • (i) If a marijuana extract was added to the product, 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;
  • (j) Warnings that state: “This product has intoxicating effects and may be habit forming”;
  • (k) Statement that “This product may be unlawful outside of Washington state”;
  • (l) The board may create a logo that must be placed on all usable marijuana and marijuana-infused products.
• (17) Labels affixed to the container or package containing marijuana concentrates sold at retail must include:
  • (a) The business or trade name and Washington state unified business identifier number of the licensees that produced, processed, and sold the marijuana concentrate. The marijuana retail licensee trade name and Washington state unified business identifier may be in the form of a sticker placed on the label;
  • (b) Inventory ID number assigned by the liquor control board traceability system. This must be the same number that appears on the transportation manifest;
  • (c) Date manufactured;
  • (d) Best by date;
  • (e) Net weight in ounces and grams, or volume as appropriate;
  • (f) If a marijuana extract was added to the product, 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;
  • (g) Concentration of THC (total Delta 9 and Delta 9 THC-A) and CBD;
  • (h) Warnings that state “This product has intoxicating effects and may be habit forming”;
  • (i) Statement that “This product may be unlawful outside Washington state”; and
  • (j) The board may create a logo that must be placed on all usable marijuana and marijuana-infused products.

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

For any comments or news regarding the guide above, feel free to email us and we’ll get it updated ASAP.