3 AAC 306.565. Packaging of marijuana products
(a) A marijuana product manufacturing facility shall observe the
potency limits set out in 3 AAC 306.560 in packaging each product for
resale by a retail marijuana store.
(b) A container or packaging for any edible marijuana product
produced by a marijuana product manufacturing facility may not have any
printed images, including cartoon characters, that specifically target
individuals under 21 years of age. In addition, the packaging must
(1) protect the product from contamination and may not
impart any toxic or damaging substance to the product; and
(2) if the marijuana product contains multiple servings, be
designed so that the marijuana product itself has markings or
demarcations clearly delineating each serving of the product; for liquid
marijuana products with multiple servings, the packaging must indicate
the number and size of individual servings.
(c) A licensed marijuana product manufacturing facility may
transfer marijuana products that are not edible marijuana products to
another licensed marijuana product manufacturing facility in wholesale
packages not to exceed five pounds.
(d) Each packaged marijuana product must be identified by a
tracking label generated by the marijuana product manufacturing
facility's marijuana inventory tracking system.
(e)A licensed marijuana product manufacturing facility shall
prepare marijuana products for transfer to another marijuana
establishment by
(1)placing marijuana products within a sealed, tamper-
evident shipping container;
(2) affixing a label that complies with 3 AAC 306.570(d) to
the shipping container; and
(3) generating a transport manifest from the marijuana
product manufacturing facility's marijuana inventory tracking system;
the transport manifest must remain with the marijuana products at all
times while being transported, and a copy must be given to the licensed
marijuana establishment that receives the shipment.
3 AAC 306.570. Labeling of marijuana products
(a) With each production lot of marijuana product sold, a
marijuana product manufacturing facility shall disclose in writing the
name of the licensed marijuana testing facility that performed any
required test and the results of each required test.
(b) A marijuana product may not be labeled as organic.
(c) To each package of marijuana product sold to a retai
marijuana store for resale to a consumer, a marijuana product manufacturing facility shall affix a label setting out
(1) the name and license number of the marijuana product
manufacturing facility where the marijuana product was prepared;
(2) the production lot number assigned to the product in the
package;
(3)the net weight of the product in the package,
(A) not including weight of packaging; and
(B)using a standard of measure compatible with the
Marijuana product manufacturing facilities marijuana inventory tracking system; and
(4) each of 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.";
(E) "Marijuana should not be used by women who are
pregnant or breast feeding.".
(d) A marijuana product manufacturing facility transporting a
marijuana product to a retail marijuana store shall affix a label to the
shipping container showing that a licensed marijuana testing facility
has tested each lot of marijuana product in the shipment and giving the
test results, including
(1) a cannabinoid potency profile expressed as a range of
percentages that extends from the lowest percentage to highest
percentage of concentration for each cannabinoid listed from every test
conducted on that production lot from the same marijuana product
manufacturing facility within the last three months;
(2) a statement listing the results of microbial testing
required under 3 AAC 306.645(b)(2);
(3) a statement listing the results of residual solvent
testing required under 3 AAC 306.645(b)(3), if applicable; and
(4) a statement listing any contaminants for which the
product was tested in addition to contaminants for which 3 AAC
306.645(b) requires testing; any additional tested contaminants include
For more information on Alaska's Marijuana program: https://www.commerce.alaska.gov/web/amco/MarijuanaFAQs.aspx
LABELING
(A) The purpose of this section is to set the minimum standards for the labeling of usable marijuana that is sold to a qualifying patient or designated caregiver by a dispensary or given by a qualifying patient or designated to another qualifying patient or designated caregiver.
(1) Usable marijuana received or transferred by a dispensary, qualifying patient or designated caregiver must meet the labeling requirements in these rules.
(2)(a) A dispensary must return usable marijuana that does not meet labeling requirements in these rules to the individual who transferred it to the dispensary and document to whom the item was returned, what was returned and the date of the return; or (b) Dispose of any usable marijuana that does not meet labeling requirements and that cannot be returned in a manner specified by the Department.
(B) Usable Marijuana Labeling Requirements
(1) Prior to usable marijuana being sold or transferred to a qualifying patient or designated caregiver, the container holding the usable marijuana must have a label that has the following information:
(a) Producer’s business or trade name and cultivation facility or dispensary number;
(b) Business or trade name of cultivation facility or dispensary or cultivation facility or dispensary that packaged or distributed the product, if different from the producer; 8
(c) A unique identification number;
(d) Date of harvest;
(e) Name of strain;
(f) Net weight in U.S. customary and metric units;
(g) Concentration of THC and CBD;
(h) Activation time expressed in words or through a pictogram;
(i) Name of the lab that performed any test, any associated test batch number and any test analysis date;
(j) Universal symbol;
(k) A warning that states: "For use by qualified patients only. Keep out of reach of children.";
(l) A warning that states: “Marijuana use during pregnancy or breastfeeding poses potential harms.”; and
(m) A warning that states: "This product is not approved by the FDA to treat, cure, or prevent any disease".
(C) Cannabinoid Concentrates and Extracts
(1) Prior to a cannabinoid concentrate or extract being sold or transferred to a qualifying patient or designated caregiver, the container holding the concentrate or extract must have a label that has the following information:
(a) Cultivation facility or dispensary’s business or trade name and cultivation facility or dispensary number;
(b) Business or trade name of cultivation facility or dispensary that packaged or distributed the product, if different from the cultivation facility or dispensary; (c) A unique identification number; (d) Product identity (concentrate or extract);
(e) Date the concentrate or extract was made;
(f) Net weight or volume in U.S. customary and metric units; 9
(g) If applicable, serving size and number of servings per container or amount suggested for use by the qualifying patient at any one time;
(h) Concentration or amount by weight or volume of THC and CBD in each amount suggested for use and in the container;
(i) Activation time, expressed in words or through a pictogram;
(j) Name of the lab that performed any test, any associated test batch number and any test analysis date;
(k) Universal symbol;
(l) A statement that reads:
(i) "This product is not approved by the FDA to treat, cure, or prevent any disease";
(ii) "For use by qualifying patients only. Keep out of reach of children.";
(iii) "DO NOT EAT" in bold, capital letters; and
(iv) “Marijuana use during pregnancy or breastfeeding poses potential harms.”
(D) General Label Requirement, Prohibitions and Exceptions
(1) Principal Display Panel.
(a) Every container that contains usable marijuana for sale or transfer to a qualifying patient or designated caregiver must have a principal display panel.
(b) If a container is placed within packaging for purposes of displaying the marijuana item for sale or transfer to a qualifying patient or designated caregiver, the packaging must have a principal display panel.
(c) The principal display panel must contain the product identity, net weight, and universal symbol, if applicable.
(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 qualified patient or designated caregiver. 10
(b) Comply with the National Institute of Standards and Technology (NIST) Handbook 130 (2017), Uniform Packaging and Labeling Regulation, incorporated by reference.
(c) Be in no smaller than 8 point Times New Roman, Helvetica or Arial font;
(i) Statements required by subsections (C)(1)(l)
(ii) and (iv) must be in at least 18 point.
(d) Be in English, though it can also be in other languages; and
(e) Be unobstructed and conspicuous.
(3) Usable marijuana may have one or more labels affixed to the container or packaging.
(4) Usable marijuana 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 usable marijuana and on any packaging that is used to display usable marijuana for sale or transfer to a qualifying patient or designated caregiver that includes at least the following:
(i) Information required on a principal display panel, if applicable for the type of usable marijuana;
(ii) Cultivation facility or dispensary business or trade name and cultivation facility or dispensary number;
(iii) For cultivation facility or dispensaries, a package unique identification number;
(iv) Concentration of THC and CBD; and
(v) Required warnings; and
(b) Must include all other required label information not listed in subsection
(4)(a) on an outer container or package, or on a leaflet that accompanies the usable marijuana.
(5) Usable marijuana in a container that is placed in packaging that is used to display the usable marijuana for sale or transfer to a qualifying patient or designated caregiver must comply with the labeling requirements in these rules, even if the container qualifies for the exception under subsection (4).
(6) The universal symbol: 11
(a) Must be at least 0.48 inches wide by 0.35 inches high.
(b) May only be used by a cultivation facility or dispensary.
(c) May be downloaded at: www.healthy.arkansas.gov/Pages/MedMarijuana.aspx
(7) 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.
(8) Usable marijuana that falls within more than one category 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.
(9) The THC and CBD amount required to be on a label must be the value calculated by the laboratory that did the testing.
(10) If usable marijuana has more than one test batch number, laboratory, or test analysis date associated with the usable marijuana that is being sold or transferred, each test batch number, laboratory and test analysis date must be included on a label.
(11) If usable marijuana 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.
(12) Exit packaging must contain a label that reads: "Keep out of the reach of children."to http://www.healthy.arkansas.gov/Documents/The%20Arkansas%20Medical%20Marijuana%20Amendment%20of%202016.pdf
More information
https://static.ark.org/eeuploads/arml/Arkansas_Medical_Marijuana_Amendment_of_2016.pdf
A. A dispensary shall ensure that medical marijuana provided by the dispensary to a qualifying patient or a designated caregiver is labeled with:
1. The dispensary’s registry identification number;
2. The amount, strain, and batch number of medical marijuana;
3. 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”;
4. If not cultivated by the dispensary, whether the medical marijuana was obtained from a qualifying patient, a designated caregiver, or another dispensary;
5. The date of manufacture, harvest, or sale;
6. A list of all chemical additives, including non-organic pesticides, herbicides, and fertilizers, used in the cultivation and production of the medical marijuana; and
7. The registry identification number of the qualifying patient.
B. If a dispensary provides medical marijuana cultivated by the dispensary to another dispensary, the dispensary shall ensure that the medical marijuana is labeled with:
1. The dispensary’s registry identification number;
2. The amount, strain, and batch number of the medical marijuana;
3. The date of harvest or sale; and
4. A list of all chemical additives, including nonorganic pesticides, herbicides, and fertilizers, used in the cultivation of the medical marijuana.
C. 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
For more information, please refer to the Arizona Department of Health Services for Medical Marijuana.
Packaging Checklist
https://www.cdph.ca.gov/Programs/CEH/DFDCS/MCSB/CDPH%20Document%20Library/Packaging_Checklist.pdf
Labeling Requirements for Flower and Flower -Only Pre-rollsLabeling Requirements for Manufactured Cannabis Products.
General Information for Cannabis in CA
https://cannabis.ca.gov/general-resources/
( Chapter 12 added November 8, 2016, by initiative Proposition 64, Sec. 6.1. )
(a) Prior to delivery or sale at a retailer, marijuana and marijuana products shall be labeled and placed in a resealable, child resistant package.
(b) Packages and labels shall not be made to be attractive to children.
(c) All marijuana and marijuana product labels and inserts shall include the following information prominently displayed in a clear and legible fashion in accordance with the requirements, including font size, prescribed by the bureau or the State Department of Public Health:
(1) Manufacture date and source.
(2) The following statements, in bold print:
(A) For marijuana: “GOVERNMENT WARNING: THIS PACKAGE CONTAINS MARIJUANA, A SCHEDULE I CONTROLLED SUBSTANCE. KEEP OUT OF REACH OF CHILDREN AND ANIMALS. MARIJUANA MAY ONLY BE POSSESSED OR CONSUMED BY PERSONS 21 YEARS OF AGE OR OLDER UNLESS THE PERSON IS A QUALIFIED PATIENT. MARIJUANA USE WHILE PREGNANT OR BREASTFEEDING MAY BE HARMFUL. CONSUMPTION OF MARIJUANA IMPAIRS YOUR ABILITY TO DRIVE AND OPERATE MACHINERY. PLEASE USE EXTREME CAUTION.”
(B) For marijuana products: “GOVERNMENT WARNING: THIS PRODUCT CONTAINS MARIJUANA, A SCHEDULE I CONTROLLED SUBSTANCE. KEEP OUT OF REACH OF CHILDREN AND ANIMALS. MARIJUANA PRODUCTS MAY ONLY BE POSSESSED OR CONSUMED BY PERSONS 21 YEARS OF AGE OR OLDER UNLESS THE PERSON IS A QUALIFIED PATIENT. THE INTOXICATING EFFECTS OF MARIJUANA PRODUCTS MAY BE DELAYED UP TO TWO HOURS. MARIJUANA USE WHILE PREGNANT OR BREASTFEEDING MAY BE HARMFUL. CONSUMPTION OF MARIJUANA PRODUCTS IMPAIRS YOUR ABILITY TO DRIVE AND OPERATE MACHINERY. PLEASE USE EXTREME CAUTION.”
(3) For packages containing only dried flower, the net weight of marijuana in the package.
(4) Identification of the source and date of cultivation, the type of marijuana or marijuana product and the date of manufacturing and packaging.
(5) The appellation of origin, if any.
(6) 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, and the potency of the marijuana or marijuana product by reference to the amount of tetrahydrocannabinol and cannabidiol in each serving.
(7) For marijuana products, a list of all ingredients and disclosure of nutritional information in the same manner as the federal nutritional labeling requirements in Section 101.9 of Title 21 of the Code of Federal Regulations.
(8) A list of any solvents, nonorganic pesticides, herbicides, and fertilizers that were used in the cultivation, production, and manufacture of such marijuana or marijuana product.
(9) A warning if nuts or other known allergens are used.
(10) Information associated with the unique identifier issued by the Department of Food and Agriculture.
(11) Any other requirement set by the bureau or the State Department of Public Health.
(d) Only generic food names may be used to describe the ingredients in edible marijuana products.
(e) In the event the bureau determines that marijuana is no longer a schedule I controlled substance under federal law, the label prescribed in subdivision (c) shall no longer require a statement that marijuana is a schedule I controlled substance.
(Added November 8, 2016, by initiative Proposition 64, Sec. 6.1.)
Colorado’s cannabis labeling and packaging guidelines state that before sale to a consumer, a retail marijuana store must place any cannabis products in a container that adheres to the following restrictions:
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.
LABELING RULES EFFECTIVE OCTOBER 1, 2017
Edibles in the Shape of Human, Animal or Fruit
The Medical Marijuana Code (“Medical Code”) and Retail Marijuana Code (“Retail Code”) mandate that the State Licensing Authority promulgate rules prohibiting the production and sale of marijuana products “that are in the distinct shape of a human, animal, or fruit” and that such rules shall take effect on October 1, 2017.1 Consistent with this requirement, the State Licensing Authority promulgated rules expressly prohibiting the production, sale or donation of edible medical marijuana‐infused products and edible retail marijuana products (collectively referred to herein as “Edible Products”) in the distinct shape of a human, animal or fruit, or a shape that bears the likeness or contains the characteristics of a realistic or fictional human, animal, or fruit, including
artistic, caricature, or cartoon renderings.
2 Medical Marijuana Centers and Retail Marijuana Stores: Beginning October 1, 2017,
Medical Marijuana Centers and Retail Marijuana Stores shall not purchase, take possession of, sell, or donate non‐compliant Edible Products.
Medical Marijuana‐Infused Products Manufacturers and Retail Marijuana Products
Manufacturing Facilities: Beginning October 1, 2017, Medical Marijuana‐Infused Products
Manufacturers and Retail Marijuana Product Manufacturing Facilities shall neither produce
non‐compliant Edible Products nor sell, transfer or donate non‐compliant Edible Products to another Medical Marijuana Business or Retail Marijuana Establishment.
Any Medical Marijuana Business or Retail Marijuana Establishment in possession of non‐compliant
Edible Products on or after October 1, 2017 shall follow waste disposal procedures pursuant to Rules M and R 307, 1 CCR 212‐1 and 1 CCR 212‐2.
Child Resistant Certificate(s). A Licensee shall maintain a copy of the certificate showing that each Child-Resistant Container into which the Licensee places Medical Marijuana, Medical Marijuana Concentrate, or Medical Marijuana-Infused Product is Child-Resistant and complies with the requirements of 16 C.F.R. 1700.15 (1995) and 16 C.F.R. 1700.20 (1995) in accordance with the requirements of Rule M 901(A).
Connecticut’s cannabis labeling and packaging guidelines come from Sec. 21a-408-56 of its regulations:
For more information, please refer to the State of Connecticut Regulation of the Department of Consumer Protection Concerning Palliative Use of Marijuana.
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:
For more information, please refer to 4470 State of Delaware Medical Marijuana Code.
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:
For more information, please refer to the D.C. Municipal Regulations and D.C. Register.
For Further Information contact: http://www.leg.state.fl.us/
Hawaii’s cannabis labeling and packaging guidelines come from Hawaii House Bill 321:
For more information, please refer to House Bill 321 Relating to Medical Marijuana.
Illinois’ cannabis labeling and packaging guidelines include the following:
For more information, please refer to the General Provisions for the Compassionate Use of Medical Cannabis Pilot Act.
Report No. 1 of 3 for Regulatory Project 2016-6 — Marijuana Pharmacy
§2443. Marijuana products
D. Packaging and Labeling Requirements.
1. Packaging.
a. The producer shall ensure every product intended for dispensing to a patient is placed within a child-resistant, light-resistant, tamper-evident container prior to sale or transport to the pharmacy.
2. Labeling.
a. Each product shall be labeled by the producer prior to its sale to the marijuana pharmacy. Each label shall be securely affixed to the package and shall include, at a minimum:
b. The labeling text on any marijuana product shall not make any false or misleading statements regarding health or physical benefits to the consumer. Further, each label shall include all of the following statements:
c. The labeling text required by this Section shall be no smaller than 1/16 of an inch, shall be printed in English, and must be unobstructed and conspicuous.
http://www.pharmacy.la.gov/assets/docs/Cmtes/RegRev/RegProj2016-6_OversightCmteRpt1.pdf
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 labeling laws. See 22 M.R.S.A. §2157.
For more information, please refer to the Rules Governing the Maine Medical Use of Marijuana Program.
Maryland’s cannabis labeling and packaging guidelines include the following:
(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) 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.
(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) 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 and packaging guidelines include the following:
For more information, please refer to the Implementation of an Act for the Humanitarian Medical Use of Marijuana.
Michigan currently has no cannabis labeling and packaging requirements.
For more information, please refer to the Michigan Medical Marihuana Program.
Minnesota’s cannabis labeling and packaging guidelines include the following:
For more information, please refer to the Minnesota Revisor of Statutes on Packaging and Labeling.
Consumer Safety
Strict Packaging Requirements ◦ Limited servings and concentration per package
Consumer Safety
Strict Labeling Requirements
◦ Labels
Accompanying materials (varies slightly by type of product)
Consumer Safety - Marijuana-Infused Products
For more information on Washington Packaging requirements.
http://app.leg.wa.gov/wac/default.aspx?cite=314-55-077
For more information on Montana Packaging Requirements
https://www.mdt.mt.gov/visionzero/docs/chsp/2016-2-4_Impacts_of_Marijuana_Legislation_Grondel.pdf
For more information, please refer to Initiative Referendum No. 124.