CALIFORNIA CANNABIS COMPLIANCE
Well, July 1st came and went, which means brands in California now have to be 100% inline with the new regulations, and that includes packaging. While you can get to grips with the fine details of #CaliCompliancy via our recent post, July 1st Checklist: Are you Cali Cannabis Compliant?, we thought we’d also publish this specific piece on three packaging areas that may be giving some of you a headache: container size, children, and cannabis products you can eat or drink.
So, you had this great idea for a packaging design for your cool cannabis product. It was going to be so eye-catching, so cute, and small enough to fit in your pocket. And then the regulatory authorities came along and said that all Cali cannabis products had to have not one, but two labels printed on their packaging, jam-packed with information ranging from batch identity numbers to THC and CBD levels. Your very unique, yet very tiny container is just too tiny. What do you do?
Don’t worry. The solution is simple. All you have to do is add a third label to your product’s packaging, called a Supplemental Label, which can take the form of a hang tag or peel-back, for example, and then you’ll be good to go. Essentially, the required regulatory info is distributed across the three labels on small containers as follows:
1. Primary Panel – the information here must remain exactly the same as the info found on larger containers. Minimum 6 point font is required. Check out the exact info needed here.
2. Informational Panel – the only text required for small containers is the government warning statement in capital letters and bold font. Minimum 6 point font is required. You can find the exact government warning statement here.
3. Supplemental Label – all the other info that is normally found on the Informational Panel should now be printed on the Supplemental Label. Minimum 8 point font is required. The exact info you need to include is as follows:
- Name, contact number or website address of the licensed manufacturer
- The date when the product was manufactured and packaged
- A list of all product ingredients in descending order of predominance by weight or volume;
- Directions for how to use the product, for example method of consumption or application, and any
preparation requirements that might be necessary
- The product expiration date, if applicable
- The UID and batch number, if applicable
- PLEASE NOTE… any additional information related to cannabinoids or terpenes that brand owners may want to include must be verified by a certificate of analysis issued by one of California’s licensed testing laboratories
FYI, regulatory authorities have made it pretty clear that QR codes, links to websites, and other such methods that separate the required information from the product itself are not acceptable forms of the Supplemental Label. Stick to a hang tag, a peel-back label, or a piece of paper inserted into the packaging to be on the safe side.
Packaging area number two relates to children. Cali regulations are hot on ensuring that cannabis packaging is first and foremost unappealing to children. However, it also demands that it’s deliberately designed to keep children out.
According to the standards set out in the federal Poison Prevention Packaging Act of 1970 (PPPA, 16 CFR §1700.1), Child Resistant Packaging (CRP) refers to all packaging designs that are deliberately difficult for under fives to open. In California, there are two types of CRP – Single Use and Multiple Use – both of which can only be considered child-resistant if the PPPA has awarded certification. If you’re unsure as to whether your packaging will meet Cali regulations or not, get in touch and we’ll check everything over for you.
Will Lola Lola be able to continue using their beautiful packaging?
Edibles in California have been slammed with additional regulations. Just to be clear, cannabis edibles are considered to be all products similar to traditional food products, including cakes, cookies, beverages, juices, tea, coffee, chocolates, gummies, gum, and mints. So, if you need to package a cannabis edible, here’s what you should do:
First up, ALL EDIBLES must be packaged in Multiple Use packaging. This is packaging that can be opened and resealed as many times as necessary. Then there’s the labels to consider…
- Make sure the phrase “Cannabis-Infused” is featured above the product identity and printed in a larger font size than that of the product identity.
- List the 9-THC and CBD levels of your product per serving in milligrams.
- List the sodium, sugar, carbohydrates, and fat content of your product per serving in grams.
- List any allergens that are found in your product, for example allergens related to milk, egg, tree nuts, wheat, peanuts, soybeans, fish, or crustacean shellfish.
- Use the specific food name when listing allergens. For example, almonds should be listed as “almonds” and not as “tree nuts”.
- Disclose any artificial food colorings used.
And, that’s a wrap, folks! If you have any questions or concerns, or if you need any advice relating to any area, feel free to contact us. We’re here to help.
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