VIDEO: California Cannabis Packaging Compliance
June 23, 2018
Watch the video from our panel discussion on cannabis packaging requirements and compliance in California.
Dr. Juli Crockett, former Chief Compliance Officer of W Vapes and current Director of Compliance for MMLG.
Christina Dempsey, Education, Training & Outreach Manager – Manufactured Cannabis Safety Branch, California Department of Public Health
Courtney Freeman, product development expert and Founder, White Buffalo Spirit
Andrew Hopkins, Director, Compliance and Logistics, The Werc Shop
James Eichner, CEO, Sana Packaging
Cannabis Packaging Primer – The Nuts and Bolts of Packaging Compliance
The state of California has released symbols to be used on all packaging for recreational cannabis. It is available for download as a jpeg, a PNG, or a PDF. The symbol is black. Do not change it to red, white, blue, or any other color. If you have black (dark) packaging, create a white circle around the black symbol.
The primary panel is the portion of the label that is most likely to be displayed to the consumer at retail. Primary panel labeling must include:
- The identity of the product
- The amount of THC/CBD in the package
- The CDPH-issued universal symbol
- The net weight or volume
In addition, primary paneling for edible products must include the words “cannabis-infused” and contain the amount of THC/CBD per serving.
The informational panel can be located anywhere else on the package. Informational panel labeling requirements include:
- The manufacturer’s name and contact information (website or phone number)
- The date the product was manufactured
- The government warning statement
- The ingredient list
- Instructions for use
- The expiration date
- The unique ID/batch number
The Government warning required (in bold print) on the panel:
GOVERNMENT WARNING: THIS PRODUCT CONTAINS CANNABIS, A SCHEDULE I CONTROLLED SUBSTANCE. KEEP OUT OF REACH OF CHILDREN AND ANIMALS. CANNABIS 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 CANNABIS PRODUCTS MAY BE DELAYED UP TO TWO HOURS. CANNABIS USE WHILE PREGNANT OR BREASTFEEDING MAY BE HARMFUL. CONSUMPTION OF CANNABIS PRODUCTS IMPAIRS YOUR ABILITY TO DRIVE AND OPERATE MACHINERY. PLEASE USE EXTREME CAUTION.
In addition, the informational panel for edible products must also contain allergen information, a list of artificial food colorings and basic nutritional information (the amount of sodium, sugar, carbohydrates and fat per serving). Medicinal products must be labeled “For Medicinal Use Only.”
Any of the informational panel information can be included on a supplemental label (for example, if it doesn’t fit because your product is small), except for the government warning. That must be on an informational panel and cannot be demoted to a supplemental label.
Examples of supplemental labels include a paper inserted into the packaging, a hang tag or a peel-back label.
Pro Tip (from Andrew Hopkins, Director of Compliance, The Werc Shop)
Don’t pre-print potency.
Use stickers for your cannabinoid content levels (THC, CBD) rather than preprinting potency on the permanent packaging. You are allowed a +- 10% variance on those listed cannabinoids in the BCC state testing laboratory requirements, so if a batch is beyond the variance, and you print the potency on the permanent packaging, what do you do? Do your final potency testing and then print content level stickers.
If you list any other cannabanoids, such as THCA, CBDA, the same rules apply, your labeling needs to be within 10% accuracy. This is much harder when you have 1 milligram of an ingredient in a dose, you only have 0.1mg wiggle room. It’s more likely that you’ll skew outside the 10% allowable variance.
The only products that have to be in opaque packaging are edibles.
You can include statements about characteristic anticipated effects on your packaging to inform consumer how they might feel when taking the product, such as drowsy, relaxing, etc. Do not get into anything disease or condition related.
You cannot include labeling or images that are attractive to children as determined by the department on a case by case basis. If you have a question about something on your label, the CDPH will review packaging on a case by case basis. The CDPH looks at the totality of the package. If it’s an adult themed package but has a graphic or drawing on it, they may still determine that it is not attractive to children. Joe Camel? Probably attractive to children.
Prop 65 Label / Warning requirements change at the end of August 2018.