Guide to Marijuana Packaging and Labeling Requirements · 2016-07-18 · Guide to Marijuana...

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Guide to Marijuana Packaging and Labeling Requirements ALASKA: The state government has until November 24, 2015, to develop regulations for its Marijuana Control Board. The rules will likely include labeling requirements. ARIZONA: R9-17-317 Product Labeling and Analysis 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 registration 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 nonorganic 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 medical marijuana;

Transcript of Guide to Marijuana Packaging and Labeling Requirements · 2016-07-18 · Guide to Marijuana...

Page 1: Guide to Marijuana Packaging and Labeling Requirements · 2016-07-18 · Guide to Marijuana Packaging and Labeling Requirements ALASKA: The state government has until November 24,

Guide to Marijuana Packaging and Labeling Requirements ALASKA: The state government has until November 24, 2015, to develop regulations for its Marijuana Control Board. The rules will likely include labeling requirements. ARIZONA:R9-17-317 Product Labeling and Analysis 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 registration 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 nonorganic 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 medical marijuana;

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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 and production 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. CALIFORNIA:No statewide labeling regulations. COLORADO:R 1000 Series — Labeling, Packaging, and Product Safety Extensive regulations detailed in the above link. Summarized here by Denver city government: – Before sale to a consumer, a retail marijuana store must place any of these products in a container that is child-resistant or place the container in an ‘exit package’ that is child resistant. – ‘Child resistant’ packaging must conform to federal consumer product safety regulations and an ASTM standard; be opaque so the product cannot be seen; be closable if not intended for single use; and be properly labeled pursuant to the Retail Code. – Proper labeling includes specific warning statements for each of the three product types; Colorado’s Universal Symbol indicating the container holds marijuana; a list of all nonorganic pesticides, fungicides and herbicides used to produce the marijuana; and a list of solvents and chemicals used to produce marijuana concentrate. – Use of certain pesticides and chemicals is prohibited. – Containers for edible marijuana products must be labeled with all ingredients, if refrigeration is required, standard serving limit and expiration date. – Other statements are required if testing was performed for potency or contaminants.

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CONNECTICUT:Sec. 21a-408-40 Labeling of marijuana products by dispensary (a) A dispensary shall not dispense marijuana that does not bear the producer label required pursuant to section 21a-408-56 of the Regulations of Connecticut State Agencies. (b) All marijuana products dispensed shall be completely and properly labeled by the dispensary, or by the dispensary technician under the direct supervision of the dispensary, with all required information as follows: (1) the serial number, as assigned by the dispensary facility; (2) the date of dispensing the marijuana; (3) the quantity of marijuana dispensed; (4) the name and registration certificate number of the qualifying patient and, where applicable, the primary caregiver; (5) the name of the certifying physician; (6) such directions for use as may be included in the physician’s written certification or otherwise provided by the physician; (7) name of the dispensary; (8) name and address of the dispensary facility; (9) any cautionary statement as may be required by state statute or regulation; and (10) a prominently printed expiration date based on the producer’s recommended conditions of use and storage that can be read and understood by the ordinary individual. (c) The expiration date required by this section shall be no later than the expiration date determined by the producer. (d) No person except a dispensary, or a dispensary technician operating under the direct supervision of a dispensary, shall alter, deface or remove any label so affixed. DELAWARE: Administrative Code 4470 – State of Delaware Medical Marijuana Code 7.3.10 a description of the packaging of the useable marijuana that the compassion center shall be utilizing which shall, as a minimum, include:

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7.3.10.1 the name of the strain, batch, and quantity; 7.3.10.2 the statement “this product is for medical use only, not for resale;” and 7.3.10.3 details indicating (1) the medical marijuana is free of contaminants and (2) the levels of active ingredients in the product. HAWAII: No statewide regulations, but the state’s website directs to a public policy page that says: “Hawaii House Concurrent Resolution 48 (relating to Medical Marijuana Dispensaries) requested that the College of Social Sciences Public Policy Center convene and facilitate a Task Force to “develop recommendations for the establishment of a regulated statewide dispensary system for medical marijuana.” Still in progress. ILLINOIS: Section 80(A)(3) Compassionate Use of Medical Cannabis Pilot Program Act (3) All items shall be individually wrapped at the original point of preparation. The packaging of the medical cannabis infused product shall conform to the labeling requirements of the Illinois Food, Drug and Cosmetic Act and shall include the following information on each product offered for sale or distribution: (A) the name and address of the registered cultivation center where the item was manufactured; (B) the common or usual name of the item; (C) all ingredients of the item, including any colors, artificial flavors, and preservatives, listed in descending order by predominance of weight shown with common or usual names; (D) the following phrase: “This product was produced in a medical cannabis cultivation center not subject to public health inspection that may also process common food allergens.”; (E) allergen labeling as specified in the Federal Food, Drug and Cosmetics Act, Federal Fair Packaging and Labeling Act, and the Illinois Food, Drug and Cosmetic Act; (F) the pre-mixed total weight (in ounces or grams) of usable cannabis in the package;

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(G) a warning that the item is a medical cannabis infused product and not a food must be distinctly and clearly legible on the front of the package; (H) a clearly legible warning emphasizing that the product contains medical cannabis and is intended for consumption by registered qualifying patients only; and (I) date of manufacture and “use by date.” (4) Any dispensing organization that sells edible cannabis infused products must display a placard that states the following: “Edible cannabis infused products were produced in a kitchen not subject to public health inspections that may also process common food allergens.” The placard shall be no smaller than 24″ tall by 36″ wide, with typed letters no smaller than 2″. The placard shall be clearly visible and readable by customers and shall be written in English. MAINE: Rules Governing the Maine Medical Use of Marijuana Program – 6.13 Trip tickets - Distribution of marijuana for medical use to a qualifying patient or a primary caregiver for use by a qualifying patient must be labeled with a trip ticket to identify the dispensary, the MMMP patient number if the patient is registered or a unique identifier assigned by the dispensary to non-registered qualifying patients, or the MMMP caregiver number if the caregiver is required to be registered or a unique identifier assigned by the dispensary if the primary caregiver is not required to be registered, the product, the amount and form, the time and date of origin, and destination of the product. – 6.13.1 - Primary caregivers shall take reasonable steps to deliver the product directly to the qualifying patient as a safety precaution and to alleviate concerns about drug diversion. – 6.13.2 - A dispensary with a growing location that is not located with the retail dispensary must label the marijuana that is being moved between the growing location and the dispensary with a trip ticket that identifies the name and address of the dispensary, the address of the growing location, the time, date, origin and destination of the material being transported, and the amount and form of marijuana and marijuana material that is being transported. – 6.14 Packaging and labeling – The packaging and labeling of

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prepared marijuana and marijuana products for sale by registered dispensaries and caregivers must comply with applicable State labeling laws. See Maine Revised Statutes, Title 22: HEALTH AND WELFARE §2157. Misbranded food - http://www.mainelegislature.org/legis/statutes/22/title22sec2157.html – 2.7.4.3 Organic certification. Marijuana for medical use may not be labeled “organic” unless the marijuana plants and prepared marijuana are produced, processed, and certified to be consistent with national organic standards in compliance with the laws and regulations promulgated by the United States Department of Agriculture. MARYLAND:Proposed rules included in the Maryland Marijuana Control Act of 2014 [still being debated, not law yet] would require labels that include information on THC concentration, production date, and a warning about driving and minors’ use of marijuana. MASSACHUSETTS: 725.105: Operational Requirements for Registered Marijuana Dispensaries (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;

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(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; 105 CMR: Department of Public Health 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);

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(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.” MICHIGAN:No labeling requirements. MINNESOTA:Statutes 2012, section 13.3806 – 13.24, Subd. 3: Manufacturer; distribution. (5) properly package medical cannabis in compliance with the United States Poison Prevention Packing Act regarding child resistant packaging and exemptions for packaging for elderly patients, and label distributed medical cannabis with a list of all active ingredients and individually identifying information, including: (i) the patient’s name and date of birth; (ii) the name and date of birth of the patient’s registered designated caregiver or, if listed on the registry verification, the name of the patient’s parent or legal guardian, if applicable; (iii) the patient’s registry identification number; (iv) the chemical composition of the medical cannabis; and (v) the dosage MONTANA:No labeling requirements, according to the Montana Department of Public Health and Human Services. NEVADA:CHAPTER 453A – MEDICAL USE OF MARIJUANA - Packaging and Labeling of Marijuana and Related Products NAC €‚453A.500 €‚ €‚Packaging: Generally. 1. €‚ €‚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.

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2. €‚ €‚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. 3. €‚ €‚Marijuana-infused products in liquid form may be sealed using a metal crown cork-style bottle cap. 4. €‚ €‚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. NAC €‚453A.502 €‚ €‚Labeling: Generally. Each cultivation facility, facility for the production of edible marijuana products or marijuana-infused products and medical marijuana dispensary shall: 1. €‚ €‚Use for labeling all marijuana, edible marijuana products and marijuana-infused products the standard label described in NAC 453A.506 to 453A.512, inclusive; 2. €‚ €‚Exercise strict control over labeling materials issued for use in labeling operations for marijuana, edible marijuana products and marijuana-infused products; 3. €‚ €‚Carefully examine labeling materials issued for a batch for identity and conformity to the labeling specified in the applicable production or control records; and 4. €‚ €‚Have and follow written procedures describing in sufficient detail the control procedures employed for the issuance of labeling. NAC €‚453A.504 €‚ €‚Labeling as “organic.” A cultivation facility or facility for the production of edible marijuana products or marijuana-infused products shall not label usable marijuana, edible marijuana products or marijuana-infused products as “organic” unless the marijuana plants used are produced, processed and certified in a manner that is consistent with the national organic standards established by the United States Department of Agriculture in accordance with the Organic Foods Production Act of 1990. NAC €‚453A.506 €‚ €‚Maximum unit size; minimum requirements for font and size of label. 1. €‚ €‚Any medical marijuana establishment that packages marijuana, edible marijuana products or marijuana-infused products must individually package, label and seal the marijuana or marijuana

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products in unit sizes such that no single unit contains more than a 2 1/2 ounce supply of marijuana. 2. €‚ €‚For marijuana, edible marijuana products or marijuana-infused products that are intended to be dispensed or sold to a holder of a valid registry identification card or his or her designated primary caregiver: (a) €‚The text used on all labeling must be printed in at least 10-point font and may not be in italics; and (b) €‚Each label must be at least 2 3/4 inches high by 4 inches wide. NAC €‚453A.508 €‚ €‚Labeling requirements for marijuana and related products for sale to medical marijuana dispensary. 1. €‚ €‚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 terpinoid 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. 2. €‚ €‚The label required by subsection 1 for a container or package containing usable marijuana, edible marijuana products or marijuana-infused products sold by a cultivation facility or facility for the production of edible marijuana products or marijuana-infused products must be in substantially the following form:

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NAC €‚453A.510 €‚ €‚Labeling requirements for usable marijuana sold at retail; accompanying materials 1. €‚ €‚A medical marijuana dispensary must affix to each container or package containing usable marijuana sold at retail a label which must include, without limitation: (a) €‚The business or trade name and the medical marijuana establishment registration certificate number of the cultivation facility that cultivated and sold the usable marijuana. (b) €‚The lot number. (c) €‚The date and quantity dispensed, including the net weight measured in ounces and grams or by volume, as appropriate. (d) €‚The name and registry identification card number of the patient and, if applicable, the name of his or her designated primary caregiver. (e) €‚The name and address of the medical marijuana dispensary. (f) €‚The cannabinoid profile and potency levels and terpinoid profile as determined by the independent testing laboratory. (g) €‚A warning that states: “This product may have intoxicating effects and may be habit forming.”

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(h) €‚The statement: “This product may be unlawful outside of the State of Nevada.” (i) €‚The date on which the marijuana was harvested. 2. €‚The label required by subsection 1 for a container or package containing usable marijuana sold at retail must be in substantially the following form:

(a) €‚“Warning: This product may have intoxicating effects and may be habit forming. Smoking is hazardous to your health.”3. €‚ €‚A medical marijuana dispensary must provide with all usable marijuana sold at retail accompanying material that discloses any pesticides applied to the marijuana plants and growing medium during production and processing and contains the following warnings: (b) €‚“There may be health risks associated with consumption of this product.” (c) €‚“Should not be used by women who are pregnant or breast feeding.” (d) €‚“For use only by the person named on the label of the dispensed product. Keep out of the reach of children.” (e) €‚“Marijuana can impair concentration, coordination and judgment. Do not operate a vehicle or machinery under the influence of this drug.” 4. €‚ €‚The text used on all accompanying material must be printed in at least 12-point font and may not be in italics.

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NAC €‚453A.512 €‚ €‚Labeling requirements for edible marijuana products or marijuana-infused products sold at retail; accompanying materials 1. €‚ €‚A medical marijuana dispensary must affix to each container or package containing edible marijuana products or marijuana-infused products sold at retail a label which must include, without limitation: (a) €‚The business or trade name and the medical marijuana establishment registration certificate number of the facility for the production of edible marijuana products or marijuana-infused products that manufactured and sold the product. (b) €‚The lot numbers of all marijuana used to create the product. (c) €‚The batch number of the product. (d) €‚The date and quantity dispensed, including the net weight in ounces and grams or by volume, as appropriate. (e) €‚The name and registry identification card number of the patient and, if applicable, the name of his or her designated caregiver. (f) €‚The name and address of the medical marijuana dispensary. (g) €‚The date on which the product was manufactured. (h) €‚If the product is perishable, a suggested use-by date. (i) €‚The total milligrams of active cannabinoids and terpinoids in the product, as provided by the independent testing laboratory that tested the product. (j) €‚A list of all ingredients and all major food allergens as identified in 21 U.S.C. § § 343. (k) €‚A warning that states: “Caution: When eaten or swallowed, the intoxicating effects of this drug may be delayed by 2 or more hours.” (l) €‚If a marijuana extract was added to the product, a 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. (m) €‚A warning that states: “This product may have

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intoxicating effects and may be habit forming.” (n) €‚A statement that: “This product may be unlawful outside of the State of Nevada.” 2. €‚ €‚The front and back of the label required by subsection 1 for a container or package containing edible marijuana products or marijuana-infused products sold at retail must be in substantially the following form:

3. €‚ €‚A medical marijuana dispensary must provide with all edible marijuana products and marijuana-infused products sold at retail accompanying material that discloses any pesticides applied to the marijuana plants and growing medium during production of the marijuana used to create the extract added to the edible marijuana products or marijuana-infused products and the type of extraction method used, including, without limitation, any solvents, gases or other chemicals or compounds used to produce or that are added to the extract, and contains the following warnings:

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(a) €‚“There may be health risks associated with consumption of this product.” (b) €‚“This product contains or is infused with marijuana or active compounds of marijuana.” (c) €‚“Should not be used by women who are pregnant or breast feeding.” (d) €‚“For use only by the person named on the label of the dispensed product. Keep out of the 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 2 or more hours.” 4. €‚ €‚The text used on all accompanying material must be printed in at least 12-point font and may not be in italics. NEW HAMPSHIRE:126-X:8 Use of Cannabis for Therapeutic Purposes – Alternative Treatment Centers; Requirements (XIV)(b) - Distributions of cannabis to a qualifying patient or a designated caregiver for use by a qualifying patient shall be labeled with a document to identify the alternative treatment center, the patient’s registry number, or the caregiver’s number, the amount and form, the time and date of origin, and destination of the product. NEW JERSEY:4.3 Standardized Packaging and Dispensing Labels All individual packages of medical marijuana dispensed by an Alternate Treatment Center must bear a ï¬ rmly afï¬ xed label that contains speciï¬ c information including but not limited to the following: • name and address of the Alternate Treatment Center; • quantity of the medical marijuana contained within the package; • THC level and whether the product is designated as low, medium,

or high • strength strain; • date of dispensing to the qualifying patient or primary caregiver; • qualifying patient’s name and registry identiï¬ cation number.

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NEW MEXICO:7.34.4.10(B)(4) – Non-Profit Private Entity Production Application Requirements A description and sample of the packaging of the useable cannabis that the private non-profit entity shall utilize, including a label that shall contain the name of the strain, batch, quantity and a statement that the product is for medical use and not for resale. NEW YORK: §80-1.11(k) Manufacturing requirements for approved medical marihuana products §1004.11 Manufacturing requirements for approved medical marihuana products (g) Approved medical marihuana products shall be limited to the following forms and routes of administration: (1) liquid or oil preparations for metered oromucosal or sublingual administration or administration per tube; (2) metered liquid or oil preparations for vaporization; (3) capsules for oral administration; or (4) any additional form and route of administration approved by the commissioner. Smoking is not an approved route of administration. (5) approved medical marihuana products may not be incorporated into edible food products by the registered organization, unless approved by the commissioner. (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. (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. (j) The registered organization shall identify each lot of approved medical marihuana product with a lot unique identifier.

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(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: (1) the name, address and registration number of the registered organization; (2) the medical marihuana product form and brand designation; (3) the single dose THC and CBD content for the product set forth in milligrams (mg); (4) the medical marihuana product lot unique identifier (lot number or bar code); (5) the quantity included in the package; (6) the date packaged; (7) the date of expiration of the product; (8) the proper storage conditions; (9) language stating: (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”; (ii) “Keep secured at all times”; (iii) “May not be resold or transferred to another person”; (iv) “This product might impair the ability to drive”; (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.”

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OREGON: http://www.oregon.gov/olcc/marijuana/Documents/Packaging_Labeling/PackagingandLabelingGuide.pdf 

General Requirements  Each marijuana item must be packaged in a container that conforms to the rules found in OAR 845‐025‐7000 through 845‐025‐7060. A "container" is a sealed, hard or soft‐bodied receptacle in which a marijuana item is placed. OAR 845‐025‐7060 requires all licensees and registrants who package marijuana items for ultimate sale to a consumer, patient, or designated primary caregiver to get all packages and labels approved through the OLCC pre‐approval process (see Pre‐approval Process Section). If the marijuana item is produced by an OLCC licensee, the package and label must be approved before any marijuana item is sold to a consumer.   If the marijuana item is a single‐serving cannabinoid product or comprised only of usable marijuana, the item can be packaged in a single‐use, child‐resistant package. If the item contains multiple servings of an edible, extract, concentrate, tincture, or topical, the item must be packaged in a resealable, continually child‐resistant package. The marijuana item may be placed directly in a container that meets the child‐resistance standard or the container may be placed in an approved child‐resistant, exit package  

RHODE ISLAND: Section 5.1.8 (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. VERMONT:Section 6:.31 “A dispensary shall include a label on the packaging of all marijuana that is dispensed. The label shall identify the particular strain of marijuana that is contained in the package. Cannabis strains shall be either pure breeds or hybrid varieties of cannabis and shall reflect the properties of the plant. The label shall contain the statement ‘The State of Vermont does not attest to the medicinal value of cannabis.'” WASHINGTON: WAC 314-55-105 (1) All usable marijuana and marijuana-infused products must be stored behind a counter or other barrier to ensure a customer does not have direct access to the product.

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(2) Any container or packaging containing usable marijuana or marijuana-infused products must protect the product from contamination and must not impart any toxic or deleterious substance to the usable marijuana or marijuana product. (3) Upon the request of a retail customer, a retailer must disclose the name of the accredited third-party testing lab and results of the required quality assurance test for any usable marijuana or other marijuana-infused product the customer is considering purchasing. (4) Usable marijuana and marijuana-infused products may not be labeled as organic unless permitted by the United States Department of Agriculture in accordance with the Organic Foods Production Act. (5) The accredited third-party testing lab and required results of the quality assurance test must be included with each lot and disclosed to the customer buying the lot. (6) A marijuana producer must make quality assurance test results available to any processor purchasing product. A marijuana producer must label each lot of marijuana with the following information: (a) Lot number; (b) UBI number of the producer; and (c) Weight of the product. (7) Marijuana-infused products meant to be eaten, swallowed, or inhaled, must be packaged in child resistant packaging in accordance with Title 16 C.F.R. 1700 of the Poison Prevention Packaging Act or use standards specified in this subsection. Marijuana-infused product in solid or liquid form may be packaged in plastic four mil or greater in thickness and be heat sealed with no easy-open tab, dimple, corner, or flap as to make it difficult for a child to open and as a tamperproof measure. Marijuana-infused product in liquid form may also be sealed using a metal crown cork style bottle cap. (8) A processor may provide a retailer free samples of usable marijuana packaged in a sample jar protected by a plastic or metal mesh screen to allow customers to smell the product before purchase. The sample jar may not contain more than three and one-half grams of usable marijuana. The sample jar and the usable marijuana within may not be sold to a customer and must be returned to the licensed processor who provided the usable marijuana and sample jar. (9) A producer or processor may not treat or otherwise adulterate usable marijuana with any organic or nonorganic chemical or other

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compound whatsoever to alter the color, appearance, weight, or smell of the usable marijuana. (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-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”;

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(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; (b) Lot number; (c) Concentration of THC, THCA, CBD, including a total of active cannabinoids (potency profile); (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. (14) Sample label mock up for a container or package containing usable marijuana sold at retail with required information:

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(a) The business or trade name and Washington state unified business identifier number of the licensees that produced, processed, and sold the usable marijuana; (15) Labels affixed to the container or package containing marijuana-infused products sold at retail must include: (b) Lot numbers of all base marijuana used to create the extract; (c) Batch number; (d) Date manufactured; (e) Best by date; (f) 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; (g) Net weight in ounces and grams, or volume as appropriate; (h) List of all ingredients and any allergens; (i) “Caution: When eaten or swallowed, the intoxicating effects of this drug may be delayed by two or more hours.”; (j) If a marijuana extract was added to the product,

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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; (k) Warnings that state: “This product has intoxicating effects and may be habit forming”; (l) Statement that “This product may be unlawful outside of Washington state”; (m) The board may create a logo that must be placed on all usable marijuana and marijuana-infused products. (16) Sample label mock up (front and back) for a container or package containing marijuana-infused products sold at retail with required information:

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