Harris Bricken: The Minefield of California Cannabis Labels

CANNANNEW REPORT

Published via LexBlog Over the last few years, I’ve been asked to review dozens and dozens of mockup cannabis labeling material to see whether they comply with California’s complex cannabis labeling requirements. I can’t recall a single instance in which I didn’t catch at least a few problems that needed changing. Mistakes in mockup cannabis labels speaks less to sophistication of cannabis businesses–I’ve seen even extremely sophisticated businesses provide draft labels with mistakes–but instead to California’s over-regulation. There are simply too many rules about what must be included, and what is forbidden, on labels. All of this springs from the Medicinal and Adult-Use Cannabis Regulation and Safety Act (MAUCRSA), which has detailed requirements for things that must go on the label such as a long, all caps warning that the package contains cannabis (duh), etc. As an aside, there are actually two different government warnings, one for cannabis and another for cannabis products, and I regularly see these getting mixed up! The California Department of Public Health (CDPH), which regulates cannabis manufacturers, issued regulations under MAUCRSA to expand on labeling requirements. The rules for manufactured products (vapes, oils, dabs, etc.) are different from those for flower or non-infused pre-rolls in many situations. Even within the category of manufactured products, there are additional rules for edibles. There are special rules for packaging and how to make it child-resistant. And if you are thinking about having separable interior packaging, guess what– even more different rules! There are rules for font size, color, boldness, and the size of a certain required “universal symbol” which looks like a cannabis leaf inside a triangle (because of course a large, capitalized, bolded government warning isn’t enough). And by the way, the universal symbol’s size rules change for the interior and exterior packaging. The rules require labeling cannabis with…

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Source : Harris Bricken: The Minefield of California Cannabis Labels

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