California wants to require a lot of stuff on cannabis labels

California Cannabis Warning SymbolDepending on how quickly the California Bureau of Marijuana Control (BMC) gets their final regulations and licensing system in place, you may see the first products on the shelf under the new medical cannabis regs as soon as January 1st. Based on the initial dump of proposed regulations by three different agencies in California, you’re going to see a lot of words on those labels.

The rules that determine what can or can’t go on a medical cannabis label can be found at the bottom of the proposed regulations developed by the Department of Health’s new office of Manufactured Cannabis Safety.

What’s not allowed

  • Saying the plants were grown in a county, or including the name of the county on the label, if they weren’t actually grown there
  • Anything that might be attractive to kids, including but not limited to cartoons, images, characters, or popular phrases used to advertise to kids
  • Imitation of candy packaging or labeling (no gummies, chocolates, etc. that resemble actual candy products)
  • Any false or misleading statements
  • Any claims of health, “or other physical” benefits

What’s required on the Primary Panel

Every product is required to have both a “primary panel” and “informational panel” on the label that are “unobstructed and conspicuous”. The primary panel must have the following:

  • Product Identity (generic name of the product type)
  • The words “cannabis-infused” immediately above the Product Identity
  • The cannabis product symbol (see red triangle symbol above)
  • Net weight or volume
  • THC content in mg per package
  • CBD content in mg per package
  • THC content per serving, in mg per serving
  • CBD connect per serving, in mg per serving
  • Content of other cannabinoids or terpenes per serving, but only if verified by a licensed testing lab
  • 6 point font minimum for all required info

What’s required on the Information Panel

  • Licensed manufacturer name
  • Manufacturer contact number or website address
  • Date of manufacture
  • 6 different required government warning statements
    • “SCHEDULE I CONTROLLED SUBSTANCE”
    • “KEEP OUT OF RECH OF CHILDREN AND ANIMALS” – this one must be in bold print
    • “FOR MEDICAL USE ONLY”
    • “IF PREGNANT OR BREASTFEEDING, CONSULT A PHYSICIAN PRIOR TO USE”
    • “THE INTOXICATING EFFECTS OF THIS PRODUCT MAY BE DELAYED BY UP TO TWO HOURS”
    • “THIS PRODUCT MAY IMPAIR THE ABILITY TO DRIVE OR OPERATE MACHINERY, PLEASE USE EXTREME CAUTION”
  • A list of all product ingredients
  • For edible products:
    • Allergen disclosure – “contains …”
    • Names of artificial food colorings
    • Amount of sodium, sugar, carbohydrates, and total fat per serving, all in grams
  • The lot number
  • Instructions for use
  • Product expiration date – either “use by …” or “best by …”
  • The unique identifier. Note: it’s a little unclear what this is exactly. It seems like the manufacturer assigns unique identifiers to every product within a batch.
  • Minimum 6 point font for all required information

As you can see, that’s a ton of information. It will be really hard for consumers to see the signal through the noise with these requirements. I’ll have more thoughts to come on some alternatives to requiring so much stuff on the label (hint: less is more).

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