Are you facing certain difficulties regarding CBD product labeling and packaging? Well of course! CBD is a rapidly worldwide growing market. If you're operating your business in California State and newly stepped into the zone, our guide for labeling and packaging CBD products will aid you much.
The below guidelines are sourced from notification proposed by California Cannabis Agencies dated Jan 16, 2019. If you're operating a licensed Cannabis work you must have to comply with Packaging and Labeling regulations to deal with all CBD and CBD-infused products sold within California.
Packaging and Labeling Recommendations by California Cannabis Agencies:
What you must consider during labeling and Packaging a CBD product beforehand presenting it to your customers, are the regulations put forward by the California Department of Public Health (CPDH). The updated notification holds labeling and Packaging recommendations for Cannabis (flower rolls and Pre-rolls) and Cannabis (extract) Manufactured goods.
To help individuals further with compliance, the notification holds Master Packaging and Labeling FAQ's, just tap on the highlighted bar to review the relevant resources.
General Guidelines for Packaging:
CBD Packaging - Opaque Containers
All cannabis flowers, pre-rolls, and manufactured cannabis goods must be packed in compliance with the following requirements stated by The Medicinal and Adult-Use Cannabis Regulation and Safety Act (MAUCRSA).
There Must Be a Tamper-evident Seal:
A tamper-evident seal reveals whether the contents of the product are initially touched or not it's a plastic seal or sticker around the lid. In case the seal is not attached with the protective cover of the product a consumer has visible evidence of its tempering.
The Product Packaging Must Bear a Resealable Property:
An ideal product packaging design is one that holds a resealable feature (such as lids, adhesive closure, box top closures, etc.), recommended for products with multiple usages. This will ensure its safety from any sort of exterior contamination through light, moisture, oxygen, etc., further, it prevents the risk of child consumption.
Consider Only Opaque Packaging for CBD-infused Edible Products:
It is difficult to see the inside contents of the product from opaque packaging unlike transparent. Opaque bottles such as Amber colored are preferred for beverages (e.g. syrups or energy boosters) and oral medicines (e.g. bottles for tablets). Such a type of packaging is designated to aid child-resistance.
The Packaging Property Must Bear Child Resistance:
It means that the package is designed in such a way that it's difficult to open for children aged fewer than 5. Smoking dried hemp and Marijuana flower buds and relevant cannabis products can cause serious hazardous impacts on them thus it must bear a Child Resistant Packaging (CRP).
What's More to Know About CRP?
The package must say about initial CRP if it is intended for single-use, whereas the initial CRP tag generally implies to flower and flower only pre-rolls, inhaled concentrates (vape and cartridges), and single-serving cannabis products.
The product must hold a lifetime CRP statement if it facilitates multiple servings 'through a single product'. It means the packaging is child-resistant as long as the product constituents end up. This tag is supported with edibles, orally consumed concentrates (tinctures and capsules, etc.), and suppositories.
The packaging needs to get certified as 'Child Resistant' by relevant authorities (by the PPPA act)
The container's closures or caps must be sealed with a pry-off crown technique.
Further, the packaging needs a 4 mil thicker protective plastic covering, must be perfectly heat sealed with no tab, dimple, or flap that discourages easy opening.
For Every Packaging
It Should Have
Packaging recommendations can be satisfied in any of the layers if the product holds a multi-layered packaging procedure
Make sure the products and their constituents are safeguarded from external toxic elements
It Shouldn't Have
Product packaging must not show any resemblance or identical to marketed children products
The packaging outlook must differ from those of non-cannabis food products.
Guidelines for labeling Cannabis (flower and flower-only pre-rolls)
CBD Pre-roll Packaging
All cannabis flower and flower-only pre-rolls must be labeled properly and all the significant details regarding the product must fall under primary and informational panel categories.
The first and foremost thing that communicates with your regular and potential buyers is your brand identity, which is displayed through the Primary Panel at the front of your packaging. This is the part of the label which includes 3 key features.
The 'principal display panel' must patently display product identity:
It contains a short description of the product's common or usual name from which a person can easily distinguish the product type, for instance, flower or pre-rolls.
Net weight/ Net quantity of contents must forefront the packaging:
The Net content measurements have to be displayed in metric (say grams) and U.S customary units (say ounces), as per guided by regulations.
The Universal Symbol of California must associate the PDP Panel:
When consumers desire more information they ultimately review the informational panel. This part can be stated elsewhere on the product besides the PDP panel. It generally includes the following data.
It is mandatory to include UID number to this label:
Receive your UID number from the California Cannabis Track-and-Trace system. Once you hold it, this requirement becomes necessary to get included. Moreover, it is prohibited to create a placeholder UID number, instead of leaving a blank place is recommended unless you load your UID number.
Include license name and contact details or website:
The legal business name or the registered DBA of the concerned licensee must be mentioned, along with the phone number or contact details. These worthy details on the informational panel added to your inner packaging of CBD products, will let consumers easily communicate their concerns with the manufacturer or retailer.
Mention caution or warning statement if any:
Explicit if any statement provided by the Government that associates the product say for medical cannabis products highlight 'FOR MEDICAL USE ONLY'. Also, bold and capitalized fonts are recommended.
Depending upon the applicability, a Prop 65 warning must be stated clearly if aware that its chemical composition can cause any serious harm on exposure to certain individuals such as cancer, birth defects, or any reproductive harm.
Manufacturing date must be disclosed on products exterior:
The date on which the finished product is manufactured significantly impacts its shelf presence. Also, the manufacturing date must be accompanied by month, day, and year.
Cannabinoid content of ingredients needs to be declared on the informational panel:
For all CBD products, there must be a full declaration of ingredients, whereas the cannabinoid contents (such as concentration or amount of THC and CBD) present in the container are generally expressed in percentage (%.
For every label
It shouldn't have:
Do not mention the country name of California unless all cannabis sources relate to inland cultivation.
Any biased or misleading information imprinted regarding the product and its content is prohibited, For instance, labeling a product 'organic' whilst it is uncertified.
The exterior labeling design must not include any cartoon or comic characters, kid's images, or words that interest minors.
Any health claims mustn't be included if it doesn't support the publicly available criteria of peer-reviewed evidence.
It should have:
Use English as a medium with a font that is easily readable; at least 6 points sized font and is recommended.
During labeling, individuals must concern the layout of information in a clear and legit way.
All the essential labeling information must be visible and securely affixed at the exterior layer of the packaging.
It is allowed to add an authentic piece of information other than recommended ones unless it is not misleading.
Guidelines for labeling Cannabis manufactured products
CBD-infused products range
Any authorized individual must verify these important recommendations included in their CBD-infused edible, cosmetic, and ailments curing product labels.
Like earlier, these basic labeling requirements are placed on the outer layer of packaging, which fall under two below-listed categories, based on the part of the packaging where it belongs.
Primary display Panel:
All the information regarding product identity (for instance, edible gummies), Net weight g or oz. or fl oz. and ml by volume, and Universal symbol have to be displayed typically at the front and top of the outer layer of packaging.
Informational display panel:
For the rest of the details apart from PDP, such as Registered Name and place of business, contact details or a QR code, Ingredient declaration, warning or caution statements, Disclosure of material facts such as health claims or any other desired information are listed on the Information display panel,.
Some additional labeling details regarding manufactured cannabis products:
There might be two key concerns regarding it.
If your product holds multiple packaging layers,
The basic PDP requirement apart from mentioning it to the other layers is mandatory to be infused on the inner container which is in direct physical contact with the product.
Any inhaled Cannabis product layout (such as cartridges, vape, shatter, or wax) must exhibit the Universal symbol, whereas for Non- inhaled Cannabis products ( such as edibles, tinctures, topical, etc.) the word Cannabis-infused must be included along with the product identity, a universal symbol, and net weight or volume details.
If your product packaging holds too little space to get listed all the required information on the outer layer.
Suppose your tincture bottle is too small to fit in all the required details, to fix this it is recommended for the leftover information to be presented using a leaflet, hangtag, peel-back labels, and inserts. It is important to note that QR codes, websites, and other methods are not part of supplemental labeling; they just serve as a source of contact to deal with product complaints and inquiries.
For every label
It should have
Make sure you display all the information in a readable format with clear and legit wordings using English as a medium language along with a 6 point font size or more.
Confirm all suggested labeling requirements are displayed on the outer layer of Packaging, whereas an insufficient package space could be supplemented by hangtags and inserts etc.
It shouldn't have
You cannot state California as the products place of origin unless all of its constituents are sourced by the country
Any inappropriate and unauthorized statement regarding products such as false health claims is considered as an act of violation of the labeling requirements, which could even lead you to federal prosecution
You must confirm that each of your edible cannabis products does not hold any sort of picture; rather it comes in an opaque covering. This initiative is an attempt by the state to reduce the risk of children's attraction towards the product.
There goes a label restriction that you cannot market your product as an alcoholic beverage, as notified by the Bureau of Cannabis Control regulations.
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