Jack Praetzellis writes:
On July 1, 2018, California’s Cannabis “transition period” ended for manufactured cannabis products (i.e., edibles). All manufactured cannabis products must now meet California’s (very) specific labeling and packaging regulations.
Among other things, the packaging must include THC and CBD content in milligrams along with the Cannabis “universal symbol” (and no, you can’t change the color).
The “don’ts” are more interesting than the “dos”. Among other things, packaging cannot:
- Include the name of a county in California unless all of the cannabis in the product was grown there.
- Imitate candy packaging or labeling and cannot use the terms candy or candies, or otherwise appeal to those under 21.
- And, in a typically California move, packaging must identify all potential allergens (shellfish, peanuts, etc.).
Manufacturers should take (or, well, should have already taken) a close look at these detailed labeling and packaging requirements. Although some of these regulations may seem excessive, there are high stakes here. Failure to comply with any of the host of California’s Cannabis regulations subjects a licensee to discipline (which may include suspension or revocation of the license). See Cal. Bus & Prof Code §§ 26030-26031.
Jack Praetzellis is an associate in the Litigation Department, resident in the San Francisco office.