Practical Tips for the Packaging and Labeling of Cannabis Drinks
If you are thinking to launch a new line of Cannabis Drinks, here are some practical helpful tips and suggestions on packaging & labeling.
In today’s patchwork legislative environment for cannabis, it can sometimes seem as if there are as many different ways to package and label cannabis drinks as there are actual products themselves. Right now, there are 8 U.S. states (and the District of Columbia) that allow cannabis products for recreational use. However, what works in Colorado might not work in California. And what works in California might not work in Oregon or Washington State or Nevada.
To help simplify matters – and to make it easier for new cannabis products (such as new cannabis drinks) to make it to market – the Council on Responsible Cannabis Regulation (CRCR) and the National Cannabis Industry Association recently partnered on a landmark document that outlines a series of best practices on packaging and labeling for all cannabis products. Thus, if you are thinking about launching a new line of cannabis drinks, it’s worth paying attention to the practical tips and suggestions included in that document.
While the document is relevant to the cannabis industry, the goal of the document is to provide a working roadmap for regulators at both the state and federal level. Sooner or later, more regulation is coming to the cannabis industry, and this roadmap is designed to help regulators, lawmakers, and industry players recognize overall best practices.
The overarching goal, of course, is to protect consumer health and safety. But the report lists a number of secondary goals – such as making sure that state laws align with federal regulations, and that packaging and labeling regulations are as uniform as possible across state lines.
The starting point for thinking about packaging and labeling is simply making sure that the font and type size on the label is uniform. The document provides very specific guidelines on what’s desirable. This is based on common sense, not on abstract rules or guesswork. For example, the best practice recommendation is that the font and type size found on cannabis products should be similar to what consumers now see on packaged food products. Makes sense, right?
Moreover, while companies have wide latitude in coming up with creative brand names for their products, they should always use the common or usual name of the product – “Cannabis” – right there on the packaging. The best practice recommendation is that the cannabis industry should follow the lead of the dietary supplement industry when it comes to clearly defining what their product is and how it should be used.
And, since consumer public health and safety is such a major concern, the best practice recommendation is for the name and contact information (i.e. phone or email) of the licensee to appear directly on the packaging. In this case, the licensee is the company or entity that dispensed or produced the finished product. The idea here is simple and rooted in common sense – if consumers have product complaints or inquiries, they should know whom to contact.
Overall, the CRCR and the National Cannabis Industry Association came up with a list of 15 different labeling recommendations, covering such topics as:
- Net quantity of contents
- License number and batch or lot code
- Ingredients list
- Allergen labeling
- Nutrition facts
- Contaminant testing statement
In addition, the two organizations came up with a list of 5 different packaging recommendations. These are all based on common sense, and not intended at all to be burdensome to cannabis product manufacturers. For example, who could argue with the recommendation that cannabis packaging should be child-resistant? Or that packaging should be opaque rather than transparent so that children and young minors cannot see the contents?
Overall, these recommendations on packaging and labeling are designed to help inform regulators, as well as provide guidance for producers, manufacturers and licensees thinking about getting into the cannabis industry. If you are thinking about bringing a new cannabis drinks product to market, it’s worth becoming familiar not just with the thinking that informed this document, but also with the 20 different recommendations on packaging and labeling.