California’s cannabis packaging requirements are detailed & specific, particularly when it comes to labeling. The state’s Department of Public Health (CDPH) has issued guidelines for how cannabis products must be labeled and packaged. Here’s a breakdown:
1. Primary Panel vs. Informational Panel
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Primary Panel: This is the part of the label most likely to be seen by the consumer—typically the front or top of the packaging. It should include essential details like:
- Universal symbol: The California cannabis symbol, which must be in black and at least 0.5” x 0.5” in size.
- Product identity: A generic name or description of the product, such as "vape cartridge" or "edible chocolate."
- Net weight or volume: Listed in both metric and U.S. customary units.
- For edibles: The phrase "Cannabis-Infused" must appear above the product identity, in a larger, bold font.
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Informational Panel: This includes other details not on the primary panel, often found on the back or sides of the packaging. It must contain:
- Manufacturer’s name and contact information
- Date of manufacture or packaging
- Government warning statements
- Unique identification (UID) number for track-and-trace purposes
- Batch or lot number
- Instructions for use, including preparation methods if applicable
- Full list of ingredients in descending order by weight
- Allergen warnings and artificial coloring details, if relevant.
2. Supplemental Labeling
- For smaller packages where all required information doesn’t fit, businesses can use supplemental labels such as hang-tags, peel-back labels, or inserts. However, websites, QR codes, and other methods that remove the required information from the package itself are not permitted.
3. Prohibited Content
- California’s regulations also have strict rules about what cannot appear on cannabis packaging:
- No appeal to children: Cartoons, candy-like images, or anything that could attract minors are prohibited.
- No false or misleading claims: The packaging must not contain unproven health claims or information that could mislead consumers about the product’s effects or ingredients.
- No mention of "organic": The use of the word "organic" is not allowed unless the product has been certified under the USDA National Organic Program, which currently does not apply to cannabis
4. Design
- Clear Information Display: Use at least a 6-point font to meet legal standards.
- Child Resistant: Look for packaging that is child-resistant and tamper-evident as required by law.
- Opaque Edible Packaging: For edible cannabis products, California law requires that the packaging be opaque to reduce the likelihood of attracting children. Photographs or images of the product itself are also prohibited.
5. CA Government Warning:
The California government warning for cannabis products must be in bold and capital letters. It should read:
GOVERNMENT WARNING: THIS PRODUCT CONTAINS CANNABIS, A SCHEDULE I CONTROLLED SUBSTANCE. KEEP OUT OF REACH OF CHILDREN AND ANIMALS. CANNABIS PRODUCTS CAN ONLY BE POSSESSED OR CONSUMED BY PERSONS 21 YEARS OF AGE OR OLDER UNLESS THE PERSON IS A QUALIFIED PATIENT. CANNABIS USE WHILE PREGNANT OR BREASTFEEDING MAY BE HARMFUL. CONSUMPTION OF CANNABIS IMPAIRS YOUR ABILITY TO DRIVE AND OPERATE MACHINERY. PLEASE USE EXTREME CAUTION.
6. Proposition 65 Warning:
WARNING: This product contains marijuana known to the State of California to cause cancer and birth defects or other reproductive harm. For more information, go to www.P65Warnings.ca.gov.
7. California Child-Resistant Packaging Guidelines
1. Single Use ("Initial CRP")
- Definition: Child-resistant when first opened, but no longer child-resistant after that. Must be labeled: “This package is not child-resistant after opening.”
- Example: Heat-sealed mylar bags with a standard zipper. Once opened, they are resealable but no longer child-resistant.
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Products that require single-use CRP:
- Cannabis Flower
- Pre-rolls
- Topicals
- Dab, Shatter, Wax
- Vape Cartridges
2. Multiple Use ("Lifetime CRP")
- Definition: Stays child-resistant through multiple openings. Can be opened, closed, & still remain child-resistant.
- Example: Child-resistant mylar bags. These require a two-step process to open, keeping products safe even after multiple uses.
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Products that require multiple-use CRP:
- Edibles
- Orally-consumed concentrates (e.g., tinctures, capsules)
- Suppositories
Note: Multi-serving packages don't need to be child-resistant if each individual serving is child-resistant.
Summary of Key Statements Required:
- Government Warning (capital letters and bold)
- Proposition 65 Warning
- Universal Cannabis Symbol
- Product Identity
- Net Weight/Volume
- Manufacturer Name & Contact Information
- Date of Manufacture or Packaging
- Batch/Lot Number
- Cannabinoid Content
- Expiration Date (if applicable)
- Allergen Warnings (if applicable)
- "Cannabis-Infused" (for edibles)
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