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Packaging Requirements For Cannabis & Manufactured Cannabis Products

Updated

OVERVIEW

The Medicinal and Adult-Use Cannabis Regulation and Safety Act (MAUCRSA) includes basic requirements for how cannabis and cannabis products must be packaged before sale. These guidelines apply to all flower, pre-rolls and manufactured cannabis products sold within California.

 

PACKAGING CHECKLIST

  • Tamper Evident - A consumer knows if the package has been opened. Example: a plastic seal, a sticker across the lid that is ripped when opened, a jar with a lid that pops up after opening, etc.

  • Child Resistant - The package is designed to be difficult for children under five years of age to open. See below for more information about what qualifies as child resistant.

  • Resealable (for products with multiple uses) - The package can be closed after each use. Example: a lid, adhesive closure, box top closure, etc.

  • Opaque (for edibles only)* - The package is not transparent; consumers cannot see the product through the packaging. *Amber-colored bottles are considered opaque.

*Note: Opaque bottles used for beverages may use a single, vertical, clear strip less than 0.25” wide to indicate serving sizes.

 

CHILD-RESISTANT PACKAGING (CRP)

State law requires all cannabis and cannabis products to be in child-resistant packaging. Until December 31, 2019, a child-resistant exit package, used by a retailer at the time of sale, may be used to fulfill the CRP requirement. Beginning January 1, 2020, every individual product must be in a child-resistant package.

 

WHAT QUALIFIES AS CHILD-RESISTANT PACKAGING?

  • Packages that have been certified as child-resistant, in accordance with the federal Poison Prevention Packaging Act (PPPA, 16 CFR §1700.1)

  • A bottle sealed with a pry-off metal crown bottle cap.

  • Plastic packaging that is at least 4 mils. thick and heat-sealed without an easy-open tab, dimple, corner or flap.

TYPES OF CRP?

  • Single Use (“Initial CRP”) - the package is initially child-resistant, but once opened, it is no longer child-resistant. If used, the package’s label must say “This package is not child-resistant after opening.”

  • Multiple Use (“Lifetime CRP”) - the package maintains its child-resistance throughout the life of the package. It can be opened and closed, but still remains child-resistant.

WHAT REQUIRES INITIAL CRP?

  • Flower and flower-only pre-rolls

  • Inhaled concentrates (infused pre-rolls, vape cartridges, shatter, wax, etc.)

  • Topicals

  • Single-serving cannabis products

WHAT REQUIRES LIFETIME CRP?

  • Edibles

  • Orally-consumed concentrates (tinctures, capsules, etc.)

  • Suppositories

* Note: A package containing multiple servings is not required to be in lifetime CRP if each individual serving is in child-resistant packaging.

DOs

  • Cannabis flower may be packaged by a cultivator, manufacturer or distributor. Manufactured cannabis products must be packaged and labeled by the manufacturer prior to transfer to a distributor as finished products.

  • Protect products from contamination and exposure to any toxic or harmful substances

  • If a product has multiple layers of packaging, the packaging requirements can be fulfilled using any one of those layers.

DON’Ts

  • Cannot imitate packaging used for products typically marketed to children.

  • Cannot imitate packaging used for non-cannabis food products.

* Visit the CDPH website for more information on the packaging and labeling requirements: www.cdph.ca.gov/mcsb

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