Manufactured Cannabis Product Labeling Requirements – Nabis Support

OVERVIEW

This article outlines California's cannabis labeling rules, separating requirements into the primary panel (e.g., product name, universal symbol, net weight) and informational panel (e.g., ingredients, warnings, UID, manufacturer details). It also details prohibited practices—like using misleading claims or child-attractive designs—and clarifies FAQs around supplemental labels, small packaging, and the distinction between batch and UID numbers.

PRIMARY PANEL

The part of the label displayed to consumers at retail; typically the front or top of the package.

Product Identity - A generic or common name that describes the product. Examples include chocolate, fruit chew, vape cartridge, lotion, tincture, etc.
Universal Symbol (in black, at least 0.5” x 0.5”) - The California symbol that identifies items as containing cannabis. Download the symbol at www.cdph.ca.gov/mcsb
Net Weight or Volume (in both metric and U.S. customary units) - The weight or volume of the contents of the package.
Edible Cannabis Product Labels Must Also Include: “Cannabis-Infused” - These words must be listed above the product identity, in a bold font and larger text size than the one used for the product identity.

INFORMATIONAL PANEL

Any part of the label that is not the primary panel.

Manufacturer Name and Contact Information* - Must be a name listed on the license certificate (either the legal business name or the registered DBA), and their phone number or website.
Date of Manufacture/Packaging* - One date may be used. Include month, day and year. (Example: MFG/PKG: 02/23/19)
Government Warning Statement for Manufactured Cannabis Products* - (in CAPITAL, bold letters, and at least 6 point font)

“GOVERNMENT WARNING: THIS PRODUCT CONTAINS CANNABIS, A SCHEDULE I CONTROLLED SUBSTANCE. KEEP OUT OF REACH OF CHILDREN AND ANIMALS. CANNABIS PRODUCTS MAY ONLY BE POSSESSED OR CONSUMED BY PERSONS 21 YEARS OF AGE OR OLDER UNLESS THE PERSON IS A QUALIFIED PATIENT. THE INTOXICATING EFFECTS OF CANNABIS PRODUCTS MAY BE DELAYED UP TO TWO HOURS. CANNABIS USE WHILE PREGNANT OR BREASTFEEDING MAY BE HARMFUL. CONSUMPTION OF CANNABIS PRODUCTS IMPAIRS YOUR ABILITY TO DRIVE AND OPERATE MACHINERY. PLEASE USE EXTREME CAUTION.”

UID Number - The UID printed on the label should be the one that was on the Metrc Package Tag that was used in the final step of the production batch process. This Package Tag and corresponding UID number represent the completed production batch manufacturing process, when it became an individual unit and was packaged and labeled.
Batch or Lot Number - Batch numbers are numbers generated by a manufacturer that identify the items that are created as part of a single production batch; batch numbers correspond to a manufacturer’s internal batch production records.
Instructions for Use and Any Preparation Needed* - For example, the method of consumption or application.
List of All Ingredients* (in descending order by weight or volume) - Include sub-ingredients, if any
Allergens* (if applicable) - The word “Contains,” followed by a list of any major food allergen in the product. The major food allergens are milk, egg, tree nuts, wheat, peanuts, soybeans, fish or crustacean shellfish. Use the specific food name when disclosing allergens (i.e. “almonds” instead of “tree nuts”).
Artificial Food Colorings* (if applicable)
Expiration, Use-By or Best-By Date* (if applicable)
“KEEP REFRIGERATED” or “REFRIGERATE AFTER OPENING”* (if perishable after opening)
“FOR MEDICAL USE ONLY”* (if applicable) - Manufacturers must include these words on the label if the product contains a THC concentration that can only be sold in the medicinal market.
Edible Product Labels Must Also Include: Sodium, Sugar, Carbohydrates, and Total Fat Per Serving* - in milligrams or grams

* Indicates labeling information that may be placed on a supplemental label.

OTHER LABELING

May be on either the primary or informational panel .

Cannabinoid Content (in milligrams) - Cannabinoid content may be added to the label by the manufacturer before testing or on the distribution premises after testing.
- THC and CBD per package (for all manufactured products)
- THC and CBD per serving (for edibles and concentrates with designated serving sizes)
- Any other cannabinoid that makes up 5% or more of the total cannabinoid content (if labeled after testing)
Prop 65 Warning - Must include: yellow or black and white triangle, WARNING (in capital, bold letters), a link to www.P65Warnings.ca.gov and the proper warning. Please see the appropriate link below for example warning.

CONSUMER PRODUCT EXPOSURE WARNING

SHORT-FORM CONSUMER PRODUCT EXPOSURE WARNING

CRV Recycling (for beverages, if applicable) - Beverage manufacturers are responsible for labeling qualifying beverage containers with recycling information. For more information, visit https://www.calrecycle.ca.gov/bevcontainer

DO

Display information clearly and legibly.
Use English and at least 6 point font.
Ensure all required labeling is displayed on the outer layer of packaging

DON’T (§40410)

California County Names - Unless 100% of cannabis in the product is grown in the county, the name of a California county cannot be included on the label.
Cannot be Attractive to Children - This includes using cartoons, images popularly used to advertise to children, imitating candy labeling, and using the words “candy,” “candies” or a variation, such as “kandy” or “kandeez” anywhere on the label.
Cannot Include False or Misleading Information - This includes anything untrue or unproven, or information that leads consumers to have an inaccurate impression, or the use of the word “organic” anywhere on the label.
Cannot Make Unproven Health Claims - Health-related statements, such as claims about a product’s ability to treat or cure disease, may not be made unless there is significant scientific agreement and the claims are supported by a totality of publicly available peer-reviewed evidence. Anecdotal information and preliminary study results do not meet this criteria. Health-related statements are heavily regulated by the FDA, and cannabis businesses are not exempt from federal prosecution for misleading health statements.
Cannot Include a Picture of The Product (for edible cannabis products only) - State law required edibles to be in opaque packaging to reduce the risk that a child would be attracted to the product. Photographs or other images of the product cannot be on the label for the same reason.
Cannot market the product as an alcoholic beverage - More information on this label restriction can be found in the Bureau of Cannabis Control regulations §5041.1.

FAQs

Where does the required labeling go?

Most of the required labeling must be placed on the outer layer of packaging. The outer labeling requirements are divided into two categories, based on the part of the package where it belongs.

Primary Panel – the part of the label most likely to be displayed to the consumer at retail; typically the front or top of the package.
Informational Panel – any other part of the label that is not the primary panel.

What if my package is small and I can’t fit all of the required information on the outer layer?

You can use a supplemental label to include some of the required information. Examples include, hang-tags, peel-back labels, and inserts. QR codes, websites and other methods that separate the information from the product are not acceptable types of supplemental labeling.

If the product has multiple layers of packaging, you must also include basic labeling on the inner container that holds the cannabis product:

Inhaled cannabis products (vape cartridges, shatter, wax, etc.) – must include the universal symbol.
Non-inhaled cannabis products (edibles, tinctures, topicals, etc.) – must include the product identity, universal symbol and net weight or volume.
Edible products must also include the words “Cannabis-Infused.”

Is the batch number the same as the UID number?

No. Batch numbers are numbers generated by a manufacturer that identify the items that are created as part of a single production batch; batch numbers correspond to a manufacturer’s internal batch production records. UID numbers are unique identification numbers generated by CCTT to track the movement of cannabis through the supply chain.

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