The National Cannabis Packaging and Label Standards Committee under The Council on Responsible Cannabis Regulations and in collaboration with NCIA has just released an amazing study with industry benchmark recommendations. When I first saw the report I was jealous to not have been on the Committee. But, after I read it I can say that the analysis, options, and recommendations are spot on from my point of view! I highly commend the committee, data gatherers, statistical analyzers, and authors of this report. Really, thank you so much for doing this and sharing it with everyone. As an industry we must help one another to rise together toward the end of a prohibition. You nailed it!
5 Takeaways from the Report:
- The report is very well organized and written with a great Table of Contents that allows a reader to really use as a reference as opposed to regulations that are difficult to follow. A next step in my mind is for us all to come together, decide on the right choices for all States and Nations, and issue an ISO / ASTM standard that is clear to follow and promotes consistency in the industry and an audit roadmap. This step is imperative for federal legalization.
- The report had respondents from several states most prominently Colorado, California, Washington, Oregon, and Nevada. There were 178 respondents. Next step… Bigger sample size with more states and nations. The report lays out the framework from which a larger sample size will drive industry, ancillary business, and consumer data. The data can then be analyzed with a high statistical confidence interval from which data driven decisions can be made.
- Recommendation 14: Small Package Label Compliance. This section recommends, the establishment of a reduced set of labeling requirements for cannabis products in retail packaging that does not have sufficient space for all of the mandatory label content. The report goes onto to recommend the label contain at least, statement of identity, net quantity of contents, license number, lot or batch, cannabis facts panel with potency info, warning statements, and universal symbol. My concern is how to define a “small package”. The committee had other recommendations for allowing inserts and potentially promoting a bar code scanning system where a consumer could get straight to a website with more information.
- Potency +/- 10% — The report is about labeling and packaging. But, it is dipping into potency tolerance. The recommendation is that, each state establish an acceptable variance for labeled potency of plus or minus ten percent, which is the amount of variance generally allowed by the U.S. Pharmacopeia unless otherwise stated in a drug monograph. This is another area where we must drive to reduce variability in our industry toward process stability. We need regulators and politicians to take us seriously and must drive toward a 10% tolerance limit.
- The UNIVERSAL SYMBOL – The scope of the report did not include the debate around the requirement to directly mark edibles as required in Colorado. However, the data gathering and analysis around what people think is an effective Universal Symbol was top notch. It includes a table that summarizes a qualitative and categorized response to what the harmonized Universal Symbol should be. Each respondent gave feedback on best approach categorized by cannabis leaf, text, cross, other. WE MUST COME TOGETHER TO MAKE THE UNIVERSAL SYMBOL TRULY UNIVERSAL.
A Concern — discussing standard serving size, the report says, A majority of those in opposition to an industry-wide standard serving of THC operate only in California’s largely unregulated (at the time of survey circulation) medical cannabis market. There is no cap on single-unit product potency in California, which is appropriate because operators only serve patients with debilitating medical conditions. I question the accuracy of this statement. Is it true that operators in California only serve patients with debilitating medical conditions? If I am taking this statement in the report out of context I apologize in advance.
Watch out for 5 more Takeaways from the report in my next Blog. There is a lot more to share.
For those who want to dive in on their own, here’s the link:
https://www.crcr.org/wp-content/uploads/2016/04/Cannabis-Packaging-and-Labeling_Regulatory-Recommendations-for-States-and-Nations-1.pdf
Bill Ludlow
President, CEO
CRATIV Packaging
