Improperly packaged and/or labeled expose cannabis and hemp clients to unnecessary liability, as well as potential damage to a business’s reputation. Internal processes must be created and implemented to minimize hiccups. Here are some things to think about when creating that process on behalf of a cannabis or hemp client:
- Specific packaging and labeling requirements typically apply to specific product types. For example, cannabis flower will have different and edibles may have different packaging and labeling requirements. Make sure you’ve properly classified a product and are looking at the correct requirements.
- Pay very close attention not only to what information is required on a label, but also where it is required on a label. Both state cannabis regulations and FDA regulations are very picky about the required content, as well as where that content should be placed on a given label (front, back, etc.).
- Monitor the packaging and labeling of any third party product that you distribute or otherwise sell, and reject products that do not meet relevant requirements. “We didn’t package or label the product, XYZ Company did” is unlikely to be a complete defense in the eyes of a regulator.
DISCLAIMER: THIS INFORMATION IS STRICTLY EDUCATIONAL AND DOES NOT CONSTITUTE LEGAL ADVICE.