Improperly packaged and/or labeled cannabis goods can expose companies to lawsuits and cause significant damage to a business’s reputation. Internal processes must be created, implemented, and reviewed to minimize hiccups.
Creating a Packaging & Labeling Process
The first step in creating an internal packaging and labeling process is identifying the specific regulations that apply to the individual product types. Specific packaging and labeling requirements typically apply to specific product types. For example, cannabis flower and edibles will typically have different packaging and labeling requirements. Make sure you’ve properly classified a product to ensure you’re looking at the correct requirements. Pay particular attention to making sure the labeling requirements are place in the correct location as well.
Finally, decide who in your company will play a role in the packaging and labeling of the cannabis goods. A standard operating procedure should be developed that specifies:
• The person responsible for creating the packaging and labeling in compliance with relevant regulations
• The person responsible for “signing off” on the first person’s work
Cannabis packaging and labeling isn’t a one-person job. Regulatory requirements are often onerous, and as stated above, vary by product type. There should be a second set of eyes on any packaging and/or labeling before it’s given a “Final” and money is spent on producing the cannabis packaging/labeling.
Implementing a Packaging & Labeling Process
Implementing a packaging and labeling process involves the same three steps mentioned in the How to Implement a Cannabis Compliance Program guidance document:
- Training
- Monitor
- Reassess & Modify
It’s just about impossible to memorize packaging and labeling requirements at all, let alone in one training session. Be sure to train employees on the requirements, and train as often as is necessary. Rather than regurgitating the regulations, consider providing real life examples of compliantly packaged/labeled products, as well as products that violate the regulations.
A Note on Third Party Products
Cannabis companies should have similar processes in play to monitor the packaging and labeling of any third party product that you distribute or otherwise sell. Cannabis goods that violate the regulations should be rejected without hesitation. Operate under the assumption that “We didn’t package or label the product, XYZ Company did” isn’t a defense in the eyes of a regulator.