The California “cannabis roller coaster” that led to a lot of people throwing out packaging is hopefully slowing down as we approach “permanent regulations”, but costly mistakes are still being made.
To help us navigate through the confusion, Inkbrite is kicking off an educational series on the most common packaging and labeling challenges we see in the market. Today we’re going to talk about a fun one. Child-resistant (CR) packaging in California.
It’s no surprise that people are confused by the regulations. The newest regulations just kicked in Jan 1 2020, and they are complicated. Previously, placing products in a CR exit package when sold was allowed. Now, that’s not okay.
Answering the question “does my product need to have CR packaging or not?” is easy. Yes. Always yes.
In California the regulations state that a package containing cannabis or cannabis products must be in CR packaging before it’s transferred to a distributor for retail sale.
Answering the question “what type of CR packaging do I need to have?” is where the complications arise. California has two standards for CR packaging:
- CR for the life of the product (lifetime CR)
- CR until first opened (one-time CR)
The type of CR packaging you need depends on the product type.
Edibles, orally consumed concentrates, and suppositories must be child resistant for the life of the product. Thankfully, California is a bit easier than other states on the suppository rule. (We’re looking at you Colorado. How do I state this delicately? Why do “women’s use” suppositories need to be in CR packaging but “all gender” suppositories only need to in CR exit packaging). But I digress…
Inhaled products (flower, pre-rolls, vape cartridges) and products that are applied topically are OK with single use CR packaging. However, if single use packaging is used, that package must be labeled with the statement “This package is not child-resistant after opening.”
That’s it. Simple? 🙂
What areas of packaging are the most confusing to you? Let us know and we’ll do our best to add them to our educational series.
This article is for educational purposes only and is not legal advice. For legal counsel, please contact your attorney.
If you have comments or questions, please comment below. We love reader feedback.
If you need beautifully designed, compliant packaging for your cannabis products, please contact firstname.lastname@example.org. Is your existing packaging compliant? Inkbrite can tell you with a compliance review.
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