The rules for multi-layered packaging (plus the most common vape labeling mistake)
California cannabis regulations state that if the cannabis is packaged in more than a single layer (e.g. bag, box, jar), there is specific information that must be on each layer.
Specifying what must be on each layer of packaging is somewhat common. It’s included in the fair packaging and labeling act and other states include it too, albeit with different names for the different layers. Let’s look at an example.
- California cannabis regulations call this the “outside container”
- Called “secondary packaging” in other industries
- California cannabis regulations call this the “product container”
- Called “primary packaging” in other industries
In California, the outside container always requires all of the packaging information including both the primary panel (product identity, universal symbol and net weight) and the informational panel (cannabinoid content, government warning, prop 65 warning and so on).
What labeling needs to be on the product container (glass jar in our example) varies depending on the product type. Some products need the complete primary label. These products include:
- Oral concentrates
Other products need only the universal symbol, including:
- Inhaled products (non-flower)
What about vape containers?
This is where the most common vape packaging problem comes in. A fairly common vape packaging I’ve seen is a vape cartridge inside a box. Most people think the box is the only layer of packaging. But actually the vape cartridge itself is considered a product container. This new rule came into play in 6/2019, and is effective 1/1/2020. All vape cartridges are considered product containers and must have the universal symbol on the cartridge itself. The universal symbol can be a sticker or printed on the cartridge.
Don’t make this mistake. Include the universal symbol on your product containers, including vape cartridges.
This article is for educational purposes only and is not legal advice. For legal counsel, please contact your attorney.
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