Colorado Labeling and Packaging Rules Begin
July 1, 2018 Colorado Labeling and Packaging Rules Begin…
Well that time is finally here! Not everyone is excited about this new regulation change and there is a lot of confusion. June 30th is the last day you will be able to transfer product using the old labeling and packaging rules. If product is transferred to your store before July 1, 2018, you have until July 1, 2019 to sell through your inventory.
The MED came out with a check list in February MED Bulletin 18-03 that is accessible to everyone. By no means is ICS Consulting giving legal advice and we are not lawyers. However we work one on one with employees, owners, and lawyers working out solutions for labeling and packaging compliance needs.
We are hearing conflicting information out there on the 1 gram containers that house concentrate products. In the definition of a “container” from R/M 103 Definitions “Container” means “the receptacle directly containing Retail Marijuana, Retail Marijuana Concentrate, or Retail Marijuana Product that is labeled according to the requirements in Rules R/M 1001 et seq. or Rules R/M 1001-1 et seq.”
This means beginning July 1, 2018 if your 1 gram container that houses concentrate product inside of it, must adhere to labeling requirements and be labeled according Rules R/M 1001 and R/M 1001-1.
Which is very frustrating for some people trying to figure out, how do I get all the verbiage and other required information on a label when my jar is the size of a quarter. Some people are moving to getting bigger jars that can fit a label, some people are ditching the inside jars and wrapping product in parchment paper and placing it inside the child resistant container, and we are also seeing creative stickers that fold out, like you would see on pill bottles.
The rules state “The labeling requirements in this rule apply to all Containers immediately containing Retail Marijuana, Retail Marijuana Concentrate and Retail Marijuana Product.” Rule R/M 1001-1 – Packaging and Labeling.
Which makes the gram jar part of “All Containers”. We understand why this rule went into effect, on the premise of, once the unlabeled jar left the CR container then it was not properly labeled and identified.
We are urging all facilities create some type of intake checklist (if you are a store) and an outgoing check list (MIPs or Cultivation). If you are looking for a better checklist, one of my colleagues has made a very comprehensive checklist. If you are interested please email me at Jenny@ICSConsultingService.com
For the most part, I believe licensed facilities have their packaging and labeling on lock down, but for those of you who do not, and need some referrals for labeling etc. please do not hesitate to reach out and send me an email.