Beginning October 1, 2016, all of Colorado’s Medical and Retail Marijuana Industries products containing THC must display the Red Retail Universal Symbol.
Current Symbol Red Symbol (10/1/16)
On the surface, this change may seem minor, i.e., buy or print a bunch of Red Retail Universal Symbol labels and stick them on your products.
However, this is a major opportunity for growers, dispensaries, and edibles manufacturers to invest in color label printers to reduce the risk of obsolete label inventory and increase the impact of their brands.
The medical and recreational marijuana industry has been growing rapidly and is becoming more regulated and “retail” by the day. It once was acceptable to have less-than-professional product labeling. Patients and consumers are becoming more discerning and brand recognition is becoming more important.
- Growers: It is no longer enough to supply in bulk to your dispensaries. How will the patient or consumer know that it’s your production of a particular strain that they prefer unless you label your product for retail sale?
- Dispensaries: Think of how important labeling is in the wine industry. If you are repackaging bulk product for resale, you can increase the shelf-appeal and preference for your brands by printing high-quality labels in-house.
- Edibles Manufacturers: If you are filling prescriptions for an MMJ dispensary, you can use the variable data capability of your in-house printer software to combine patient, product, Identity Statements, Standardized Graphic Symbols, etc. onto a single label. (See our cannabis case study here to learn more.)
And as the amount of product information required by regulators increases, growers, dispensary owners, and edibles manufacturers run the risk of having obsolete pre-printed label inventory when labeling requirements change.
Also, consider the amount of information that must be included on product labeling.
Colorado requires, via CODE OF COLORADO REGULATIONS 1 CCR 212-2 Marijuana Enforcement Division, R 1000 Series – Labeling, Packaging, and Product Safety Basis and Purpose, that “Every Retail Marijuana Products Manufacturing Facility must ensure the following information is affixed to every Container holding a Retail Marijuana Product:”
- a. The license number of the Retail Marijuana Cultivation Facility(-ies) where the Retail Marijuana used to produce the Retail Marijuana Product was grown;
- b. The Production Batch Number(s) of Retail Marijuana Concentrate(s) used in the production of the Retail Marijuana Product.
- c. The license number of the Retail Marijuana Products Manufacturing Facility that produced the Retail Marijuana Product.
- d. A net weight statement.
- e. The Production Batch Number(s) assigned to the Retail Marijuana Product.
- f. A statement about whether the Container is Child-Resistant.
- g. A clear set of usage instructions for non-Edible Retail Marijuana Product. CODE OF COLORADO REGULATIONS 1 CCR 212-2 Marijuana Enforcement Division 149
- h. The Identity Statement and Standardized Graphic Symbol of the Retail Marijuana Products Manufacturing Facility that manufactured the Retail Marijuana Product. A Licensee may elect to have its Identity Statement also serve as its Standardized Graphic Symbol for purposes of complying with this rule. The Licensee shall maintain a record of its Identity Statement and Standardized Graphic Symbol and make such information available to the State Licensing Authority upon request;
- i. The Universal Symbol, which must be located on the front of the packaging and no smaller than ½ of an inch by ½ of an inch, and the following statement which must be labeled directly below the Universal Symbol: “Contains Marijuana. Keep out of the reach of children.”;
- j. The following warning statements:
- i. “There may be health risks associated with the consumption of this product.”
- ii. “This product contains marijuana and its potency was tested with an allowable plus or minus 15% variance pursuant to 12-43.4-202(3)(a)(IV)(E), C.R.S.”
- iii. “This product was produced without regulatory oversight for health, safety, or efficacy.”
- iv. “The intoxicating effects of this product may be delayed by two or more hours.”
- v. “There may be additional health risks associated with the consumption of this product for women who are pregnant, breastfeeding, or planning on becoming pregnant.”
- vi. “Do not drive a motor vehicle or operate heavy machinery while using marijuana.”
- k. A complete list of all nonorganic pesticides, fungicides, and herbicides used during the cultivation of the Retail Marijuana used to produce the Retail Marijuana Product.
- l. A complete list of solvents and chemicals used in the creation of any Retail Marijuana concentrate that was used to produce the Retail Marijuana Product.
One change to any single word in the above will obsolete your pre-printed label inventory.
Plus, adding color to your labels will not only allow you to comply with Colorado’s new Retail Universal Symbol requirement, it gives you an opportunity to increase your brand recognition, streamline your workflow, and eliminate obsolete label inventory.
