Published: Sunday, 09 July 2017 00:09
Labeling Cannabis Edibles in Nevada
It makes me feel kinda old, but I can remember a time when even the suggestion that marijuana should be legal anywhere, for any reason, would have gotten you screamed at. Most people wouldn't even consider its use for medical reasons. And this wasn't all that long ago!
Nowadays, the medical benefits of marijuana for cancer and pain treatment have been proven. I won't get into social issues here, but as of this month, marijuana is also legal for recreational use in eight states (including the entire West Coast, big surprise there), as well as for medical use in 20 other states and D.C. One result is that suddenly, producers of cannabis products are really going to need a lot of labels—and at Etiquette Systems we're standing by, ready to provide them.
The market for edible cannabis products is ripe for exploitation. There will surely be cannabis-infused brownies, cookies, granola, trail mix, cake, and for all we know, tacos popping up within the next few weeks… and guess what? They all need custom printed labels!
The Nevada legislature has been very strict about what the labels of medical marijuana edibles have to include, encoding the rules in state statutes as NAC453A.512. It's been less fastidious about labels for non-medical cannabis edibles, as the passage of the referendum legalizing recreational use seems to have surprised lawmakers, but the legislature has voted in a few emergency rules. You can take a look at the details here, but we'll run down the most important aspects of all of Nevada's cannabis edibles labeling laws for you.
First of all, the labels can't be attractive to children, so nothing too flashy or cartoony except maybe for your logo. Any such features on existing labels have to be covered up, especially for non-medical edibles. (Oh, BTW, did you know we make blackout and correction labels too?)
Several emergency requirements were added to existing Nevada marijuana laws on June 28, 2017 regarding cannabis edibles, specifically to keep dispensaries from selling:
- Any products that contain any more than 10 milligrams of THC per dose or more than 100 milligrams of THC per package.
- Any products that appear to be lollipops, ice cream, or are modeled after a brand of products marketed to children.
- Any products that look like real or fictional characters or cartoons.
- Any products that apply THC to candy or snack foods other than dried fruit, nuts or granola.
- Any cookie or brownie products that are not in a sealed, opaque bag.
- Any products that have images of cartoon characters, action figures, toys, balloons or mascots on the labeling.
Also as of June 28, the cannabis product label has to read: "THIS IS A MARIJUANA PRODUCT" in bold type, and also has to include "Keep out of reach of children" and an ingredients list.
Otherwise, you basically have to stick with the medical marijuana rules, which require you to print in at least 12-point font on the labels of all "marijuana-infused products" the following announcements and warnings:
- (a) “Caution: When eaten or swallowed, the intoxicating effects of this drug may be delayed by 2 or more hours.”
(b) “This product may have intoxicating effects and may be habit forming.”
(c) “This product may be unlawful outside of the State of Nevada.”
(d) “There may be health risks associated with consumption of this product.”
(e) “This product contains or is infused with marijuana or active compounds of marijuana.”
(f) “Should not be used by women who are pregnant or breast feeding.”
(g) “For use only by the person named on the label of the dispensed product. Keep out of the reach of children.”
(h) “Products containing marijuana can impair concentration, coordination and judgment. Do not operate a vehicle or machinery under the influence of this drug.”
All of those are required -- no kidding! And on top of all that, for medical cannabis edibles the label has to include the business name; the medical marijuana establishment registration certificate number; the lot numbers of all marijuana used to create the product, the batch number of the product; the date and quantity dispensed, including the net weight in ounces and grams or by volume, as appropriate; the name and registry identification card number of the patient and, if applicable, the name of his or her designated caregiver; the name and address of the medical marijuana dispensary; the date on which the product was manufactured; if the product is perishable, a suggested use-by date; the total milligrams of active cannabinoids and terpinoids in the product, as provided by the independent testing laboratory that tested the product; a list of all ingredients and all major food allergens as identified in 21 U.S.C. §§ 343; and if a marijuana extract was added to the product, a disclosure of the type of extraction process and any solvent, gas or other chemical used in the extraction process, or any other compound added to the extract.
Whew! It's almost like the state is actively trying to discourage manufacturers from producing cannabis edibles. No worries, this is all likely to change once the serious tax dollars start rolling in!
Meanwhile, if you need a label producer for your new cannabis smoothies or cookies, shoot us an email or give us a call here at Etiquette Systems for a quote. Obviously, we're up on all the labeling requirements for Nevada… and we'll be happy to study up on the labeling requirements of your state if you're not in Nevada.