Cannabis Product, Packaging, and Labeling �Review and Approval Process

A cannabis processor licensee must obtain product, label, and packaging approval for all cannabis-infused products meant for oral ingestion. Approval is required prior to offering these items for sale to a cannabis retailer.

Review & Approval Process:

• Have a processing facility constructed, kept, and maintained in a clean sanitary condition in accordance rules from the Department of Agriculture, 15-125 WAC.
• Have an approved cannabis-infused edible endorsement from the Department of Agriculture.
• Obtain recipe approval from the Department of Agriculture prior to submitting to the Board, 16-131 WAC.
• Submit a completed application to the Label Approval Program Specialist and include:
• Product image
• Packaging and labeling image
• Retailer/Bar code label image (if applicable)
• Licensees with non-compliant submissions will be given the opportunity to make necessary changes or appeal the decision through the administrative hearings process.�

Product, Packaging, and Labeling Requirements

Cannabis Product Labeling

Products must display:

• Business name/UBI
• Product lot number
• Serving size (edibles)
• Net weight (if applicable)
• Total THC
• List of ingredients (edibles)
• Solvent disclosure statement
• Required warning statements

Products may not display illustrations or statements that are:

• False or misleading
• Promotes over consumption
• Statement or representation of curative or therapeutic effects
• Especially appealing to persons under twenty-one

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Consumer Safety

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Serving Size/Transaction Limits

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• Serving size distinguishes infused edible per serving/max serving standard with no more than 10mg THC per serving. Medically compliant products of 50mg THC may be purchased by registered patients or designated providers.
• Cannabis-infused edible products in solid or liquid form must be homogenized to ensure uniform disbursement of cannabinoids.
• Transaction limits distinguish the total amount of product that may be purchased per day.
• Transactions cannot exceed personal possession amounts.

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Quality Assurance Testing

Lab testing of cannabis flower lots, intermediate product, and end products:

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• Test is completed for potency, moisture analysis, foreign matter screening.
• If medically compliant, additional testing of pesticide screening and heavy �metal screening is required.

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No High Risk Foods

Potentially hazardous foods that require time-temperature control to keep them safe, require cooking or baking, or has to be acidified to make it shelf stable are prohibited. Examples of food items that may not be infused with cannabis include, but are not limited to:

• Fruit or vegetable juices, dairy products, dried or cured meats, any pies containing egg, etc.

Prevention Measures/Multi-pronged Approach

Product labeling

• May not be Especially appealing to persons under the age of twenty-one.

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Marijuana warning symbol requirements

• The marijuana universal symbol and the not for kids symbol must be on the principal display. The agency worked directly with the Washington Poison Center on the not for kids symbol.

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Child-resistant packaging for edible products

• Must align with federal requirements, Poison Prevention Packaging Act or in plastic that is two mil or greater in thickness, heat sealed without an easy-open tab, dimple, corner, or flap.
• Packages with more than one serving must have each serving individually wrapped. Capsules, lozenges, and similar products may be approved on a case-by-case basis to be packaged loosely.

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Advertising

• Aligns with product labeling.
• Businesses may not be situated within 1000 ft. of locations frequented by persons under twenty-one.
• Except for outdoor advertising, must contain the same warnings as product labeling, including text messaging and other digital advertising.
• Social media and internet advertising present unique legal and regulatory challenges.�