Regulations Regarding Packaging & Labeling

Summary of Emergency MAUCRSA Regulations Regarding Packaging & Labeling

 

The Bureau of Cannabis Control (Bureau) is responsible for developing regulations for licensing of various types of commercial cannabis businesses under the Medical and Adult-Use Cannabis Regulatory and Safety Act (MAUCRSA)

The Bureau intends to adopt emergency regulations that have not yet been published; however, a summary of the proposed regulations in the Initial Study/Negative Declaration released by the Bureau on September 6, 2017.

Distributors

The proposed regulations will provide that distributors may package and label—or repackage and relabel—cannabis in the form of dried flower on behalf of a cultivator or another distributor and  distributors may not package, repackage, label, or relabel manufactured cannabis goods.

Manufacturers

Under MAUCRSA, the California Department of Public Health (CDPH) is tasked with the licensing of manufacturers.

 

MAUCRSA creates two license types for manufacturers: Type‐6 manufacturers extract using nonvolatile solvents, and Type‐7 manufacturers extract using volatile solvents.

 

Under MAUCRSA, CDPH is expected to create two additional license categories: Type‐N for manufacturers that produce edible products, topical products, or other types of cannabis products (infusion) and that do not extract oils; and another license type for manufacturers that do not manufacture the actual product, but only package and label those products (akin to the previously proposed “Type P” license under MCRSA).

 

Manufacturers that hold other types of manufacturing licenses would not be required to hold a separate license if they are labeling and/or packaging their own manufactured products. Manufacturers that do not conduct extractions, but rather produce edible or topical products using infusion processes or cannabis products other than extracts or concentrates, will be Type‐N licensees. Type‐6 licensees may conduct extractions using mechanical methods or nonvolatile solvents, and may conduct infusion operations. A Type‐7 manufacturing licensee may conduct all of the same activities as a Type‐6 manufacturer, but may also conduct extractions using volatile solvents.

 

Permitted Activities for each Manufacturing License Type in CDPH Proposed Regulations:

License

 

Activities Allowed  Under Microbusiness License?
Type 6 • Extractions using mechanical methods (such as presses or screens)
• Extractions using nonvolatile solvents
• Infusion operations (must be designated on application)
• Packaging and labeling of own products
Yes
Type 7 •Extractions using volatile solvents
•Extractions using mechanical methods (such as presses of screens) (must be designated on application)
• Extractions using nonvolatile solvents (must be designated on application)
• Infusion operations (must be designated on application)
• Packaging and labeling of own products
No
Packaging and Labeling Only* • Packaging and repackaging of cannabis products

• Labeling and re‐labeling of cannabis products

Yes
Type N • Production of edible or topical cannabis products using infusion

• Production of cannabis products other than extracts or concentrates (no extractions permitted)

• Packaging and labeling of own products

Yes

*The name of this license type has not yet been determined by CDPH.
MJIC Compliance offers a full range of services and products supporting all aspects of legally compliant cannabis operations in California.  For more information please reach out to Alexandria Shaw at ashaw@mjic.com or Dottie Lulick  at dlulick@mjic.com.

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