Massachusetts has established stringent packaging and labeling regulations for cannabis products to ensure consumer safety, prevent accidental ingestion, and promote responsible consumption. These requirements are outlined in the Code of Massachusetts Regulations (935 CMR 500.105) and are enforced by the Cannabis Control Commission (CCC).
Child-Resistant and Tamper-Evident Packaging
All cannabis products sold in Massachusetts must be enclosed in child-resistant packaging. This means the packaging should be designed or constructed to be significantly difficult for children under five years old to open within a reasonable time, and not difficult for adults to use properly. Additionally, packaging must be tamper-evident, providing a clear indication if the package has been opened or altered.
Opaque and Nondescript Design
To prevent appeal to minors and ensure discretion, cannabis product packaging must be opaque or translucent, so the contents are not visible from the outside. The design should be plain, without bright colors, cartoons, or images that resemble commercially available products, especially those marketed to children. This includes avoiding likenesses to candies or beverages that do not contain cannabis.
Mandatory Labeling Information
Each cannabis product package must have a firmly affixed, legible label with text no smaller than 1/16 inch in size. The label must include:
- The name and registration number of the product manufacturer.
- A list of ingredients and potential allergens.
- The net weight or volume of the contents.
- The THC and CBD content, expressed in milligrams per serving and per package.
- The date of manufacture and expiration date.
- A batch number for tracking purposes. A warning that the product contains THC and should be kept away from children.
- A statement that the product is for adult use only and not for resale.
- The CCC’s universal symbol indicating the product contains cannabis.
Specific Requirements for Edible Products
Edible cannabis products have additional packaging and labeling requirements:
- Multi-serving edible products must be clearly marked with the statement “INCLUDES MULTIPLE SERVINGS” in a font no smaller than 10-point Times New Roman, Helvetica, or Arial.Each serving within a multi-serving package must be easily divisible and, if possible, scored to indicate individual servings.
- If scoring is not feasible due to the product’s form, the product must be packaged as a single serving.
- Each serving must be marked, stamped, or otherwise imprinted with the CCC’s universal symbol.
Pre-Approval of Packaging and Labeling
Before a cannabis product can be sold, licensees may submit their packaging and labeling designs to the CCC for pre-approval. This process ensures compliance with all regulatory requirements and helps prevent costly recalls or enforcement actions due to non-compliant packaging. The CCC may charge a fee for this pre-approval process.
Environmental and Waste Management Considerations
Cannabis establishments must also adhere to waste management protocols for packaging materials. Unused or waste cannabis products must be rendered unusable and unrecognizable before disposal, often by grinding and mixing with other waste materials. At least two establishment agents must witness and document the disposal process, maintaining records for a minimum of three years.
Conclusion
Massachusetts’ comprehensive cannabis packaging and labeling regulations are designed to protect consumers, especially minors, and ensure that products are used safely and responsibly. By adhering to these requirements, cannabis businesses contribute to a safe and transparent market, fostering trust and compliance within the industry.