As more United States. states allow medical and non registered adult use of cannabis, ensuring fully informed use with the minimization of risks and harms should be a priority. Standardized labeling for food and beverages is an integral part of consumer safety. The Food and Drug Administration (FDA) provides clear guidelines on food label requirements to ensure transparency and convey critical information. Nutrition labeling of food products enhances consumer knowledge, can effectively reduce consumer intakes of total energy and fat and increase intake of vegetables, and is particularly effective when consumers are provided with contextual information aiding interpretation of product characteristics. 

Currently, there are 31 U.S. states with labeling requirements for cannabis products. However, there is a lack of uniform labeling practices, as each state independently determines labeling requirements.

As with food product nutrition labels, uniform guidelines for the packaging and labeling of cannabis products may promote consumer awareness and consistency for those who use it. Consistent labeling facilitates educational campaigns on informed use, which may lower consumer risks and harms. Canada has standardized packaging and labeling guidelines for cannabis products through the Cannabis Act and the Cannabis Regulations. The Cannabis Regulations require usage guidelines such as delta-9-tetrahydrocannabinol (THC) content, cannabidiol (CBD) content, and health warning messages (e.g., delayed effects from edibles). Requirements also include aspects similar to marketing restrictions for tobacco products, such as plain packaging and labeling for all cannabis products, with restrictions on logos, colors, branding, and specific display formats about how product information must appear on the label (e.g., typestyle, size, and spacing).

Materials and Methods:

Information requirements ranged considerably by U.S. state. All states required delta 9 tetrahydrocannabinol content and manufacturer contact information, >80% of states required the batch number, health risks, production tracking, a cannabis symbol, cannabidiol content, children disclaimer, and an impairment disclaimer. There appeared to be a random pattern in requirements for other specific items. The relationships between the extent of cannabis product labeling requirements and the number of years that a state had a medical cannabis program or whether states allowed non registered adult use cannabis were not significant, although there was a trend for non registered adult use states to require more recommended label attributes.

A comprehensive framework for cannabis use is needed to protect the public, maximize benefits, and minimize harms and risks. Standardization of cannabis product labeling requirements would benefit consumers and promote safer and more effective usage of cannabis products.

Issues with inconsistent labeling

The lack of consistency in labeling cannabis products may endanger public health. Providing clear and specific guidelines could reduce adverse health effects such as excessive dosing. Although a comprehensive comparison is needed to assess the impact of cannabis labeling, the need for better educational efforts is demonstrated by the rise in cannabis-related poison center calls in states with legalized cannabis. This may be especially important for those using cannabis for medical purposes.

In a regulated cannabis market, consumers should easily be able to identify the cannabinoid composition and concentration of products and determine how much of the product to consume based on their desired dose or outcome. One of the challenges of labeling products is ensuring people who use the product can understand what is on the label. The comprehension of food labels is associated with literacy and numeracy; however, even individuals with strong literacy skills may have trouble reading food labels. Similarly, few consumers can understand and effectively utilize quantitative THC labeling on cannabis products.9 THC labels that provide “interpretive” information, such as descriptors, symbols, or references to servings, have greater efficacy. Consistency in labeling may also promote comprehension.

There are no current regulations on naming conventions of cannabis cultivar (i.e., “strain”) or standards for levels of cannabinoid content, and the same cultivar may have different cannabinoid profiles depending on the source or harvest. Recent articles call for the standardization of dosage or serving size (depending on whether the product is an inhalant or edible), as several U.S. states use 5 mg of THC as a standard “serving” for cannabis edibles, whereas other states and Canada use 10 mg of THC as a standard unit for serving size or dosage and packaging regulations. Given that definitions of THC dosage are not consistent even within the United States, it would be valuable to examine the variation in guidelines regarding cannabis product labeling related to cannabinoid content and other properties.

Are There Restrictions to Cannabis Package Designs?

In addition to all the various required and optional label elements, cannabis product packaging has to abide by some other rules. The exact rules vary by state, but the following requirements are common for cannabis packaging.

• Child resistant packaging – Containers must be difficult for children to open (exact age can vary).
• Tamper evident seals – It should be clearly visible if the package has been opened prior to sale.
• Resealing – Packaging with more than one serving should be able to reseal after use.
• Opaque packaging – Any edible cannabis products must be in an opaque package that does not allow consumers to see the contained product.

There are also special design restrictions that impact the look of your label and overall package. The FDA and other organizations do not want certain types of businesses marketing products to children. For example, the FDA and the Federal Trade Commission (FTC) sent letters to e-juice and e-cigarette companies back in 2018 warning them against using packaging that “causes products to resemble kid friendly food products, such as juice boxes, candy or cookies, some of them with cartoon like imagery.”

Those same rules apply to cannabis products, although “marketing to children” is unfortunately vague and subjective at times. To start, cannabis labels and containers should resemble any commercially available snack, drinks, or other products the word “candy” and other versions of that word are completely disallowed. Cannabis packaging also should not include any cartoons or other imagery that typically appeal to children.