This great state is home to the world’s largest freshwater lake which happens to be the only Great Lake completely within U.S. territory. Can you guess which state this is? You got it, it is the state of Michigan! While Michigan has made news and headlines about those fantastic bodies of water, the state is now entering into a new era, surrounding the cannabis industry. Medical cannabis has been legal since 2008, but adult-use or recreational cannabis is still in it’s early phases. Michigan has packaging and labeling guidelines that must be followed to sell cannabis products in the state, since medical cannabis has been legal since 2018. There are about 50 separate rules surrounding the guidelines of cannabis, but only about four that speak specifically to the guidelines of packaging and labeling.*
Rule 33 is the first rule and it is all about the requirements for marijuana-infused products or edibles. Processors are required to package and label products prior to sale or transfer. Additionally, processors must list THC levels of products in a statewide system as well on the product label. All infused products must be stored in secure locations and be labeled with the following information: name and address of processing facility, name of infused product, ingredients in descending order by weight, net weight/volume. For edible products, they must include items previously listed as well as allergens specified by federal labeling requirements, nutrition claims appropriate by federal requirements and the statement “Made in marijuana facility”. Processors cannot produce edible marijuana products in a shape, color, package, or label that appeals to minors 17 or younger. Additionally, the product cannot be associated with cartoons, toys, colors, designs, or other related items that appeals to minors. Edible marijuana products must be distinct and not easily confused with commercially sold candy, and the use of the word candy or candies on the packaging or label is prohibited. All edible cannabis must be securely placed in child-resistant packaging.
Rule 34 explains the maximum THC levels for marijuana products. This information must be present on the label of the packaged product. For topical products such as lotions and balms, there is no maximum amount per serving but a maximum percentage per container. The maximum amount per container is 6% by volume. Similarly, tincture products do not have a maximum per serving rather a maximum per container. The maximum for amount for a tincture per container is 1,000mg. The last item that does not have a maximum amount per serving is high-potency products such as capsules, or patches. However, there is a maximum of 1,000mg per container for these items. Items such as beverages and edibles do have a maximum amount of THC per serving, both at 50mg per serving and a maximum of 500mg per container.
Rule 37 is the next rule that discusses labeling requirements for tracking identification purposes. This rule requires all product that are sold or transferred between facilities to have a tracking number that matches a statewide system. This ensures the safety of the product if there are any recalls they can easily be tracked and provide information to retailers and consumers who purchased the item.
Rule 39 goes into detail the label information that is required when marijuana products are sold or transferred. Label information includes name of licensee and their license number as well as the statewide monitoring system number, unique harvest number, date of harvest, strain name, net weight in U.S. and metric units, THC or CBD, activation time, test information, universal symbol and two warning statements. The warning statements are: "For use by registered qualifying patients only. Keep out of reach of children” and "It is illegal to drive a motor vehicle while under the influence of marihuana."
*For a more detailed explanation of the rules and regulations regarding packaging and labeling, please download our packaging and labeling guide available below. If you have more questions regarding packaging and labeling, visit Michigan’s Marijuana Regulatory Agency document online at https://www.michigan.gov/mra/0,9306,7-386-83994-454513--,00.html. You can also send an email to MRA-Adult-Use-Marijuana@michigan.gov call (517) 284-8599.
*THC Label Solutions provides this document to serve as a guide and not as legal advice.