Similar to Oregon’s packaging requirements, the labels too must go through a pre-approval process through the OLCC. In the state of Oregon, labels are more than just what goes on the package. The label includes text, graphics, pictures, and logos. Each additional panel is considered part of the label and must go through the same pre-approval process. The commission evaluates all labels and decided if it is compliant with the following rules.

GENERAL RULES FOR LABELS

Each information panel has a different set of rules and regulations, some may be more general, while others are more specific. Regardless of label type or positioning, all labels must be typed in a legible font that’s easy to read and provides enough contrast with background colors. The size of the text must be at least one-sixteenth (1/16) of an inch high based on the uppercase “K”. All writing must be in English but can include additional languages as well. The label must be unobstructed and obvious to the consumer. There may not be an untruthful or misleading statement listed on the panels.

OREGON UNIVERSAL SYMBOL

The principal display panel must contain specific requirements such as net weight, a universal symbol, and product identity. For net weight, the amount must be listed in both metric units such as milligrams or milliliters as well as U.S. customary units such as ounces or fluid ounces. Depending on the product, either the universal or hemp symbol will be used. The symbol must be in could and at least 0.48 inches wide by 0.35 inches high. The principal display panel must also include the product identity, which is the common name for the product that informs the consumer what they are purchasing. Marijuana product types such as cannabinoid edibles, topicals, or concentrates have specific labeling requirements that must be included on their labels.

Those requirements can be found on Oregon state’s website at https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=3873

Failure to include all required label information may result in a label application denial.

There are special circumstances in which labels do NOT need to go through the pre-approval process. If the label is generic and ONLY contains the required information then it is okay to use. This rule implies that there cannot be graphics, photos, logos, or any additional information that is not required by law anyone on the packaging. The other circumstances are if the label has been previously been approved and the changes that are made are included in the following list.

The information listed is the only change that can be made to a label for it not to need to be approved again. Changes such as:

• harvest or processing date
• strain
• test results including lab information and THC or CBD concentration
• net weight or volume
• the harvest process
• UID numbers

The next alterations have to do with the deletion or addition of information such as deleting non-mandatory information:

• change in UPC barcodes or 2D mobile barcodes (QR codes)
• instructions for opening or using the child-resistant packaging
• alterations to the website
• phone number fax number
• zip code of licensee
• registration

Lastly, the repositioning of label information on package as long as the label information is consistent with labeling rules does not need a second approval.

For more information about packaging and labeling, please read the Packaging and Labeling Guide. If you have a question, please call 503-872-5459 or send an email to marijuana.packaging@oregon.gov.

*THC Label Solutions provides this document to serve as a guide and not as legal advice. For more information visit Oregon state’s recreational marijuana program at https://www.oregon.gov/olcc/marijuana/Pages/PackagingLabelingPreApproval.aspx