Committee Insights | From Lab to Label: Safeguarding Consumers in the Cannabinoid Product Landscape

NCIA’s #IndustryEssentials webinar series is our premier digital educational platform featuring a variety of interactive programs allowing us to provide you timely, engaging and essential education when you need it most.

In this edition of our NCIA Committee Insights series, originally aired on June 13, we were joined by members of NCIA’s Cannabis Manufacturing, Scientific Advisory and Hemp Committees for an in-depth discussion of the current cannabinoid testing & labeling landscape alongside complications compounding consumer safety and product manufacturing concerns.

Consumer products that contain cannabinoids are a popular new consumer product category sweeping the United States. Whether these consumer products are manufactured using cannabinoids derived from cannabis or hemp, consumers deserve to know what they are consuming.

Truth in labeling is critical to providing cannabinoid content information to a consumer so they can make an informed purchase decision and in ensuring consumer safety. However, with so many different label content requirements from state to state for consumer products containing cannabinoids, this lack of consistency can lead to potential risks to the end consumer.

This is especially true when the majority of cannabinoid product manufacturers are dependent on third-party data during product manufacturing and compliance testing. This interdependence between testing laboratories and product manufacturers makes it all the more important that label content requirements are both achievable from a manufacturing standpoint without being overly burdensome for regulators to verify and do not endanger public health and safety.

In this webinar, our panelists explored about the current state of America’s somewhat-monitored cannabinoid-product marketplace, and examined several of the issues related to cannabinoid quantification, cannabinoid content declarations, and label claim verification and how these relate to consumer safety.

Learning Objectives:

• Learn about the potential risks associated with untested, unlabeled products both for the business owner and as a consumer

• Review the current landscape of cannabinoid testing requirements, how they vary state to state and the role 3rd party labs play in the picture

• Understand the nuances with label content compliance and implications on label claims

• Explore data integrity issues preventing consumers from making informed decisions

• Share best practices for what the the industry should do, what consumers can do and what regulators need to do

Panelists:

Paul Coble
Technology Attorney
Harris Bricken Sliwoski LLP

Matthew Johnson
Vice President, Risk Services
QuadScore Insurance Services

Rhiannon Woo
Co-Founder & CSO
TraceTrust

Keith Butler
CEO
OP Innovates / Naturia+™

Darwin Millard
Owner/Founder /// Subcommittee Vice-chair
TSOC LLC /// ASTM International D37.04 on Cannabis Processing and Handling

This is the third of five in a multi-part series of #IndustryEssentials webinars. You can watch Parts I-V at the links below.

Defining the Conversation: Minor, Novel & Synthetic Cannabinoids (Part I): https://bit.ly/3D2LReB

Meet the Minors (Part II): https://bit.ly/3qUD8Ip

From Lab to Label: Safeguarding Consumers in the Cannabinoid Product Landscape (Part III)https://bit.ly/3Xc9Lx6

Know Your Hazards – Occupational Health and Safety Considerations in Cannabinoid Ingredient Manufacturing (Part IV)https://bit.ly/3rEUeKP

Concepts for Regulatory Consideration – Shifting the Conversation from “Cannabis vs. Hemp” to “The Cannabinoids” (Part V): https://bit.ly/3P3r5AW

Committee Blog: Brand Driven Package Design Cheatsheet

by Wendy Barr, CEO & Creative Director, Barrcode Branding
Member of NCIA’s Packaging and Labeling Committee

You want “that” package, the one that is flying off the shelves; the one that people photograph and post on social media; the one that makes the consumer feel something inside, something special, maybe even emotional. Maybe it’s a package they keep, reuse, save, share, and purchase over and over again.  

If you’re in retail, you want a package that earns you shelf space. A package that retailers want at eye-level in their stores and dispensaries, featured on their website, in their app, directly in front of the consumer… tantalizing, educating, and urging them to purchase. Admit it, you have an amazing product, and you want irresistible packaging design!

What does all gorgeous packaging have in common? 

YES!! Branding!

Cool, you have been listening…

Yes, it’s true, we’re extremely passionate about packaging design (and branding). That’s why we’ve committed our professional life to the packaging design industry. We want to understand why a consumer is compelled to purchase one package over another. What makes this package so hypnotic and desirable? We want the graphics, colors, messaging and overall design to appeal to something deep inside of the discerning adult consumer. It’s our goal to create a personal connection that expands beyond the product itself. The packaging is more than a mere vehicle. It should hold the sale, inform, and delight the consumer.

Did you know that packaging design is one of the last sustaining manufactured print products?

Think about it. Magazines, books and literature, posters, flyers, brochures, album covers (yes, I remember vinyl), even business cards are on their way out. But, product packaging is here to stay. It can’t be purely ‘digital’; the product has to go into something for transport, storage, information, and more. 

Your packaging is a billboard that represents your entire brand.

Your branding will dictate the look and feel of your packaging, and the language used to communicate the product’s value to the consumer. When you get this part right, you can experience huge rewards. But if you get this wrong, you may never get a second chance. Ouch, that stings…

Many businesses get this wrong, especially those in newer industries like the legal cannabis, CBD, and hemp industry, for example. Some companies opt for a white label product and simple packaging design created by the white label company. Or they print their own labels using their DIY logo and wonder why it’s not selling. It’s a great product, tried and true, but the packaging doesn’t communicate the brand value to the consumer effectively resulting in #epicfail. 

Why focus so much energy on Brand Driven Package Design?

If the goal is to be visible, popular, and profitable, your product packaging can’t be an afterthought. Your branded product packaging is part of the big picture. It’s functional marketing and should be treated as such. Keep it simple, clean, and on-brand, and you can’t go wrong. You got this!

Here is your mini cheatsheet:

Branding (need I say more?)

Your spot-on brand identity comes first, it has to, because your packaging design is a reflection of your brand. The logo, colors, fonts, imagery, and language must be indicative of your unique differentiation as a brand. 

Sustainability (it’s time to save the planet!)

Make sure that your packaging materials reflect your brand values and mesh with the product. Sustainability issues and concerns are critical due to the potential negative impact on the environment. Consider recycled and/or recyclable materials, and work with regulators and lawmakers to improve access and feasibility. 

Primary vs. Secondary Packaging (what does it all mean?)

Primary packaging is what directly holds and contains the product (like a bottle). Secondary packaging is the exterior packaging (like the box that holds the bottle) that protects and/or labels the product. Tertiary packaging is used for bulk handling, storage, and distribution.

Specialty Design Agency (can you say branding?)

Choose an agency that is or has worked closely with you on the development of your brand. A professional agency will have designers with expansive knowledge regarding packaging design, print production, branding, and marketing. Your packaging design, website, and marketing efforts must be intrinsically and cohesively linked to your brand identity.

Wait, maybe white label or private label would work for you. But, in that case, is branding still a valid concern? 

I’m so glad you asked! White labeling is hot and trending in the cannabis industry. But, is it right for you? Let’s take a look…

What are White Label Products?

White label products are mass produced by a manufacturer as a generic product, and sold to a retailer who will in turn add their own label and sell it under their brand name. The formula is standard and typically, cannot be customized. So, the only thing that you can customize is the branding, packaging design and brand marketing. 

What are Private Label Products?

Private label products are produced by a manufacturer as well, but in partnership with the brand to create a unique formulation. It is a longer, more expensive undertaking, but it results in an exclusive product. Retail brands use this to differentiate their products and cater to their niche audience. 

White Label vs. Private Label

How do business owners decide which is the best investment for them? Well, it’s important to weigh the price differential. White labeling is more affordable, but the product is not original. Private label requires a more substantial investment, but it allows for collaboration, flexibility, and exclusivity with regards to formulation, and in some cases, trademarking and market share. But, unless you have a loyal, expansive customer base and exceptional branding/marketing, it could be difficult to compete against established, well-known brands. 

What is exactly the same?

BRANDING! In the end, no matter the direction you choose, a white-label product or a private label, the only way to optimize your visibility and assure that your product stands out is branding. Having professional, eye-catching branding, a spot-on brand story and a unique branded marketing strategy can earn you distribution, shelf space, and loyal customers now and in the future. 

Short story long, if you are in this to win this, do it right the first time! Make it custom, make it YOURS!

 

 

 

 

Committee Insights | 7.14.21 | How to develop a Risk Assessment for your Canna-Business

In this edition of our NCIA Committee Insights series originally aired on Wednesday, July 14, 2021 we were joined by members of our Risk Management and Insurance Committee for a discussion on how to evaluate and rank risks to your cannabusiness.

Our experts discussed the potential impact of risk to cannabusiness operations and how to effectively identify and rank them. The discussion included risks posed by product sales, partnership agreements and corporate culture. The expert panelists also shared insights gained from their respective areas of specialty which include; Legal, Financial, Manufacturing, Technology and Insurance. Their insights will arm YOU with the tools needed to fortify yout operational practices and minimize or avoid costly losses.

Presentation Slide Deck: https://bit.ly/3hJJwLD

Panelists:
Helkin Berg
CEO
Strimo

Merril Gilbert
Co-Founder & CEO,
TraceTrust

Kevin Haller
Principal
Akene Consulting, LLC

Mathew Grimes
Vice President – Cannabis Specialty Group
HUB International Limited

Summer Jenkins
Business Development Manager
Cannasure Insurance Services

Committee Blog: Best Practices Guide – Allergen Labeling

By Brandon Dorsky, The Law Offices of Brandon Dorsky
Member of NCIA’s Packaging and Labeling Committee

Determining which edible to consume is an art all by itself. Making that choice when you suffer from food allergies often makes the decision all the more challenging.

Despite the continued federal illegality of cannabis, cannabis products are still obligated to abide by federal labeling requirements regarding the disclosure and identification of the presence of common allergens, including tree nuts (such as coconut and almonds), peanuts, fish, shellfish, dairy, soy, eggs, and gluten. Labels often do identify the presence of those ingredients and sometimes even the traces thereof. Although companies are seemingly committed to following federal requirements, there is still a continued absence of additional, more specific information that could help individuals with allergies make better-informed decisions when selecting their edibles.

A commitment to providing more information in labeling of common allergens not only helps consumers but also has the propensity to battle the stigma of cannabis as an underground and unregulated industry by embracing more advanced self-regulation and increased transparency. Additional information promotes transparency in the production and packaging processes, and provides valuable information to the discerning customer in addition to promoting better business practices. With roughly one in 20 adults allergic to peanuts or tree nuts, at least 5% of purchasers are directly impacted by the information related to the presence and management of nuts in a manufacturing facility.   

In the marketplace today, common label designations include “may contain traces of,” “produced in a facility that also processes” or “produced on equipment that also processes.” Rarely is more information provided. Even though broad strokes disclosures satisfy federal requirements and limit legal liability, they do not do much to inform consumers suffering from allergies who could eat something produced with care, but cannot safely or comfortably consume food products that may contain traces of. With anxiety and paranoia, a potential consequence of cannabis overconsumption, the availability of more information about the presence of allergens on a label could possibly cure or temper an unwarranted freakout. More detailed information could even help avoid emergency room visits and the related trauma and anxiety from experiencing allergic reactions or the vestiges of one. No one enjoys the associated trauma and paranoia of hives in their mouth or wheezing while under the influence of an edible because they ate something that may contain traces of and actually did contain traces of the allergen.

The “may contain traces of” designation is good for the edible manufacturer at discharging potential liability, but it does not do much for consumers that are actually allergic to the items beyond sending the signal that if they consume the product, there is a possibly a legally identifiable amount present within the edible that could potentially trigger a severe allergic reaction. The language provides little information as to why there may be traces of the allergen. For the affected consumer, the business practices used to segregate common allergens or otherwise avoid cross-contamination or contact is what is critical for determining the likelihood and magnitude of the risk of any potential contamination, and therefore the risk presented by the consumption of an edible. This language, while good for insulation from liability, is not informative as to how the traces may have occurred and has the potential to be misleading and deter purchasers that would not be deterred if the label were more accurate at disclosing where in the production chain a potential trace of contamination could have occurred.   

Manufacturers currently provide notice if there are “traces of,” or if equipment or a facility contains a common allergen, but they could go further. Four potentially more informative versions of “may contain traces of” or “made on the same equipment as other items that include…” or “made in the same facility as items that include” are:

Produced in a facility, but on separate equipment,

Produced on equipment, that processes INSERT ALLERGEN(S), but using best/reasonable business practices to segregate allergens in the production and storage process.

Produced on equipment, that processes INSERT ALLERGEN(S) where the facility produces products containing allergens on different days than products not containing INSERT ALLERGEN(S).

Produced in a facility that processes INSERT ALLERGEN(S) where the facility produces products containing allergens on different days than products not containing INSERT ALLERGEN(S).  All production machinery is cleaned between the productions of different types of edible products.

Cannabis edibles product manufacturers could lead the charge on providing more informative allergen disclosures by promoting the use of more descriptive labeling practices. While such a move may cost fractions of a penny in ink and packaging real estate, the goodwill it could buy is invaluable. The loyalty of the allergy afflicted consumer (and the purchasers who care for or care about them) should not be understated. If a little extra print turns one in 20 customers into a lifetime brand patron, it is probably worth the rub.


Brandon Dorsky helps clients navigate the constantly evolving global marketplace in a variety of industries, providing strategic, seasoned counsel to facilitate growth, mitigate risk and seize opportunity in the cannabis, fashion, music,  entertainment and media industries. Through a wealth of experience, contacts, enthusiasm, and commitment, clients receive carefully tailored legal and consulting services to accelerate their business’s success.

Member Blog: ‘New Normal’ Dictates Label And Packaging Printer Review

by Gary Paulin, VP of Sales and Client Services at Lightning Labels

In a world of uncertainty, reliability and timeliness rule

COVID-19 is altering the landscape in ways unimagined a few weeks ago. With new realities, fears and uncertainties running rampant, it’s time for cannabis and CBD manufacturers and purveyors to recheck their label and packaging protocols right along with products. When it comes to printing and fulfillment, it’s wise to stay as “close to home” as possible.

“Close to home” encompasses two major areas in label/packaging custom printing: They are country of origin and centralized process control. 

Country of origin is fairly straightforward. If at all possible, it’s a good time to be “made in the USA.” The uncertainties and disruptions in a number of foreign countries, complicated by the pandemic, make custom label printing abroad a dicey proposition at best.

Centralized process control has to do with how printing, fulfillment, and shipping are managed. The more that is done under one roof, the better. While shipping requires using an outside third party in most cases, everything else can be completed in-house.

Brokering printing and/or fulfillment to outside entities can present a version of the same problem that occurs with foreign countries. Anything done out-of-house is more subject than ever to delays and disruption. Even after COVID-19 subsides, this is a lesson to be learned well going forward.

Summed up, develop, manage and reinforce a reliable supply chain where getting high-quality cannabis labels and packaging printing quickly and economically is Job #1.

Cannabis and CBD companies wanting to confirm that they’re getting the best quality, price and turnaround time consistently and reliably can review options below. Everyone deserves a predictable, quality-driven and customer service-obsessed printer all the time. Right now, it’s even more important with the added pressures stemming from COVID-19 and resulting stressors. 

Review factors within and beyond a printer’s control.

Make sure that what’s claimed in the way of processes and workflow is actually practiced. To confirm validity, this is a great time to conduct a virtual tour of the facility to see it in full operation. Video call platforms that make this easy and efficient have proliferated. Don’t hesitate to ask your printer for a tour. As an essential business, printers can remain open to handle all needed functions. So, the virtual tour of operations should show some level of normalcy. Account/sales/customer service teams, however, are likely working from home — so ask to have them chime in on a video conference. That way, you can see the plant in action and assess how well the remote employees are performing in their new “offices away from the office.”

Besides confirming claims, doing a virtual tour will provide insights about workforce stability and morale. Optimally, it’s pretty much business as usual. However, if there are signs of low morale or lagging productivity, check it out further.

Also check to see that operations numbers match up to expectations. Are printing and fulfillment stations manned as expected? How is staffing matching current demand, which for some label and packaging printers may actually be surging?

If something seems askew, such as a printer claiming healthy volume when the plant is almost deserted, keep asking questions. These may be early drops of rain on the windshield, portending a coming storm.

Conduct a problem-solving and contingency-planning meeting with your printer.

In addition to assessing what’s going well, address what could go wrong and how the printer will handle it. As COVID-19 impact has shown, there well may be challenges ahead that—under normal circumstances—wouldn’t be considered high priority. Now, on top of potential twists and turns in the regulatory and various jurisdictional environments, there’s the added challenge of a pandemic.

In cannabis and CBD, the focus for the foreseeable future may well be on increasing versus faltering product demand. How a printer can be nimble and scale to coming challenges on all fronts will likely dominate a variety of discussions for awhile.

Other contingencies may involve direct impact of COVID-19 itself. How well can a printer backstop employees who get sick? How will this be done? Will it be primarily substituting present employees, already well familiar with the company and operations, who have capabilities crossing a number of areas? Or, will new people need to be brought in? If so, where will they come from? What other ways can printers maintain productivity amid these challenges?

Look for present performance in readily documentable areas.

Is turnaround consistent with previous orders? How is the quality? What about customer service availability and timeliness? Are you dealing with the same people as before? Are people acting consistently with pre-pandemic expectations? (If not, you may want to give a bit of grace, as everyone is dealing with unusual stresses.) If everything is essentially business as usual, and you’re getting everything you want and are accustomed to, that’s a win. If there are problems, find out why and problem-solve with the printer. Even if it involves a problem beyond direct printer control, such as a shipping snafu, it deserves troubleshooting for workarounds.

 

Obviously, this is not an exhaustive list — but it will help ensure that product manufacturers and purveyors continue to get the quality, turnaround, and price they deserve. If there’s an issue that may be COVID-19 related, and the label/packaging printer has been a longtime stellar performer, consider figuring out a solution before going elsewhere. If, however, there’s a systemic, attitude or customer-service problem that looks to be long-term, look for another printer that checks the right boxes.


Gary Paulin is VP of Sales and Client Services at Lightning Labels, a Denver-based custom label printer that uses state-of-the-art printing technology to provide affordable, full-color custom labels and custom stickers of all shapes and sizes. Contact: sales@lightninglabels.com; 800.544.6323 or 303.481.2304.

NCIA Committees: Spring 2020 Update On Achievements And Projects

NCIA’s member-driven committees are an opportunity for individuals from NCIA member companies to get directly involved in specific industry issues and sectors. These volunteer-driven efforts engage members’ expertise and passion to drill down in those areas to effect change, provide professional development opportunities, and develop best practices and guidelines that will shape the future of our industry.

We recently checked in with these various committees to learn more about what they’re up to and what projects they’re working on this term. Get updated on their activities below.


Risk Management & Insurance Committee (RMIC)

The RMIC has recently contributed to several NCIA white papers and educational webinars. They are currently working on an insurance manual. The committee has divided into sub-committees responsible for managing white papers, webinars, and the manual. 

Scientific Advisory Committee (SAC)

SAC’s vision is to disseminate educational materials to NCIA members on scientific topics in the cannabis industry and to advise on other NCIA initiatives, ensuring that any formal recommendations produced are scientifically sound, sustainable, and legitimate. This term, SAC published a blog discussing why everyone should know about the endocannabinoid system.

SAC is working on other pieces addressing topics such as the recent vape illnesses from a physician’s perspective, indica versus sativa designation, how cannabis can help the opioid crisis, common scientific myths confusing the industry, and budtender and consumer education about the endocannabinoid system.

SAC is also developing a webinar that discusses what should be on a label, how to read a label, and how to associate what’s on a label with either statements on efficacy or marketing/branding.

Cannabis Cultivation Committee (CCC)

The committee has recorded two podcast episodes for NCIA’s Cannabis Industry Voice Podcast. The first was a Cultivation Best Practices Roundtable, hosted by Noni Goldman of the CCC. In that episode, Cody Hitchcock of Smokey’s 420 and James Cunningham of Fog City Farms were interviewed to shed light on their different growing styles and techniques, focusing on the ways that they implement sustainability in their operations.

The second soon-to-be-released interview was with High Times’ new CEO Stormy Simon, and was hosted by CCC Chair Mo Phenix and member Noni Goldman. This interview explored Stormy’s history and how she got to where she is today, as well as what High Times is up to, and where Stormy sees the industry going.

More podcasts to come in the next couple of months from the CCC! Keep an eye out for an episode or two on regenerative agriculture.

Packaging & Labeling Committee (PLC)

The PLC sub-committees have each contributed to a blog or presentation up to this date. The Sustainability sub-committee has worked with Kaitlin Urso and team in regards to their White Paper. A panel discussion proposal has been submitted for future NCIA conferences. 

NCIA’s Northeast Cannabis Business Conference in Boston (February 2020) Panel Discussion on the Future of Cannabis Packaging went great!

State Regulations Committee (SRC)

NCIA’s State Regulations Committee has continued to produce content to help educate and inform members on the latest developments in the world of state regulation of cannabis. As the industry’s law and regulations change quickly across the country, the SRC members stay ahead of the curve and share their insight in a variety of forms. These projects include panel presentations at NCIA conventions, published blogs, and interactive webinars. In this quarter, they published three blogs, produced one webinar, presented on two panels, and participated in an NCIA summit.

Blogs Published:

The Social Consumption Sub-Committee published “California Social Consumption Leads the Way” by Debby Goldsberry.

The Interstate Commerce Sub-Committee published two blogs: 

The first blog “Ending the Ban on Interstate Commerce” was published on January 15, 2020. 

Shortly thereafter, it followed-up with “Interstate Cannabis Commerce Will Benefit Public Safety, Consumer Choice, and Patient Access.”

Another sub-committee that aims to provide advice on governmental relations published the blog “Working With Your Local Government as a Cannabis Cultivator.

Webinars:

As the committee strives to keep everyone updated on burgeoning legal topics, the SRC committee presented a webinar on Michigan, a newly regulated market. The webinar provided information on this key Midwestern state, “Michigan’s Adult-Use Market – What Comes Next?

Conferences:

SRC members also traveled from across the country to share their expertise on panel sessions at NCIA’s Northeast Cannabis Business Summit in February 2020 in Boston.

The Social Equity Sub-Committee leaders, Erin Fay, Chris Jackson, and Margeaux Bruner provided helpful insight during their session, “What You Need To Know For Winning Applications and Successful Operations That Promote Diversity and Inclusion.”

Sean Donahoe and Gabriel Cross of the SRC’s Interstate Commerce Sub-Committee presented on the issues surrounding interstate commerce and strategies for preparing for this anticipated change in the cannabis industry.

Also, SRC members participated in the NCIA’s summit about tackling the illicit market.

The State Regulations Committee is excited about its work and continues to stay knowledgeable about the ever-changing legal and regulatory landscape. Their projected work includes a webinar on the Illinois adult-use market and a wide range of written projects. Stay tuned!

Banking & Financial Services Committee (BFSC)

The committee’s vision is to provide the NCIA member base with current and actionable information related to Banking and Financial Services in the State legal cannabis industry.

They have implemented monthly newsletters for the member base and have been extremely active in response to the proposed federal legislation regarding banking and the cannabis industry.

Human Resources Committee (HRC)

The Committee’s vision is to provide best practices in all disciplines of Human Resources to NCIA members. They have worked on a couple of blogs this year around the recent reduction in force trend and will be releasing a few blogs providing some recommendations for how cannabis employers can navigate CV-19 when it comes to their workforces.

The HR Committee is working on a very exciting case study. They are looking forward to releasing the first few modules of it this summer!

Marketing & Advertising Committee (MAC)

The MAC coalesces the talents of 20 of the industry’s top-tier marketing and communications professionals around three focus areas: Education, Advertising Access and 2020 political goals. The committee uses their personal, professional and business skills and networks to help build a responsible, legal cannabis industry. The committee is producing best practices, webinars, workshops and social media campaigns to aggregate and generate support from NCIA members, the public, media, government and business leaders.

The MAC Education Subcommittee has focused its energies on developing a Speakers/Expert Directory with a goal to launch by year-end.

The 2020 Subcommittee has created its first infographic covering Oklahoma’s 2020 ballot initiatives; infographics for additional states with legalization initiatives on the ballot this year will follow soon.

The Advertising Access Subcommittee is adding more states (as they come online) to their overarching list of “Do’s and Don’ts” for compliant cannabis advertising. Those are pending editing and legal review and will be published on the NCIA website soon thereafter.

The committee is also working on upcoming webinars including “Advertising Best Practices.” 

Cannabis Manufacturing Committee (CMC)

The Cannabis Manufacturing Committee is focusing on reviewing existing business practices and state regulations of concentrates, topicals, vaporizers, and edibles ensuring the manufacturing sector is helping shape its destiny.

Their first informative blog using lessons learned from the e-cig sector exists in on-going discussions with NCIA’s Safe Vaping Task Force. 

They are also working on their second publication, “Facts About Current Good Manufacturing Practices (cGMPs) And Their Role In The Cannabis Industry” which will be a resource for essential businesses.

In addition to the work the CMC is carrying out, they are collaborating with other committees to help create an NCIA resource library.

The CMC Testing sub-committee is working on writing blogs about “Positives of Testing” (from the operator’s view), and “Nomenclature: Cannabis Nomenclature Register” for publication.

Retail Committee (RC)

Members of the Retail Committee attended NCIA’s Northeast Cannabis Business Conference in Boston in February 2020 to participate in an educational panel on Retail 101. The committee has an upcoming webinar in April: “Retail: Tips and Best Practices” which will include 4 panelists that are currently license holders or working in licensed dispensaries in 3 different states (CO, CA, WA), and will also address some tips and best practices for the current CV-19 climate.

Facilities Design Committee (FDC)

Committee member David Vaillancourt of The GMP Collective appeared on NCIA’s weekly podcast, NCIA’s Cannabis Industry Voice, in February 2020 to discuss GMPs (Good Manufacturing Practices) in an episode titled “Revolutionizing How Cannabis Producers Achieve Success.”

 

Committee Blog: Opportunities & Challenges with Next Gen Packaging In the Legal Cannabis Market

by NCIA’s Packaging and Labeling Committee/ Next-Gen Sub-Committee
Lisa Hansen, Plaid Cannabiz Marketing & Brian Smith, Satori Wellness 

What Is Next Gen, Anyway?!

It’s a new year, a new decade and quite frankly—a new era of packaging in the cannabis industry. We are officially face-to-face with next gen packaging in our ever-growing market. But what is next gen packaging, anyway? By definition, next-generation packaging is “basically a packaging technology, which possesses different advanced features, such as traceability, offers various benefits such as product shelf life extension and provides product quality information.” 

Essentially, it’s taking our cannabis packaging to the next level.

The Growing Opportunities

With new products, formats, and technologies available, the opportunities for next gen cannabis packaging are limitless. In fact, there are so many options for next gen technologies that our NCIA Packaging and Labeling Committee has organized a subcommittee that is dedicated to the topic. We’ve also created subcommittees for Sustainability, Honesty in Labeling and Intellectual Property and Protection. A new era for packaging indeed!

Today’s cannabis cosumers are supporting the legal market for its quality and transparency, and today’s cannabis retailers need accessible platforms to educate them. These dynamics create an environment where next gen packaging (and merchandising) can really shine. With these new tools, brands can immediately engage, inform, and incite action.

Dreams Vs. Reality

While our hopes are super high for next gen cannabis packaging, the reality can be a bit of a buzzkill. In a state-by-state market, the variables for packaging create an inherently significant expense. And with regulations frequently shifting, it makes investing in premium packaging challenging, to say the least. There’s also the complication of managing data and actions behind a next gen platform. Worth the effort? We sure think so. And the good news is that next gen packaging is designed to be measurable so there’s data to evaluate its impact. 

Promising Examples

The applications of next gen packaging for cannabis are seemingly limitless. Everything from a simple QR code, to complicated anti-counterfeiting technology, are possible. Augmented and virtual reality, scratch and sniff add ons, and improved breathability all present powerful opportunities to quickly and effectively affect a purchase decision. 

KURZ is really pushing the boundaries of cannabis packaging with value-added security and technology solutions that are not only effective but purposefully decorative. Think holograms on packaging that can be used for anti-counterfeiting and other special finishes that add pop but are also sustainably produced. Now we’re talking next gen! 

BUNDLAR is getting ahead of the curve with what they call “AR made Easy.” By making aspects of AR technology publicly available as well as offering customization, brands can more easily experiment with this exciting new platform. 

The strategic approach to structural design that Greenlane is taking and the inspiring steps SANA Packaging has made with hemp-based materials are other compelling examples of the momentum in next gen packaging. Perhaps the most promising example of all is that as an industry, we’re just getting started. 

New Decade, New Attitude 

Our subcommittee predicts more exploration in cannabis with packaging that covers the exciting world of next gen possibilities in this new 2020 era and beyond. Which brands will step up? Will retailers ask for it? Will consumers pay for the experience? In an industry that refuses to stand still, these questions will inevitably be answered. The Packaging and Labeling Committee will be watching and sharing more examples and insights in additional articles.

Are you using next gen packaging? Drop a comment and share your experience!

Committee Podcast: The Emerging National Hemp Market

In this interview, industry specialist and NCIA Infused Products Committee member Ashley Hanson of Humboldt Green Light Kitchen speaks with Mike Perry, President and founder of PNX Botanicals, about the emerging national hemp market. Ashley and Mike discuss the relationship between cannabis and hemp products, the effects of regulation on small and medium-sized businesses, and testing standards for hemp CBD products. With state and federal governments rapidly developing new regulations, the conversation focuses especially on improving the conversation surrounding dosing, labeling, and product quality standards.

 

 

NCIA’s Infused Products Committee focuses on edible and topical products, reviewing existing business practices and state regulations. Regulation of these products is the IPC’s initial key focus, but the committee’s purpose is to ensure the infused product sector is helping shape its destiny, rather than being driven by differing jurisdictional regulations. The IPC is also working with the Council on Responsible Cannabis Regulation (CRCR) to develop standardized regulations for legislators and regulators to adopt as their states legalize the industry.

Committee Blog: California Permanent Regs Roundup

by NCIA’s State Regulations Committee
authored by Juli Crockett, MMLG

As 2018 came to an end, the FINAL proposed text of the permanent regulations for California cannabis were submitted to the Office of Administrative Law (OAL) by the three regulatory agencies – the California Department of Food and Agriculture (CDFA), California Department of Public Health (CDPH), and the Bureau of Cannabis Control (BCC). The cannabis regulations submitted to the OAL are currently undergoing a 30-day administrative review to ensure alignment with MAUCRSA and statutory requirements. These “final’ regulations shall become effective immediately upon approval/adoption which should be on/before January 16th 2019.

What “final” means in this evolutionary process of California cannabis regulations is debatable, as there are already several Assembly and Senate bills queued up to be put through the legislative tango and all three of the regulatory agencies have indicated that there will be further clean-ups and clarifications of the “permanent” regulations. Although there will assuredly be changes ahead, this is a highlight reel of where California Cannabis stands now.  

For those that dug into the October redrafts, much of the substantial changes that occurred in that version carried over into the final proposed text. Here we will highlight the top eight changes impacting cannabis businesses in California.  

The Final Statement of Reasons from the BCC, which also included responses to pertinent comments received during the previous 15- and 45-day comment periods, is where some greater clarity about the regulatory changes and intents can be found. It is by spelunking into these deeper caverns of reasoning where the sweet ore of further clarity can sometimes be extracted.  

Here are 8 highlights for anyone interested in California cannabis.  

1. Ownership and Financially Interested Parties

In October we saw the expansion of the definition of ownership and financially interested parties that clearly sought to capture the identification of any and all warm bodies that stand to direct, control, or financially benefit from commercial cannabis. While there were some changes in sections §5003 and §5004 between the previous and current version, the scope and intent remained the same. One particularly vague line §5003.b.6.D “Any individual who assumes responsibility for the license.” was removed from the BCC’s definition of owner, this very line turned up over the in the CDPH’s update in §40102.a.4.D.  

The Ownership and Financially Interested Parties disclosures dovetail into the White Labeling issues (See #2)  in that “Brand Owners” that may be licensing IP to contract manufacturers have been impacted by the prohibition on non-licensees conducting commercial cannabis business with licensees. In the response to comments in the FSOR was this gem of insight, “In response to commenter’s questions, if a licensee includes as one of their owners a brand-owner, the licensee can produce the branded products because in this case the licensee is not engaged in commercial cannabis activity on behalf of an unlicensed person. Because the owner of the brand is an owner of the licensee, there is no unlicensed person involved.” Of course, before everyone runs off and adds brand-owners as owners of their contract manufacturing business, let’s take a moment to reflect on the value and critical importance of a well-drafted contract.  

2. §5032 (b) The So-Called “White Label Prohibition”  

  • 5032.b shall go down in infamy as one of the more talked-about sections of the BCC’s regulations. This simple sentence, “Licensees shall not conduct commercial cannabis activities on behalf of, at the request of, or pursuant to a contract with any person that is not licensed under the Act,” brought with it a level of confusion and white-hot panic regarding the inferred white label prohibition contained therein. October’s version had more explanatory examples for the types of “on behalf of, at the request of, or pursuant to” activities that the BCC was talking about, such as, “procuring or purchasing cannabis goods from a licensed cultivator or licensed manufacturer. Manufacturing cannabis goods according to the specifications of a non-licensee, Packaging and labeling cannabis goods under a non-licensee’s brand or according to the specifications of a non-licensee, Distributing cannabis goods for a non-licensee.” This language was removed in the final version submitted to the OAL and is one of the examples of where the FSOR is enlightening. 

From the BCC’s FSOR: “Initially, the Bureau determined that it was necessary to assist licensees with determining what types of activities may or may not be allowed under the Act and its implementing regulations. The initial proposed change identified certain transactions that would generally be considered commercial cannabis activities under the Act. However, the Bureau has determined that inclusion of the clarifying example transactions is causing more confusion. Accordingly, the Bureau has decided not to move forward with the proposed changes which identify examples of specific commercial cannabis transactions.” The definition of “commercial cannabis activities,” therefore, is an important one, and we can refresh ourselves on that one (Business and Professions Code §26001.k) “‘Commercial cannabis activity’ includes the cultivation, possession, manufacture, distribution, processing, storing, laboratory testing, packaging, labeling, transportation, delivery or sale of cannabis and cannabis products as provided for in this division.”  

This has been a hot, hot topic, and there have been some great analysis articles of this provision that dig further into solutions and scenarios related to this section. Get thee to Google and find out more!  

3. Option to label THC/CBD post-final testing by Distributor

This was a big win for the industry! A substantial percentage of testing failures for “label claims” are due to products, previously required to be labeled with THC/CBD content prior to final testing (the one test that counts!) not falling within the 10% allowable variance threshold. It’s common knowledge that the science of cannabinoid testing is still getting dialed in, and the labs have some serious challenges in hitting the same tiny target twice. Especially when they are dealing with the vast array of cannabis product matrices, and an industry that it still learning about important things such as homogenization. The good news is, the CDPH now allows products to be labeled for THC/CBD content after that all-important final test, which should eliminate well-upwards of 50% of the product failures in California and ensure a steadier supply chain.  

4. Regulation of Technology Platforms

The cannabis industry has always been a place of innovation and loophole-finding. These regulations are an attempt to close some of those loopholes that seem to have created a situation where unlicensed tech platforms were enjoying the privileges of licensed commercial cannabis without undergoing the slings and arrows of local/state licensure and regulation. Seeing themselves outside of the regulatory purview, certain business claimed that agencies such as the BCC had no dominion over their activities. Well, they may have wanted to wait until the ink dried on the final regs before making such an assertion, as now it seems the BCC has expanded its reach to embrace all kinds of advertising, facilitating, and delivery platforms.  

5. Delivery to a Physical Address

This was (potentially) a huge win for patient access, however, it remains to be seen how this truly shakes out. When the BCC added the line that “a delivery employee may deliver to any jurisdiction within the State of California” it caused some serious outrage from municipalities that have banned commercial cannabis activity, the League of Cities, law enforcement, and others that saw this as a huge overstepping of the local authority ensured by Prop 64 and MAUCRSA. The LOC even launched a “wandering weed” campaign, in response to which it seems that a subsection that includes “a restriction on delivering cannabis goods to a school providing instruction in kindergarten or any grades 1 through 12, day care center, or youth center” was added to the regulations, for clarity. Whether the OAL will approve as is, and how this interacts with local bans, tax requirements, and law enforcement, and lawsuits… stay tuned! While the BPC (§26090.e & 26080.b) explicitly prohibits a local jurisdiction from preventing delivery, and transportation, of cannabis goods on public roads, it does not prevent localities that have banned commercial cannabis in their area from adopting ludicrous tax rates for deliveries that would in effect ban via taxation delivery in their area.  

6. Sale of Non-Cannabis Goods (aka No Hemp)  

While the seeming victory of the Farm Bill has folks leaping with joy for the future of hemp, statements from the FDA and other agencies have certainly rained on the parade of many a CBD vendor. Add to that the collections of California cannabis regulations that in effect eliminate hemp-derived CBD from cannabis dispensaries and products.  

“In addition to cannabis goods, a licensed retailer may sell only cannabis accessories and any licensee’s branded merchandise.” (BCC §5407)

This limitation for retail (and retail delivery) is further clarified in the BCC’s FSOR in their responses to comments:  

“Cannabis retailers are licensed to sell cannabis goods. The definition of cannabis within the Act explicitly excludes industrial hemp products. Industrial hemp is regulated by the California Industrial Hemp Program under the California Industrial Hemp Farming Act.”  

“A retail license from the Bureau authorizes the retailer to sell cannabis goods and cannabis accessories. A retail license from the Bureau does not authorize licensees to sell items that are unrelated to cannabis.”

Combined with the retail prohibition on non-cannabis products, this trifecta from the CDPH extends that prohibition to manufacturers:  

  1. “A manufacturer licensee shall only use cannabinoid concentrates and extracts that are manufactured or processed from cannabis obtained from a licensed cannabis cultivator.” (CDPH §40175.c)
  1. “Except for cannabis, cannabis concentrate, or terpenes, no product ingredient or component shall be used in the manufacture of an edible cannabis product unless that ingredient or component is permitted by the United States Food and Drug Administration for use in food or food manufacturing, as specified in Everything Added to Food in the United States, or is Generally Recognized as Safe (GRAS) under sections 201(s) and 409 of the Federal Food, Drug, and Cosmetic Act.” (CDPH §40305.a)iii. “Except for cannabis, cannabis concentrate, or terpenes, topical cannabis products shall only contain ingredients permitted for cosmetic manufacturing in accordance with Title 21, Code of Federal Regulations, Part 700, subpart B (section 700.11 et seq.) (Rev. March 2016), which is hereby incorporated by reference.” (CDPH §40306.a)


For now, it seems, non-cannabis derived CBD is DOA in CA.  

7. Child Resistant Packaging (CRP) Requirement

Heads continue to spin (and cannabis business’ cash to hemorrhage) in response to the changes in the packaging requirements. As of July 1, 2018, all cannabis products were to be in child-resistant packaging, and retailers had converted back to the statutory requirement that all exit packaging was to be “opaque,” allowing them to use reusable totes and paper bags to satisfy this requirement. In the October regs, we saw a pivot that allowed for a seeming “grace period” for the child-resistant requirement to return to being able to be satisfied by the retail via CR exit bag. Some confusion remained as to whether products that were already IN child-resistant packaging would have to be put INSIDE of child-resistant packaging for the next year. The addition of the statement from the CDPH, “Until the date specified [1/1/20] the child-resistant package requirement [§26120] may be met through the use of a child-resistant exit package at retail sale.” (CDPH §40417.d) suggests that the significant ecological impact of CR packaging within CR packaging MAY be avoided, however, most legal counsel will probably be advising retail clients to use the CR exit bag to avoid potential liabilities. Viva Kafka!   

In the CDPH’s Statement of Reasons, they said This is necessary to comply with the packaging requirements in Business and Professions Code section 26120 while providing licensees with time to comply with packaging requirements.” Compliant operators were left somewhat confused, as they had been required to comply with these packaging requirements since July!

8. OSHA Training for Everyone!  

All three regulatory agencies added the following requirement for OSHA training:

“For an applicant with more than one employee, the applicant shall attest that the applicant employs, or will employ within one year of receiving a license, one supervisor and one employee who have successfully completed a Cal-OSHA 30-hour general industry outreach course offered by a training provider that is authorized by an OSHA Training Institute Education Center to provide the course.”

This will be an additional training requirement, on top of existing state and local training requirements for cannabis operators. And remember, all that training documentation must be kept, like all other records, for seven years!

As with everything in life, more will be revealed as we get deeper into 2019.  


Juli Crockett is a member of the NCIA’s State Regulations Committee and is Director of Compliance at MMLG. Slides from Juli’s recent Workshop on this topic are available for download here. You can also watch the workshop video in its entirety on MMLG’s Facebook page.

Member Blog: First Blush And Branding Need To Go Hand In Hand

by Gary Paulin, Lightning Labels

Budding cannabis companies: Pay attention to labels from the get-go

Cannabis companies starting up in states where recreational and medicinal marijuana are just being legalized need to pay close attention to their label branding from the get-go. Too often, this critical part of a successful cannabis business becomes an afterthought — which can lead to major problems in compliance, competitive positioning and credibility in the marketplace.

As the cannabis industry expands in the U.S. and now Canada, it’s also maturing. Gone are the days when a purveyor could hang out a shingle and open their doors to teeming masses of buyers without any substantive concern about packaging and labeling beyond early-day regulatory compliance.

With the industry maturing, so is the sophistication of entities charged with compliance. As more is learned about all aspects of the industry — from edibles to raw cannabis — requirements being placed on purveyors are getting more complex. Plus, there are municipal and state regulations that may cross over one another.

Competitive Positioning
It’s never too soon to get into the branding game, and distinctive labels that grab attention and share important information accurately are key to making a name for yourself.

A Forbes article earlier this year made the case: “Tim Calkins, Clinical Professor of Marketing at Kellogg School of Management at Northwestern University, foresees a highly competitive environment… an outburst of marketing and branding innovation… ‘We will see very creative brand-building activities in the years to come. I anticipate that marketing investment will grow exponentially as companies work to carve out a leading position and capture value in an emerging market…It isn’t often that you see an entirely new market emerge on the scene, especially one where brands will play a key role. Many people first experienced cannabis as a[n] unbranded plastic bag. This is not likely to be the future state. Cannabis will become a market dominated by strong, vibrant brands.’”

Compliance
In their startup enthusiasm, purveyors may miss something on the label compliance scene. It’s easy to do, but can be very hard to fix. Products have had to be recalled, companies have been fined or even shut down for running afoul of regulations. Labels, as a product’s “front door,” are especially susceptible.

A Manufacturing.net report reinforces the point: “Often, cannabis products require specialized labels for traceability and stating suggested medical applications. State laws still vary greatly, and companies should be careful to know and have tools to track their compliance in all states and countries that they do business.”

Bottom line, newcomers to the industry need to be as diligent about their labeling and packaging as they had to be to get license approval. Anything less may result in more headaches than they can imagine.

Credibility in the Marketplace
In Colorado’s early days of cannabis legalization, some labeling and packaging looked — to put it mildly — homespun. The look and feel of that early-day branding pales in comparison to the much more sophisticated label and packaging branding typically seen today.

But for industry newbies, there can still be a temptation to move ahead on operations at lightning speed, with branding, packaging and labeling lagging behind.

Ultimately, that may stifle credibility, giving competitors an opportunity to get a leg up. Ontario, Canada’s experience so far showcases how label problems can hamper credibility. Their online marketplace is the only “game in town” so far; there are no brick-and-mortar establishments. But, in a competitive marketplace, purveyor missteps can cause reputation damage as well as regulatory repercussions.

Notes a Civilized.life article, “Ontario Cannabis Store Faces Backlash Over Improperly Labeled Products… When Peter Lyon logged on to the OCS website on October 17, he did so with the intention of buying a strain high in THC — the compound in marijuana that gets you high. However, that is not what he got… Not only is the error in the product labeling upsetting for customers who won’t be getting what they paid for, cannabis retailers have a legal obligation to ensure that their labelling is accurate. Otherwise someone looking to unwind with a low-THC strain could wind up having a panic attack because the product they bought is way too potent.” 

The first blush of entering a new marketplace deserves branding, labeling and packaging that measure up.


Gary Paulin is Director of Sales and Client Services for Lightning Labels, a  Denver-based label printer that has been offering state-of-the-art affordable, full-color custom labels and custom stickers of all shapes and sizes to cannabis purveyors for more than a decade. They offer many options for materials and laminates and special effects to achieve digital short-run requirements (50 minimum) on up to 15 million labels, plus Lightning fast delivery. For more information and to place orders online, visit LightningLabels.com. For the latest in packaging news and labeling promotional offers, find Lightning Labels on, Facebook, Instagram, Twitter (@LightningLabels), Pinterest, Google+ and LinkedIn.

 

 

Committee Blog: Progression in Packaging – Challenges & Opportunities for Cannabis Brands

Organic Cannabis Product Packaging

by NCIA’s Packaging and Labeling Committee
Lisa Hansen, Plaid Cannabiz Marketing and Brian Smith, Satori Wellness

Exciting Times

Any visit to a licensed dispensary is proof of how far we’ve come with the packaging of legal cannabis. Sure, we still have plenty of standard glass jars, CR pouches, pop-tops and cans; but we also now see proprietary package structures, full branded lines commanding shelf space and packaging so beautiful it doubles as a merchandising tool. Just in the past several months, cannabis packaging design trends have been covered by mainstream media including The Dieline and Packaging Digest.

These are exciting times to say the least, but packaging and labeling remains at the crux of the serious challenges and opportunities that cannabis brands face today.

Keeping Up With Compliance

Here in California, the challenge of keeping up with compliance is beyond real. The race to meet state regs by July 1st were only met with a new set of checklists (literally) the following day. Added labels is the name of the game for any California supplier. This is a real problem for those brands who are trying to stand out with their packaging. Understandably, companies are hesitant to invest in their packaging when the regulations are still in flux. Those who are in this for the long haul need to be agile and forward thinking when it comes to packaging and labeling.

Branding… Because it Really Does Matter

With limitations on how a brand can reach today’s cannasumer, packaging is a critical marketing tool. It’s the one guaranteed touchpoint we have, and just like in traditional retail environments, every second counts when trying to capture a shopper’s attention. While it’s tempting to go with the standard compliant packages, a lack of brand value will commoditize your product (and thus, the price point). Brands should ensure that their package is reflective of their unique position in the market. Whether it’s a regional play, a potency position or targeting the growing number of boomer consumers—your packaging should speak directly to who your target market is. Now is the time to create brand loyalists!

Taking a Note from Natural Products

All across retail industries, we are seeing a market demand for products that have a more “natural” approach. From clean ingredients to plant-based everything, it’s impossible to avoid this trend. As the OG natural product, cannabis brands have a real opportunity to take advantage of today’s more discerning shoppers. Tell your story, explain your growing practices, show us your social responsibility… It’s all part of the package, literally and figuratively.

A Need for Sustainable Solutions

To really take our natural story to the next level, we can all agree on the need for more sustainable options for packaging and labeling. It’s great to see some brands, companies, and organizations like W Vapes initiating recycling programs. But as an industry, we need to rally together to work on this issue. It’s definitely a challenge that NCIA’s Packaging and Labeling Committee discuss regularly.

An Optimistic Future for the Realists

For those cannabis brands who can be agile, patient and focused—there is a bright future ahead. Despite the challenges of cost and compliance, an effective package can pay for itself. And if other industries like food and beverage are integrating technologies beyond the QR code (think AR and VR), we’re just getting warmed up. As both in-store and retail experiences evolve, so will the opportunities for cannabis packaging. Form, function, technology and product development are bound to take packaging and labeling to exciting new heights.

 

Member Blog: Belly Up to Cannabis Barcode Labels

by Mark Lusky, Lightning Labels

In an increasingly hostile marijuana environment championed by Attorney General Jeff Sessions, tracking of marijuana from “seed to sale” is more critical than ever. All other threats aside, if you can’t document it, you’re in trouble.

And, that’s not just at a federal level. In an effort to document total compliance and control of this rapidly-growing industry, states have taken it upon themselves to require comprehensive due diligence from all cannabis purveyors.

Forbes magazine addresses this in a recent article entitled, “Tracking America’s Cannabis Industry Through Big Data.” Citing Colorado, the article states in part, “This harnessing of an information technology to track the cannabis market is key to Colorado’s forceful march towards creating a thriving legal marijuana industry. Crucially, the state’s ability to use tracking and Big Data could provide a reference point for other jurisdictions interested in the regulatory potential offered by tracking. This ‘closed loop’ ‘seed to sale’ inventory tracking system embodies a ‘full traceability’ mode…”

The article continues, “The use of tracking as a regulatory device is expanding, operating in Oregon, Maryland and Alaska. There are other cannabis tracking companies such as MJ Freeway operating in Nevada and BioTrackTHC in Washington, New Mexico, Illinois, New York, and Hawaii. After all, tracking is part of day to day life. We track parcels and Uber drivers with our phones while retailers track us through those pesky cookies on our computers. Whatever the context, whether it is a regulator or us doing the tracking or whether it is marijuana or us being tracked, the technology is an essential part of contemporary commercial and regulatory life.”

Cannabis Barcode labels to the rescue
An established staple in retail and inventory environments, barcodes/QR codes facilitate trackability. Now that message is resonating in the cannabis industry. A primer in motherboard.vice.com points out, “Walk into any licensed cannabis grow op in Colorado and one of the first things you’ll notice are the barcodes.” They point out in another article, “There are a number of advantages of having a bar code for cannabis growers, producers and retailers. The most important is proper inventory control – which is mandated, in Washington, by the Washington State Liquor Control Board. Having bar codes on inventory items allows rapid identification of specific SKUs. The likelihood of inventory quantity irregularities is greatly reduced.”

They also emphasize, “The reasoning behind implementing these cannabis surveillance systems is pretty straight forward. Since cannabis is still illegal on a federal level, the burden is on the states that have legalized weed to prove that legalization has not aided black market activity.”

Systems spring up to support tracking
Regardless of what type of cannabis tracking label is used, sophisticated systems are springing up to oversee the entire process. An article in the Cannabis Industry Journal entitled “The Importance of Traceability” cites insights of Cody Stiffler of BioTrackTHC, one such system, at a Cannabis Labs Conference in 2016: “The primary goals of a traceability system, according to Stiffler, are to prevent diversion and promote public safety. Our software helps get safe products to patients and consumers in a responsible manner. BioTrackTHC’s tracking software covers everything from seed to sale, involving regulatory bodies in oversight. In the beginning of cultivation, each plant is assigned a bar code or sixteen-digit identifier.”

While “location, location, location” is the driver in real estate, “tracking, tracking, tracking” is the name of the game in the cannabis industry.


Mark Lusky is a marketing specialist who has worked with Lightning Labels since 2008. Lightning Labels uses state-of-the-art printing technology to provide affordable, full-color custom labels and stickers of all shapes and sizes, along with barcode labels and consecutive numbering. From small orders for individuals, to the bulk needs of big businesses, Lightning Labels is equipped to handle and fulfill custom label and sticker projects of all types. Lightning Labels was established in 2002 and based in Denver, Colorado. 

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