The cannabis industry changes day to day. On the one hand, the novelty of the industry gives cannabis entrepreneurs and investors big opportunities for profit; on the other hand, the growing pains of this brand-new industry can make it difficult for businesses to navigate to success. A good example of the challenges of creating products for an industry that is so new is the issue of labeling.
Currently, cannabis product labels are regulated by individual states. Because the U.S. Federal Government continues to control cannabis as a Schedule I drug – one that is dangerous and not medically advantageous – no Federal agencies are involved in cannabis regulation. Unfortunately, as states legalize cannabis in their own time, their own individual agencies develop unique rules and policies surrounding product manufacturing and labelling. The result is a frustrating patchwork of label regulations that make it difficult for businesses to spread to new markets.
Fortunately, changes could be on the horizon. Not only is the Federal Government seriously considering changing its stance on cannabis laws, but a nationwide agency for cannabis labels is in development. With some coordination and some luck, states could adopt a universal cannabis information label that reduces the expenses of packaging, keeps users properly informed and grows the cannabis economy into the future.
All About the UCPS and UCIL
There is significant public and political will to change the current state of the cannabis industry, but as yet only one group of cannabis innovators has recognized the limitations of current cannabis labelling regulations: the Doctors for Cannabis Regulation (DFCR). The DFCR has proposed an improved system for cannabis labeling, which includes a Universal Cannabis Product Symbol (UCPS) as well as a Universal Cannabis Information Label (UCIL).
The UCPS harkens to the familiar caution sign, taking the form of a yellow triangle with a black border and a black cannabis leaf inside. The symbol can be printed in black and white, if color printing is not appropriate or available for a particular package.
Meanwhile, the UCIL borrows its design from nutrition labels present on food packages. Within a simple black rectangle, manufacturers must print various types of information about the product, to include:
- The strain of cannabis used
- The product form – e.g. flower, concentrate, edible, beverage, patch, ointment, suppository, etc.
- The product’s intended use – e.g. inhaled, oral, sublingual, transdermal, topical, rectal, etc.
- The product’s weight
- Suggested serving size (as well as information about serving calculations)
- Servings per container
- Total THC and CBD per serving
- Other cannabinoids and terpenes per serving
- Ingredients or inactive ingredients
- Potential health warnings
- Unit tracking number
- Expiration date
- QR code for additional product and safety information online
Both the UCPS and the UCIL are intended for use on any product that contains THC or CBD, regardless of whether the product is intended for medical or recreational use. Thus, cannabis consumers should expect to see them on essentially every product sold in a recreational dispensary in Aurora, Colorado, but the symbol and information label should also be present on CBD products available in grocery stores, drugstores, supplement stores and other places around the country.
Why Universal Labeling Matters
There are two problems associated with the current hodgepodge of cannabis labeling regulations: It makes it expensive and time-consuming for canna-businesses to move into new markets, and perhaps more importantly, it has the potential to confuse and mislead the consumer. Cannabis isn’t nearly as dangerous as it once was thought to be, but as a substance with psychoactive effects, cannabis should be consumed only by those who fully understand its effects.
The UCPS helps to clarify for consumers which products contain cannabis compounds – which can keep cannabis out of the hands of minors, pets and others who shouldn’t have access to the drug. Similarly, the UCIL demystifies various aspects of cannabis products, from what they contain to how they should be used. This can make cannabis products more accessible to beginners, who can learn from the labels. The UCPS and UCIL have the potential to keep cannabis companies accountable to their consumers. Universal requirements for labeling will lead to universal requirements for testing, which should improve the quality and safety of all cannabis products.
Already, state regulators have shown an interest in adopting the standards of the UCPS and UCIL, but it is possible that few will take any steps to change their policies without Federal intervention. Ultimately, the sooner the Federal Government updates its cannabis laws, the better.
