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Packaging Regulations

According to COMAR 10.62.24.01 and 10.62.29.01, the packaging requirements for medical cannabis finished products are as follows:

  • Plain packaging: The packaging should be uniform in color and texture, and may include the product name, manufacturer name, and manufacturer logo.
  • Opaque packaging: The contents of the package should not be visible from outside.
  • Display of Universal Symbol: The packaging must include the Universal Symbol issued by the Commission.
  • Information required: The packaging must include the licensee information, finished-product lot number, expiration date, allergen warning or nutrition labeling as required by law, list of non-medical cannabis ingredients, licensee’s telephone number for reporting adverse events, Maryland Poison Control Center emergency telephone number, itemized cannabinoid and terpene content, and a personalized label for the qualifying patient.
  • Clear warnings: The packaging must bear clear warnings that the product is intended only for the qualifying patient listed on the label, it is illegal for anyone else to possess or consume the contents, and it is illegal to transfer the package or its contents to anyone other than a caregiver for a qualifying patient.

In addition to the previous requirements, as per COMAR 10.62.37.13, the packaging for edible cannabis products must meet the following criteria:

  • Food safe: The packaging must comply with the food additive requirements established in 21 CFR §§174-178.
  • Tamper-evident: The packaging must have one or more indicators or barriers to entry that would provide visible evidence to patients if tampering has occurred.
  • Child-resistant: The packaging must comply with 16 CFR §1700, et.seq. – Poison Prevention Packaging Act of 1970, meaning it should be designed or constructed to be difficult for children under 5 years of age to open, but not difficult for adults to use properly. If the packaging is intended for multiple openings, it must be capable of being resealed and still child-resistant after being opened. However, patients or caregivers may request child-resistant packaging for other medical cannabis products.
  • Multi-serving products: If the packaging contains multiple servings, it must clearly indicate this on the label, along with the number of servings contained within.

There are several general packaging restrictions for medical cannabis finished products, including:

  • Resembling commercially available candy, snack, baked goods, or beverages is not allowed.
  • Statements, artwork, or designs on the packaging must not be misleading about the contents of the package.
  • Designs, illustrations, pictures, or representations that encourage or promote the recreational use of cannabis or its use as an intoxicant are not allowed.
  • The packaging must not bear any seal, flag, crest, coat of arms, or insignia that could mislead anyone to believe that the product is endorsed, manufactured, or used by any state, county, municipality, or agency.
  • The packaging must not contain any cartoons, color schemes, images, graphics, or features that may be attractive to children.

Medical cannabis packaging is not allowed to make any medical or therapeutic claims unless the following conditions are met:

  • The claim is supported by substantial clinical data or evidence.
  • The packaging also includes information about the significant side effects or risks associated with cannabis use. If requested, the relevant supporting scientific research and/or clinical evidence must be submitted to the Commission for review.

According to COMAR 10.62.29.02, all medical cannabis product packages must have a securely attached label that includes the following information:

  • The name of the qualifying patient, certifying provider, product, and licensee where the product was dispensed.
  • The date the medical cannabis was dispensed.
  • The name of the product.
  • The quantity of medical cannabis dispensed, displayed in units appropriate to the dosage form, and concentration of the applicable cannabinoid and terpene compounds.
  • Any directions for use of the product.
  • Instructions for proper storage and handling.

According to COMAR 10.62.37.14, in addition to the general labeling requirements, edible cannabis product labeling must also include:

  • A list of all ingredients and sub-ingredients in descending order of prominence, including any natural or synthetic preservative added.
  • A statement of any common food allergens, as indicated in the Food Allergen Labeling and Consumer Protection Act of 2004, 21 U.S.C. §301, et seq., that the edible cannabis product may contain. This includes, but is not limited to:
    • Eggs
    • Soybeans
    • Milk
    • Wheat
    • Peanuts
    • Tree nuts
    • Fish
    • Crustacean shellfish

Shipping Regulations

– It’s Federally illegal to transport cannabis products across state lines, excluding hemp-derived CBD products
– Importing certain materials such as vape batteries and cartridges may be considered Electronic Nicotine Delivery Systems or ENDS under the PACT ACT, and thus may be challenging to ship.

Extra Notes

Packaging must be child-resistant, must list psychoactive ingredients and establishment’s name.
– Container must be opaque
– No cartoons, no resemblance to candy
– Packaging must be tamper-evident
– Must have allergen warning
– Packaging must be resealable
– Identification of selling establishment’s number

*This document is intended to serve as a guide and should not be construed as legal advice.


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