Whatever the reason you got into the cannabis-product business, you probably did not get into it to deal with rigorous packaging standards and regulations.
Like many other aspects of bringing cannabis-derived products to market, packaging has its own unique challenges that can incur hundreds of thousands of dollars in fines if not properly addressed. However, with a knowledgeable packaging partner, you can successfully navigate the regulations that help ensure product safety.
Common Sense Regulations
Packaging system confidence starts with choosing a reputable and knowledgeable packaging partner. Choose one with experience in regulated industries and preferably one who has some cannabis packaging experience as well. Do not trust a packager who claims certification without knowing all of the needs and requirements of your package. Transparency is key; the more your packaging partner knows about your specific application, the more likely their packaging ideas will work.
Be sure to share details like ingredients, dosage, lifecycle, shelf life, storage, and use conditions. Share whether opacity is required, either due to state laws or for light protection. The lifecycle of a package can impact performance as well: opening a package just once may require different design features than a package that needs to open and close multiple times throughout its lifecycle. Capturing and sharing all the performance requirements will help ensure you’re picking the right package for your use.
You will also need to think about how your package looks both on-the-shelf and at home. While laws vary from state to state, packaging a product that is harmful to children in child-appealing packaging is not recommended. Think twice before showing off your multi-colored edibles through a clear container that a child might confuse with candy (even if a state allows it).
While cannabis is still illegal on a federal level (USA), your Child Resistant Closures (CRC) must adhere to the regulations dictated in the Poison Prevention Packaging Act.
In addition to the considerations, some of which are listed above, these regulations require testing the container system with people (both children and seniors) to ensure that, should a child get access to the package despite all the design barriers, parents have enough time to react to keep their kids safe.
What does CR Certification Entail?
A reputable and knowledgeable packaging partner will only promote “CR” on a container and closure systemthat have passed these tests, however, the test itself is only a part of the full certification of child resistance.
Even if your packaging partner validated and passed the CR test on a given container system, and has the results to prove it, you, and not the packaging company, will be liable should a package fail.Some things to think about:
Document your process and design controls and keep a copy of your CR-testing safe. Proof that your process still follows established protocols can protect you should a package fail. Failing to conduct tests, not recording results, or not ensuring proper process controls in your packaging process can be catastrophic to your business.
At a federal level (USA), fines of up to $100,000 per unit soldwith a maximum penalty of $16 million can easily put any fledgling cannabis venture out of business. There are also profit forfeiture laws and other penalties that should be motivation enough to perform the tests and make sure your systems pass.
What does a CR test entail?
Going at it alone is not recommended. Your package system needs to thwart a child’s attempt at opening, while not overly frustrating folks aged from 50 to 70 to gaining access when needed. If you need to conduct your own testing to validate that a package is CR compliant, find an experienced testing firm that has a large, accessible network of local pre-schools and day-care centers for the children, as well as a methodical way of finding seniors.
Like your packaging partner, be transparent with them about your product type (solid, liquid) and packaging requirements. Also let them know where you’re selling your product, as test methods vary from country to country. Finally, prior to spending the $8,000-$12,000 on testing for CRC, send them one or two container systems to gauge their confidence in the package passing.
Your testing partner should be familiar with the appropriate tests and approach for your application and country. And again, no matter how rigorous your packaging partner’s tests are, you still must determine if these tests meet your requirements. Ultimately, you will be held liable should things go askew.
Here are some helpful questions to ask when working with a packaging partner:
Each country has its own slightly different methods for CRC Testing. The USA test method, for instance, might not meet the Canadian CRC guidelines.
Not all cannabis products need it and not all states require it. (examples: in the USA, Hemp-based CBD may not require CR in all states, some single-serving packages may not require CR)
Some highly concentrated oils are known to deteriorate certain types of plastics. Make sure you know how your product will react with your packaging materials, especially over time.
Example: if your package is a traditional “push & turn” style, torque requirements can impact test results. Understanding the steps taken by your packager during testing can help you replicate them during your assembly and determine its fit for use.
Single-serving versus multiple-servings may have different lifecycle requirements.
Not all material resins or manufacturing facilities are required to be “food-grade” or “pharma-grade”– make sure that your facility & raw materials meet your requirements.
CRC for liquids requires that the package was tested with a liquid and confirmation it did not leak during the testing.
The CR test is found under the Federal Poison Prevention Packaging Act (PPPA, 16 CFR §1700.1) and the test method itself is PPPA, 16 CFR § 1700.20.
Click herefor a list of testing companies from the Consumer Product Safety Commission (CPSC).
Shar Puskala is the Director of Program Management at Berlin Packaging, a worldwide leader in the packaging industry. With deep experience in product design and the management of complex engineering projects, Shar has most notably lent her insights to leading design and commercialization of various Class I and Class II medical devices. Shar can be reached directly at: [email protected]
Your email address will not be published. Required fields are marked *
Name *
Email *
Website
Save my name, email, and website in this browser for the next time I comment.
Comment *
Notify me of follow-up comments by email.
Notify me of new posts by email.
Δ
The legal cannabis industry is thriving in the U.S., reaching its highest-ever number of jobs and sales, a new report shows. Vangst, a cannabis industry job platform, found that at…
Maine is the newest frontier for the illicit marijuana trade, with potentially hundreds of suspected unlicensed grow houses operating in the state, a CBS News investigation has found. It’s part…
Ten years ago this month, Iowa policymakers made it legal to use cannabis for certain medical treatment, marking the start of what would eventually become Iowa’s existing medical cannabidiol program.…
By Tom Hymes Remediation in the cannabis industry has become an increasingly hot topic as the practice has expanded in legal markets throughout the country, and for good reason. Remediation…