Recreational Marijuana Product Categorization Guide
Product Categorization Guide
What are the changes starting October 1st?
On October 1st a series of changes will be implemented by the Oregon Health Authority. There is a significant amount of confusion regarding these changes and this memo serves to clarify what producers, processors and dispensaries can expect.
- Testing Changes: On October 1st all new product taken in by dispensaries must be tested by an ORELAP certified lab. Material taken in before October 1st, that was tested by a non-certified lab may still be sold but must be clearly marked that it was tested pre-October 1st.
- Packaging and Labeling: As of October 1st ALL material sold by dispensaries must be compliant with the new packaging and labeling rules. These rules are extensive. The key requirements are listed below.
- 1. All labels must be approved by the OLCC except for generic labels. Generic labels may only contain the information specific to the product/material and no colors, images, logos, etc.
- 2. Dispensaries are not allowed to keep any material or product on their shelves that have an old label on them. There are no exceptions.
- 3. Edibles, extracts, concentrates, topicals may be packaged in non-childproof containers such as boxes or envelopes but MUST leave the store in approved, re-sealable, childproof containers. If the product is single use or dose then the container must be an approved childproof but does not have to be re-sealable.
- 4. There is a list online of pre-approved childproof containers. Any childproof container must be approved. You can find that list on the OLCC website.
- 5. Edibles that can not be scored do not need to be. Instead an edible producer may include a “score guide” explaining to a consumer how to divide up the edible appropriately for a single dose.
- Concentration and dose limits: The new concentration and dose limits take effect October 1st.
- 1. These changes DO NOT impact early sales rules. That means that an OHA dispensary may still, and may only, sell 15mg single dose edible to an early sales adult use customer and one non-refillable container of extract.
- 2. The new medical limits apply to OHA dispensary sales to medical customers.
- 3. The OLCC adult use limits will apply to OLCC sales to rec customers once a dispensary receives their OLCC license.
- The ODA deadline has been extended until the end of the year.
- Early sales through OHA will end on December 31st, 2016 or when a dispensary gets their OLCC license.
- Processor Registration: A dispensary may only accept product from an extractor, concentrate maker, edible maker who is on the provisional list or who has received their OHA processor license after October 1st. That means patients, growers and caregivers may no longer direct transfer processed materials to dispensaries. The only thing push back from October 1st is that a processor in no longer required to be fully licensed by OHA on October 1st.
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