Common Issues:

• The word “Marijuana” and the universal symbol.
• Abbreviations for milligrams and grams.
• Listing all terpene results from mandatory testing.

Based on ongoing reviews of existing packaging and labeling, as well as feedback from licensees, the Division of Cannabis Regulation (DCR) has identified several common non-compliant issues that affect many products across the industry.

To support licensees and streamline compliance efforts, DCR will not issue violations or settlement agreements at this time for the specific non-compliant packaging and labeling issues listed below. Instead, DCR will allow continued use of these identified non-compliant elements until June 1, 2027.

DCR expects licensees to use this time to exhaust non-compliant packaging and update packaging to compliant versions through their product compliance team facility specialists.

• If item applications with any of the below issues are submitted prior to the deadline above, specialists will advise licensees of the issue(s) and recommend correction.
• If the purpose of including such packaging in an application is to exhaust existing non-compliant packaging before June 1, 2027, the application will not be denied for the non-compliant issues indicated below. Licensees should not take this approval to mean they may utilize that packaging beyond June 1, 2027.
• Any licensees utilizing packaging with these issues after June 1, 2027, should expect to receive educational warnings, notices of violation or other disciplinary actions.

The word “Marijuana” and the universal symbol

Common issue: The word “Marijuana” is wrapped around the container, causing it to be distorted, partially hidden or less visible.

Common issue: The word “Marijuana” and/or the universal symbol on packaging is layered over logos or incorporated into other design elements.

19 CSR 100-1.120(1)(C)1 requires:

• The word “Marijuana” to be clear and conspicuous. “Clear” means “easily visible” and “conspicuous” means “obvious to the eye or mind.” Together, these terms mean the information must be presented in a manner that is readily noticeable, readable and understandable.
• The universal symbol to be “prominently displayed.”  “Prominent” means standing out or readily noticeable.

For “Marijuana” to be clear and conspicuous, packaging must display the word “Marijuana” in a way that does not require rotating the container to read the full word at one time and may not be incorporated into any other aspect of packaging.

For the universal symbol to be “prominently displayed,” it may not be incorporated into any other aspect of packaging. For example, the universal symbol cannot be within a logo design, as such a placement would not be prominent.

Abbreviations for milligrams and grams

Common issue: The abbreviations MG, Mg and G are used instead of the correct abbreviations, which are mg for milligrams and g for grams, both always in lowercase. Incorrect abbreviations on packages are not accurate and may cause confusion. 

19 CSR 100-1.120(1)(C) requires the use of milligrams and grams on packaging throughout. Milligrams and grams are part of the International System of Units (SI). Their official abbreviations are defined by SI standards (refer to NIST: https://www.nist.gov/pml/owm/si-units-mass).

On packaging, milligrams and grams must either be:

• Spelled out in full (milligrams, grams) or
• Abbreviated using the correct lowercase SI units (mg, g).

Listing all terpene results from mandatory testing

Common issue: Requesting terpene analysis during mandatory testing but not including all terpene results on the mandatory label.

19 CSR 100-1.120(1)(C)2.I requires all terpene results, with the exception of non-detects or zeros, to be included on the product testing label if terpene analysis is conducted as part of mandatory testing. This requirement applies regardless of how many terpenes were analyzed or the levels detected.

If a licensee elects to include terpene analysis in mandatory testing, they must ensure that:

• Every terpene with a reported test result is included on the mandatory label.
• No terpene result from the analysis is omitted.

For questions or feedback regarding packaging, labeling and product design compliance or the Item Approval process, please contact the Product Compliance Team by email at CannabisProductCompliance@health.mo.gov. Licensees can find additional information on our website: https://health.mo.gov/safety/cannabis/facility-comms-guidance.php